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Even so, suspension is an unusually forceful intervention.

“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”

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Players typically play across various verticals, and by imposing restrictions on specific verticals or betting markets, engaged customers will look elsewhere to access these activities.

“If a customer finds black market sites that have all their preferred betting and gaming options, convenience dictates they will transfer a broad range of their expenditure there. Consumer recycling means that banning or restricting key products has a broader distortive impact on the entire market,” the report noted.

Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.

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