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The review examined the gaming sector and associated money laundering, terrorist financing and proliferation financing risks.

Spillemyndigheden said it contributed actively to this work and sat on FATF’s gaming sector working group. The regulator confirmed that many of the indicators in the report carry relevance for operators licensed in Denmark.

FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history. 

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“It was still very much a trading kind of UX,” he said of Kalshi at the beginning of the year. “The actual product offering has come a long way.”

Andrew Gonzalez, founder of prediction market infrastructure startup ParlayX, believes the ability of small teams to provide liquidity is one of the sector’s defining features. “Anyone can be a market maker,” he said. “You have these two- or three-man shops.”

Jefferies described market makers as the ecosystem’s “liquidity backbone”. They post executable bids and offers, manage inventory and provide prices when customer activity is heavily weighted to one side.

What is Scratch Cards - Scratch & Win?

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.

Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.