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Up to 1,124 occurrences of virtual currencies being used were discovered by Spectrum, which added up to 11.5% of the sessions included in the spreadsheet provided by Evolution.
“Spectrum notes that Evolution relies upon its clients to develop and implement these additional AML and KYC procedures. Further, Evolution does not review the operator’s compliance with this requirement of enhanced due diligence,” the report says of Evolution’s compliance processes for preventing the use of virtual currencies.
The full Spectrum Gaming Capital report can be accessed here.
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Depsite it having liberalised gambling in pursuit of the economic benefits that casinos can bring, its regulatory architecture and deeply ingrained social attitudes are not particuarly pro gambling.
The regulatory framework strictly keeps the casino component in check. Casino floor space is capped at 3% of the total floor area of the IR, while Japanese residents are restricted to three visits per week and 10 visits within any 28-day period. Each visit also carries a mandatory ¥6,000 entry fee, reinforcing the government’s intent to curb excessive gambling even as it opens the door to casinos.
Japan’s path to IR legalisation was not straight forward. The IR Promotion Act, which set Japan on the road to casino-integrated resorts, was passed in December 2016 after a contentious debate. Nearly two years later came the IR Implementation Act, which laid out the regulatory frameworks for casinos, from entry restrictions to measures addressing gambling addiction and other social concerns. Yet even as the government pitched IRs as a catalyst for tourism, regional development and economic growth, opposition remained aggressive.
About Money Train Origins
For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.
One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”
Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.