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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.

Taking a deeper look at these restrictive driving black market activity, up to 46% of the markets covered in the report enforced “significant advertising restrictions” on the regulated market, including in Belgium, Bulgaria, Coratia, Cyprus, Germany, Italy, Latvia, Lithuania, Montenegro, the Netherlands, Poland, Romania and Spain.

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Atucha warns that regulations are often perceived as operator-friendly at the start before governments begin looking to squeeze licensed sectors, likening the process to “boiling a frog”. He has observed similar scenarios in other LatAm markets, with tax increases occurring in Brazil, Colombia and Mexico in the last couple of years.

Rossi believes the ISC in Peru is an example of a government implementing new taxes without truly understanding how the industry works, and the potential impacts on channelisation to licensed offerings.

“Peru has been quite successful in channelling customers into the regulated framework,” Rossi comments. “The risk is that this channelisation can decrease in favour of the black market. We know the black market won’t have any consumption tax.

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“We had various iterations of the drafts internally probably going back at least a decade, and just never made it to the finish line for various reasons,” he explained.

The board is hoping that the proposal drafts or more or less finalised, though there will likely be input from stakeholders during the comment period and at the hearing. One group that typically weighs in on such matters, the Association of Gaming Equipment Manufacturers, did not respond to a request for comment by Friday’s deadline for publication. Depending on the amount of feedback or potential objections from the Nevada Gaming Commission, the new standards could be adopted and published by year’s end.

Overall, it’s been a busy stretch for the board since the start of 2025. In that time the regulator has issued five multimillion-dollar anti-money laundering fines to entities on the Las Vegas Strip, an unprecedented run of sanctions for America’s gambling capital.