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“If a customer finds black market sites that have all their preferred betting and gaming options, convenience dictates they will transfer a broad range of their expenditure there. Consumer recycling means that banning or restricting key products has a broader distortive impact on the entire market,” the report noted.
Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.
As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”
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The proposal does not explicitly prohibit the display of betting brands on team jerseys, but some city councillors want to include this in the bill.
Clubs fear the measure will jeopardise revenue from betting company sponsorships. Corinthians (Esportes da Sorte), Palmeiras (Sportingbet), and São Paulo (Superbet) alone hold contracts worth BRL350 million annually with betting firms.
One concern is the measure might force clubs to host matches outside the city to maintain their advertising agreements.
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In response to the penalties, Dabble Sports has agreed to a two-year court-enforceable undertaking. It has obliged the company to commission an independent review of its compliance systems. Dabble must develop a board-approved plan to implement these changes with appropriate resources.
An ACMA spokesperson reiterated: “BetStop is an important consumer protection measure, but it only works if wagering companies follow the rules.”
As of January 2027, BetStop will be further promoted as part of a reform package to gambling laws in Australia. Following a statutory review, the government committed to improving system usability and boosting promotional efforts. It is also committed to funding ACMA marketing to support BetStop and recovering operational costs from industry participants.