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For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.

The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.

Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.

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According to The Intercept, some content even uses expressions like “leaving the CLT [Brazilian labour law]” and “your dream income” to promote this type of activity. There are also screenshots of alleged user earnings and posts that present gambling as a kind of investment.

These professional content creators on Instagram aren’t limited to sports betting. There are niches of creators focused on casino games, like the controversial Fortune Tiger, with a communication strategy similar to that of sports betting.

Another influencer (fictitious name, João) shares live game-style videos on his stories, simulating high-paying gaming sessions. In them, he points out which operator or game “is paying the most”, while in another piece of content, he posts a screenshot of his exclusive Telegram group, where he shares “highest payout” times for betting on specific games.

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As highlighted by Klebanow, Japan’s fragmented approach to gambling regulation may impact the development of Japan’s IR gambling industry, and Suzanne Perilloux Leckert, co-founding partner of Convergence Strategy Group somewhat agrees.

“Japan is acting cautiously, after observing missteps from other jurisdictions. They are proceeding in the way that best suits them,” she adds.

The factor that led some operators to drop out of the licensing race could be the “uncertainty” created by regulations that “didn’t seem set in stone”, says Leckert.