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“Operators do pay, yes, but they pay whatever suits them,” they said. “In other words, we effectively pay what benefits us. All the while, the state has no means of monitoring its regulatory policies.”

In response to these issues, earlier this year the DRC Ministry of Finance outlined plans for a new gambling monitoring platform to enhance its supervision of the sector.

The DRC government is also developing a new legal framework for the gambling industry, designed to modernise existing rules and strengthen oversight of tax collection.

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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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According to a high court ruling from over a decade ago, the tax rise cannot be allowed to rise to the point of ‘consuming livelihoods’. 

“If the tax burden alone makes it impossible to establish the occupation of slot machine operators as the economic basis of one’s livelihood within the municipality,” the ruling said. 

Braun also argued that the public had been excluded from the preparatory finance committee meeting without justification.