iGamingExpert

bet365: Dutch duty of care ‘allegations will be found to be unsubstantiated’

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bet365 has told iGaming Expert that it will continue contesting a binding instruction issued by the Netherlands gambling authority to improve its duty of care, believing the authority’s findings will be found to be “unsubstantiated”.

Kansspelautoriteit (KSA) stated that an audit of Hillside New Media Malta, the operator of bet365, discovered it had failed to “adequately respond to signals that players may no longer be able to bear the financial consequences of their gambling behaviour”.

In addition, the KSA said bet365 did not take “sufficient intervention measures when this signal was detected”. The audit took place between 6 December 2024 and 6 June 2025.

The Netherlands has policy rules in place for net deposits per calendar month, exceeding €300 for young adults aged 18-23, or €700 for those aged 24 and older.

Operators must conduct a means test to determine an appropriate net deposit limit to check if a player can deposit more without encountering financial difficulties. Player deposits must be blocked if this check can’t be performed.

Following an audit, the KSA noted that bet365 had “not adequately fulfilled its duty of care”.

The authority said: “Before March 2025, Hillside asked players to complete a questionnaire about their income. The KSA already informed gambling providers in early 2025 that a questionnaire is not suitable for conducting a means assessment.

“It was also found that the calculation of the net deposit limit was performed incorrectly. This allowed players to deposit more than they could possibly afford based on their financial situation.”

bet365 objects binding instruction

Under the binding instruction, bet365 now has four weeks to adequately complete the ability-to-pay test for the KSA.

This can be completed by recording and analysing the signals that could signify a player can no longer afford the financial consequences of their gambling behaviour, taking appropriate action if necessary.

If this instruction is not completed, further sanctions could be issued by the KSA, including a fine or the revocation of its gambling licence in the Netherlands.

However, bet365 has objected to the binding instruction, arguing that it has not committed any violation and did not commit a violation during the audit period, so there is no authority to impose such a binding instruction.

“bet365 does not recognise the allegations made by the Kansspelautoriteit,” a bet365 spokesperson told iGaming Expert.

“bet365 places customer safety at the forefront of its activities, and takes gambling protections extremely seriously. We will continue defending this matter through the proper legal process, and remain confident that the allegations will be found to be unsubstantiated.”

2026 supervisory agenda

Duty of care is one of the KSA’s five key themes published recently in its supervisory agenda for 2026, alongside tackling illegal gambling operators, protecting vulnerable groups, supervising advertising and supervising compliance with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft).

The authority stated that online operators’ duty of care compliance will continue to be monitored with a particular focus on the tightened regulations for duty of care, gaming limits and gaming behaviour.

Studies into how providers assess the financial capacity of players will take place. Other areas will be examined, including the speed of behaviour analysis, as well as negative forms of behavioural management by operators and the extent to which this violates the duty of care.

In the early stages of this year, investigations into Cruks notifications and personal interviews will be completed, with recommendations that will be monitored for compliance.

Guidance on AI and monitoring tools usage by operators will be published, while compliance with land-based duty of care will continue to be monitored in accordance with guidance published at the end of last year.

Key priority

Speaking last week at the Annual Gaming Industry Event at the Royal Industrieele Groote Club in Amsterdam, KSA Chair Michel Groothuizen stated that high deposits have been dropping on average, while duty of care has been improving, since the introduction of the mandatory affordability check and net deposit limits.

Groothuizen added that many case files that were examined recently and resulted in fines predated the tightening of regulations.

“Players are not spending such extreme amounts. While that is, of course, disadvantageous for your bottom line, I’m pleased, as the regulator, that these protective measures are working so well. And channelisation, in terms of number of players, doesn’t seem to have been hit too severely either.

“Although things are improving, there’s still plenty to do. The duty of care will therefore remain a key priority for the KSA in 2026.”

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UKGC: operators must make black market ‘commercially toxic’ for suppliers

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The UK Gambling Commission (UKGC) is urging regulated operators to carry a fair share of the burden when it comes to battling back against the black market by making it “commercially toxic” for third-party companies to supply them.

This was the message from the UKGC’s Executive Director, Tim Miller, to industry stakeholders at ICE when addressing the current state of the UK gambling, stating that licensed operators in the market can’t “have their cake and eat” it.

Miller praised the increasing alignment between regulators and the legitimate industry on the importance of tackling the illegal market, adding that the commission is taking action.

He said, between April and December last year, the UKGC issued 592 cease and desists to advertisers and operators, reported 327,964 URLs to various search engines with 203,571 URLs removed so far, referred 839 websites to the search engines for delisting and disrupted 627 websites so that they have either been taken down or geo-blocked.

Miller argued that, as much as regulators and governments need to be aware of the impact they could have on channelisation rates with their decisions, operators need to be mindful of the role they could be playing in growing the threat of the illegal market.

“If we want consumers to make well-informed choices and, if not experiencing harm, remain in the licensed market, then there needs to be clear blue water between that and the unlicensed space,” noted Miller.

“But at the moment, the dividing line is being muddied by those who want to be a part of supplying legitimate, regulated operators, yet are either indifferent to whether they also facilitate the illegal market or are actively seeking to play both sides.

“Gambling regulators across the world are increasingly identifying suppliers, affiliates, advertisers, tech companies and others that work with licensed operators but who are also providing the same services to the illegal market.”

Miller stated that it must be made “commercially toxic” for any supplier to work with an unlicensed operator, even if it results in short term impacts of some competition reduction and consequential upward cost pressures, as it’s a “small price to pay” to not help build the illegal market.

He encouraged operators to go through a checklist before making partnerships, asking how they’re addressing the illegal market threat, their due diligence, as well as contractual provisions that can be put in place to make sure such deals don’t happen.

He continued: “As regulators, we will seek to use the powers available to us to take appropriate action against those who facilitate the provision of illegal gambling. However, when pulling the lever marked ‘legal action’, there is a hard reality that dragging a cloud services company based in, say, California or an affiliate marketer based in Curacao through the domestic courts will not always be practical or possible.

“That’s why, alongside a regulatory or law enforcement response, there is an important and essential role for industry to play. A role that is further upstream. A role with the aim of commercially strangling those third parties that facilitate unscrupulous operators to steal your customers or exploit vulnerable consumers.

“As a global, regulated industry, you have significant economic muscle and considerable commercial leverage. And for all of us here today with a shared desire to fight against the illegal market- well, I think we have overlooked this important and powerful weapon in our arsenal. And it’s time we deploy it.”

Meta

Miller also addressed Meta, which he says has seen more adverts for illegal online casinos appearing on their brand platforms using ‘not on gamstop’ signage to target customers who have self-excluded using GamStop.

The UKGC has been in contact with Meta about the issue, but Miller has stated that they have made “very limited progress” and that they should be doing more to fight against the illegal market.

“Their suggestion was that we should deploy AI tools ourselves to monitor and find these ads and then report them,” he said.

“I would be very surprised if Meta, as one of the world’s largest tech companies, is incapable of proactively using their own keyword facility to prevent the advertising of illegal gambling. It could leave you with the impression they are quite happy to turn a blind eye and continue taking money from criminals and scammers until someone shouts about it.”

Outlook

The recent additional £26m in funding the UKGC has received from the government through last November’s budget was addressed by Miller, who noted that it “recognises the success” the commission is starting to have.

The Government’s Crime and Policing Bill, currently at Committee Stage in the House of Lords, will also allow the UKGC “to obtain orders to suspend internet protocol – or IP – addresses and internet domain names linked to illegal gambling” when enacted. A comprehensive programme for its work against the black market is also in development.

“It’s also worth remembering that the Commission alone won’t be able to solve the challenge of illegal gambling,” added Miller.

“Success will only come through strong collective action with government, with international regulatory colleagues, with industry and with others so that we can hit this criminal market and those who provide succour to it from as many angles as possible – using regulation, using prosecutions, using legislation, using technology, using commercial pressure, using hard powers, using soft powers. Using everything in our collective arsenal.

“No one actor in this space can win this battle alone – we need to work together. We need to work together to ensure that there is no room for suppliers and other companies who want to benefit from the legitimate industry, whilst also actively undermining our collective efforts to tackle illegal gambling operators.

“Government, regulators and industry should no longer tolerate anyone having a foot in both camps. It’s time to work together. It’s time to force them to pick a side.”

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Divisive Dugher sends final black market warning before BGC departure 

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The Betting and Gaming Council (BGC) has announced that Michael Dugher will be stepping down as Chair with immediate effect, bringing an end to six years at the standards body for the regulated UK betting and gaming industry.

Dugher will be moving into a new role as Head of UK Public Affairs Practice at global advisory firm Brunswick Group. He had been the BGC’s Chair since April 2024 and before that he was the organisation’s founding Chief Executive for over four years.

The change atop the BGC comes following some of the most volatile years in UK gaming, at a time when Dugher led the BGC in rallying back against intense lobbying efforts and increased regulatory pressure.

Dugher, who is a former Labour MP for Barnsley East, played a central role in navigating the standards body through the UK government’s Gambling Act review and the publication of the gambling white paper in 2023.

In what was the most significant evolution in UK gambling since 2005, a much-feared outcome was avoided, which would have seen a full blackout on gambling advertising.

However, there was a tightening of online casino restrictions, specifically when it came to slot stake limits and promotions. Dugher led the BGC campaign warning against these types of restrictions, given that they would handicap the regulated industry against the black market.

The outgoing Chair commented on the work with his peers at the BGC over the past few years, stating he was “immensely proud” of what was achieved, thanking BGC members and current Chief Executive Grainne Hurst, as well as ministers, shadow ministers and officials at DCMS.

He also highlighted how “in an era when there is sadly so much ignorance and snobbery about betting – not helped, in my view, by the decline in the number of working-class people in Parliament – the BGC did a difficult job in navigating the industry through the previous Government’s gambling review”..

Dugher continued: “This resulted in a White Paper that, though not without its challenges, avoided many of the most draconian and disproportionate measures advocated by anti-gambling prohibitionists.

“By embracing change and positively engaging with Government and Parliamentarians, we made the case for an evidence-led approach to regulation and legislation that raised standards, protected jobs and growth as much as possible, and delivered historic deregulation and investment for Britain’s world-leading casino sector – all while keeping customers safe in the regulated industry.

“This approach is increasingly at risk today, given the very worrying growth in harmful gambling in the unregulated online black market.”

Hostility between the BGC and Parliament escalated last year during the debate around the Budget, as warnings from the BGC and UK gambling seemed to fall on deaf ears in Westminster.

The BGC failed to hit home with its message during the debate around taxation, as Remote Gaming Duty was raised from 21% to 40%.

Regulatory hostility hasn’t waned amidst the tax hikes, which many have warned will cripple the profitability of operators, as MPs have seemingly taken aim at High Street betting.

It means that whoever comes in to replace Dugher has little time to settle before they are fending off aggressive political rhetoric and potential negative headlines.

Guiding the industry

The BGC spotlighted that, under Dugher’s leadership, 20 new safer gambling codes containing 100 new standards were introduced and adopted by the standards body. Several charity initiatives, including the Britannia Stakes charity race at Royal Ascot and the Grand National Charity Bet, were also launched.

Hurst praised Dugher for his contribution and for bringing “clarity of purpose, a trusted standing with policymakers and regulators, and a steadfast commitment to championing a responsible, well-regulated betting and gaming industry”.

“Under his leadership, the BGC was firmly established as a credible standards body, uniting a diverse membership around stronger consumer protections and a shared determination to do the right thing, often going beyond regulatory requirements,” added Hurst.

“He guided the industry through the most significant regulatory reform in a generation, helping to deliver the Gambling White Paper and shape its implementation in a way that balances consumer protection with the realities of a major UK leisure industry enjoyed safely by millions each month. His leadership was also pivotal in securing long-overdue casino modernisation and proportionate regulation.

“On a personal note, it has been a genuine privilege to work alongside Michael. He leaves a proud and lasting legacy at the BGC, having strengthened standards, unified the industry and ensured it is well prepared for the challenges ahead.”

Industry praise

Dugher has received thanks from industry operators as well, with Ian Proctor, Chair of Flutter UK & Ireland, stating: “Michael worked tirelessly to help establish the BGC as a strong and authoritative body for the regulated industry.

“During a period of significant policy change, his experience and judgement were invaluable in supporting constructive engagement with Government and the regulator, including through the Gambling Act Review and the delivery of the White Paper.

“I would like to thank Michael for all his hard work and, on behalf of the wider industry, wish him every success in the future.”

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Fears tough affiliate regulations will fuel Finland’s black market

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As Finland continues to iron out finer details of its gambling framework ahead of a 2026 launch, stakeholders remain fearful over the current direction being taken when it comes to affiliates and digital marketing.

The cogs of the new legislation will turn throughout the year ahead of the commercial market going live in July 2027. Sports betting and online casino licences will be issued from March, but Lotto, Eurojackpot and physical slot machines will remain under the control of the state-owned operator Veikkaus.

Final decisions will be made on several different components of legislation before the market launches, but alarm bells have been raised that the current direction of the marketing framework will have a major impact on the prosperity of smaller operators.

Digital direction

Jari Vähänen, Co-Founder & Partner at The Finnish Gambling Consultants, believes marketing regulation is unclear at the moment and that it should be leaning more towards the digital scope.

“The legislation approved in December remains imprecise regarding marketing, so it isn’t easy to assess the marketing opportunities in the future license-based market for now,” noted Vähänen.

“According to my interpretation, large operators with sufficient funds to participate in ‘brand advertising competitions’ in mass media will have good business opportunities. On the other hand, the upcoming restrictions on digital marketing will pose challenges for smaller operators. Therefore, there is a risk that several companies will continue to operate in the black market.

“I would have liked to allow licensed companies to compete with modern digital marketing tools and would have preferred to limit mass media marketing, because it targets everyone, not just customers interested in gambling.”

Hippos ATG Chief Compliance Officer, Antti Koivula, is in agreement with Vähänen that limitations in digital marketing could create significant issues in the newly regulated Finnish commercial market.

“My concern is that the new rules are fairly permissive for traditional mass media and sponsorships, but very strict for digital marketing. This creates two big problems.

“First, it pushes more marketing into mass media that people cannot really avoid, including minors and vulnerable groups. If the goal is to reduce harmful exposure, the logic should be the other way around: stricter limits on mass media, and a controlled but workable space for targeted, age-gated digital marketing.

“Second, digital marketing will not go away by prohibiting it. Affiliates, influencers, social media and other digital marketing channels will still exist. If licensed operators cannot use these channels, unlicensed operators will.

“Expecting these channels to stop targeting Finland is unrealistic unless enforcement becomes very strong, including across borders. And right now, that does not look likely. If legal operators cannot compete where people actually discover brands, channelisation will drop, and all the negative effects will follow.

“Overall, I am extremely worried that the current choices will do the opposite of what the reform is meant to achieve: they will help the black market, increase harm, and reduce channelisation.”

Marketing must be responsible

Last month, the country’s gambling bill achieved a bipartisan 158-9 vote to move away from a monopoly of Veikkaus to a regulated, licensed market. Only the President’s signature is required for the bill to become law.

Finland’s National Police Board will make licensing decisions before the Licensing and Supervision Agency takes over regulatory responsibilities in June this year. The process for B2B licences will begin in July next, with a licence becoming a requirement for the market by July 2028.

Koivula urged Finland to change lanes completely in terms of the marketing direction that the country is currently travelling in.

“The starting point is simple: licensed operators must be allowed to market enough so people can find them, compare them and choose them,” stated Koivula.

“If legal operators cannot be seen, demand will not disappear. It will move to the black market. That means less consumer protection, more harm and less tax income for the state.

“At the same time, marketing must be responsible. Finland should not repeat the trend we have already seen under the monopoly system, where gambling harms have grown rapidly. Minors and other vulnerable people must be protected. That requires clear and consistent rules that push marketing into places where exposure can be limited and checked.”

Affiliates may continue to operate with black market

Vähänen also believes that, despite the ban on affiliate marketing, promotions could still occur with black market operators.

“I believe the Finnish media will not accept advertising from black-market operators. At least this has been the case so far. Instead, I am terrified that affiliates will continue to operate, and black market operators will be their only customers, because licensed companies are not allowed to use affiliates.

“The success of the entire gambling system will depend on how the new regulator is able to prevent the business of companies operating without a Finnish license. Unfortunately, I am sceptical about this, but I hope I am wrong.”

Vähänen added that casino operators will be impacted by the ban on affiliate marketing, stating that 50% to 90% of customers are acquired through that channel. Other restrictions will affect operations as well.

“A considerable means is the use of welcome bonuses, which will also be prohibited under the new Finnish system. I assume that the current affiliates that attract Finnish customers will continue their operations and, in particular, direct Finnish casino customers to black market operators.

“This will probably not be as big a problem in the betting business. Influencers are a subcategory of affiliates. I myself would have been ready to ban influencers, but I would have liked to allow, for example, betting and, why not, casino comparison sites.”

The year ahead

Outstanding components that still need to be fine-tuned and clarified include secondary legislation, where game characteristics (e.g. autoplay, bonus buys), maximum stake levels, and game speed will be determined; technical regulations; as well as further guidance on certain key interpretative issues, particularly in areas such as marketing.

How these developments will be issued remains to be seen beyond the dates listed above, as Finland’s parliament will not reconvene until next month, with the election of the President and Vice-Presidents on 3 February, the opening of the 2026 parliament the following day and an oral question and answer session taking place on 5 February.

With 2026 set to be a big year for Finland’s gambling future, what kind of marketing direction should be set out for the European market when commercial operators go live in July 2027?

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Turkey empowers MASAK as gatekeeper of financial transactions

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Turkey’s Financial Crimes Investigation Board MASAK has been granted expanded authority to verify financial transactions to “prevent the proceeds of crime”.

The new powers were confirmed by the Ministry of Treasury and Finance in the latest issue of Turkey’s Official Gazette. It formally notifies public authorities and businesses of new compliance obligations that MASAK will begin to enforce from 1 February 2026.

Under the amended General Communiqué, MASAK is authorised to supervise and mandate identity-verification processes for online transactions, with the directive stating that obligations are being strengthened “within the scope of preventing money laundering and terrorist financing”.

The reforms align with the governing AKP government’s unified strategy against illegal gambling, unlicensed betting and online crime. The policy follows a direct pledge made by President Recep Tayyip Erdoğan, who has instructed state institutions to intensify action against illegal gambling networks ahead of Turkey’s next general election.

MASAK’s authority now extends across multiple digital-facing sectors, including gambling and betting activities, e-commerce services, fintech and payment providers, as well as insurance and pension operators. The communiqué notes that obligated entities must ensure customer identification procedures are applied “before the establishment of a business relationship or execution of a transaction”.

Specific provisions apply to gambling and betting transactions, under which banks are required to verify that payments originate from a bank account that “matches the identity information of the customer”. MASAK states that customer acceptance and transaction processing must not take place until verification is completed in accordance with the new rules.

The framework is designed to ensure that, once verified, gambling-related transactions can only be processed through Turkey’s state-authorised operators, including İddaa (sports betting), Milli Piyango (lotteries) and Türkiye Jokey Kulübü (horse racing). The directive emphasises that these controls are intended to “prevent misuse of financial systems” and to “reinforce lawful fiscal channels to Turkish state enterprises”.

All financial institutions facilitating payments will be required to adopt enhanced customer onboarding procedures to ensure accounts are not falsified, misrepresented or connected to prior criminal activity.

The new powers granted to MASAK are specifically designed to prevent crime syndicates from accessing Turkish payment rails and to disrupt mule accounts and falsified identities within Turkey’s economic system.

The communiqué makes clear that accounts opened under the new framework “shall not be used until identity verification is completed”, effectively embedding banks and payment service providers into Turkey’s digital identity-verification architecture.

Full State Control

Following President Erdoğan’s pledge, Turkish authorities have been instructed to ramp up monitoring and enforcement against illegal online gambling across all state institutions.

MASAK has been charged with leading the government’s wider “Action Plan” to eradicate illicit gambling, coordinating actions with the Ministry of Justice. As part of this effort, Justice Minister Yılmaz Tunç introduced reforms under the 11th Judicial Package, granting prosecutors enhanced powers to seize, suspend and prosecute assets and bank accounts linked to illegal betting operations.

At the close of 2025, the Ministry of Justice also instructed Turkish banks to issue direct warnings to customers, stating that engaging in or facilitating illegal online gambling could result in criminal prosecution and conviction.

President Erdoğan and Minister Tunç have warned that the fight against illegal gambling operators will not be confined solely within Turkish borders. In 2026, MASAK has been instructed to prosecute and take down illegal operators that have knowingly targeted Turkish citizens with gambling offers from jurisdictions including Cyprus, Georgia, North Macedonia and Armenia.

Taking on its expanded powers, MASAK now sits at the centre of Turkey’s all-out enforcement regime under the government’s Action Plan. The strategy reflects the clear political direction set by President Erdoğan, who has stated his intention to eradicate illegal gambling activity that authorities believe has penetrated the Turkish state, its banking and payments infrastructure, the digital economy and professional football.

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Macau accelerates momentum in tackling illicit gambling networks

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Authorities in Macau have thwarted a counterfeit chip scheme that defrauded gamblers of tens of thousands of dollars.

According to local media, four arrests were made in total by the Judiciary Police after suspicions arose following the discovery of fake chips in three casinos operated by the same company in Cotai and NAPE.

The suspects were alleged to have targeted gamblers near casino premises, offering to exchange counterfeit chips for cash.

In one example, a suspect allegedly attempted to exchange seven HK$10,000 ($1283) chips with a male gambler in Cotai, while further investigations revealed 18 more chips in circulation across the three casinos.

In total, the scammers are alleged to have defrauded gamblers out of HK$210,000 ($26,900).

All four claimed that they were hired by a crime syndicate and were promised a minimum of US$2,800 if the scam was successful. They have been charged with involvement in a criminal organisation and large-scale fraud.

Not a new problem

Given Macau’s status as Asia’s largest gambling hub, it is not surprising that the region has been targeted by criminal activity.

In January 2025, a trio of suspects were accused of defrauding a Macau casino of $75,000 through distributing fake chips.

More recently, gamblers lost HK$330,000 ($42,370) after being deceived by money changers.

Though only relatively small sums, this activity will still represent a cause for concern for authorities in Macau heading into 2026, as the jurisdiction looks to build on the positive momentum gathered in the second half of 2025.

The Gaming Inspection and Coordination Bureau reported full-year gross gaming revenue of $30.8bn, up 9.1% from 2024 and beyond the government’s target of $29.9bn. The figure also represents 85% of pre-pandemic levels of gaming.

After a slow start caused by a number of challenging conditions, including the Super Typhoon Ragasa, the early months of the year experienced single-figure revenue growth.

However, fortunes turned a corner in May when the jurisdiction reported a 19% year-on-year rise in GGR to $2.6bn.

This surge was further backed by similar double-figure growth in the remaining months of 2025 – except for September. Macau closed the year with a 14.8% YoY rise in December, recording GGR of $2.6bn.

Setting a fraud-fighting trend

Meanwhile, in mainland China, President Xi Jinping has also spearheaded efforts to crack down on wider fraud and ensure that illicit activities aren’t able to take place in the country.

China elevated its strategy to tackle the significant amount of illicit funds within illegal gambling, a large chunk of which was being funnelled through crypto payments.

This action included the extradition of She Zhijiang, a Chinese national who is alleged to have been the mastermind behind a major illegal gambling network in Southeast Asia.

He was extradited from Thailand back to China, underpinning a level of collaboration across the continent when it comes to thwarting the leaders of illicit gambling networks.

Furthermore, as regulatory frameworks in neighbouring markets continue to shift, expect a number of syndicates to be targeted during 2026 as China and Jinping laser in on the illicit gambling activities taking place across the continent.

The latest efforts by China to detect and prosecute the counterfeit chip game aren’t an isolated case and may well set a trend for future action from China in ensuring that illicit gambling activities and fraud are detected and sanctioned.

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Dutch Gambling to be overseen by new KSA governance model

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Kansspelautoriteit (KSA), the Gambling Authority of the Netherlands, has transitioned to a new governance structure to strengthen oversight of enforcements and player protections.

Effective from 1 January 2026, the KSA operates under a new board comprising one full-time chair supported by two part-time directors. The reform comes as KSA reforms its internal departments that will now function as “three principal directorates”.

Changes will help the KSA sharpen its mandate on improving player protection, digitalisation and data-driven supervision. The regulator said the new structure is intended to “respond to the increasing complexity of gambling oversight, driven by technological developments such as artificial intelligence, the growth of illegal gambling supply, and intensified international regulatory cooperation.”

Chairman Michel Groothuizen remains in charge of day-to-day operations, acting as the organisation’s primary leader both domestically and internationally. Groothuizen will be supported by two part-time board members, whose recruitment and appointment process is at an advanced stage.

The new directors’ are expected to provide strategic expertise and act as sparring partners in areas including governance, integrity and digital transformation.

The change in operational structure sees KSA transition to the three directorates: Player Protection & Management Advice, Permits & Supervision, and Digitalisation, Analysis & Business Operations. The new structure is intended to create “clearer lines of responsibility and enable faster decision-making, while allowing the board to focus more explicitly on strategy, framework-setting and oversight of statutory and societal objectives.”

The transition marks the departure of Vice-Chair Bernadette van Buchem, who has served on the KSA board since 2018. Van Buchem is concluding a 40-year career in public service, including senior roles at the Ministry of Economic Affairs and the Netherlands Authority for Consumers and Markets (ACM).

The governance changes come at a pivotal moment for Dutch gambling, as the Netherlands prepares for a broader legislative overhaul in 2026. The Kamer maintains its pledge to repeal and replace the Remote Gambling Act (KOA), the framework which launched the regulated online gambling market in 2020.

Progress on reform was paused following the collapse of the Dutch conservative coalition government leading to the Netherlands Snap Election in Novemer 2025.

As stands Kamer responsibilities for gambling policy are maintained by Arco Rutte, who was as State Secretary for Legal Protection. However changes are due as a new governing coalition has yet to be formed. Negotiations are currently underway as Rob Jetten, leader of the social-liberal Democrats 66 (D66) bargains with four parties to establish a centrist government.

Despite the political uncertainty, a broad consensus has emerged within the Kamer that the overhaul of KOA should prioritise harm reduction, with specific protections for young consumers under the age of 24.

Lawmakers have also confirmed that the reform process will not include a review of gambling taxation, with the planned increase in online gambling taxes to 38% of gross gaming revenue (GGR) by 2027 remaining in place.

KSA Chairman Michel Groothuizen has acknowledged the scale of the regulatory challenge, stating that future gambling policy must explicitly account for the most severe gambling-related risks, including suicide and minimising financial harms.

KOA licenses have broadly supported the inbound legislative reforms, however the forthcoming government has been urgently warned to fix regulatory discrepancies and product restrictions that have severely weakened channelisation. Latest audits saw channelisation rates fall below 50% of gambling revenues, as the Netherlands had become an active market for black market encroachment since its regulation in 2020.

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Is Uruguay on the cusp of major gambling reform following reopening?

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Uruguay’s casino sector was given a boost at the start of the year after the culmination of strike action saw operations restart.

This was made possible after the General Directorate agreed to negotiate and sign a document that opens a new round of dialogue with the union.

The original action was undertaken in revolt against new frameworks and what was described as ‘a disguised salary cut’, implemented by the new administration, headed by Director General Fernández Estévez.

Such conflict caused venuesto be closed during what would have been one of the busiest times of the year for casino footfall – any further delay had the potential to be considerably detrimental to the wider economy.

Cecilia Alegre, General Secretary of ANFUCE, referred to the situation in an interview with Radio Cadena del Mar of Uruguay (FM 106.5), stating: “It all started when the General Director Estévez, introduced changes that directly affect our jobs, without having gone through collective bargaining, as required by law.

“Furthermore, he informed us that he will disregard a bill regulating online gambling that was approved by an absolute majority in the Senate during the previous legislature. That bill is still in effect, but the new casino management has decided not to pursue it. Our salaries are 80% variable. They always depend on customer traffic in the casinos. And with the rise of online gambling, this will be significantly reduced.”

According to media reports, the proposal was put forward and led to the adoption of a common position, which subsequently saw the reopening of casinos.

Negotiations will continue between the union and the General Directorate, even as casinos have reopened, with the vast majority of them being state-run operations.

There has been much speculation that Uruguay could see significant reform within its gaming framework as it looks to modernise the sector and gain a major economic uplift as a result.

Plans to establish a new National Online Gambling Regulation Agency will undoubtedly have been boosted by the quick resolution to the dispute between workers and the state-owned casinos, with the reform to the gambling sector reportedly set to create north of 20,000 jobs.

There has been a significant need for the overhaul of casino regulation and supervision in the country, with the growth of the illegal sector causing much trepidation.

It is anticipated that the bill will be progressed in the first half of 2026, with President Orsi having previously urged caution when it comes to gambling reform, underpinning that it will be focused on public health outcomes rather than political pressure.

During a recent press briefing, he said: “Regulation cannot be dictated by market pressure or political expediency. It must be guided by what protects our citizens and strengthens confidence in the institutions that govern gambling.”

The bill for modernisation was put forward by Senator Felipe Carballo, as he eyed a “mixed model” in which the state would operate its own gambling platform but also regulate private operators.

The National Directorate of Lotteries and Quinielas would administer the state-owned platform, as well as oversee the licensing of private operators, the regulation of advertising and marketing practices and hold the power to sanction stakeholders and revoke licences.

Carballo underpinned the vital nature of modernisation for Uruguay, as it adapts to the globalised nature of the iGaming market.

He stated: “This paradigm shift has placed the Uruguayan state at a disadvantage in a globalised market, hindering its capacity for supervision, taxation, and control.

“The expansion of transnational platforms, coupled with the use of cryptocurrencies and virtual private networks (VPNs), has reduced the possibility of exercising effective authority over a sector that, if left unregulated, could generate significant economic, health, and social damage.”

There have also been proposals for private operators to be granted the opportunity to apply for licenses, in a system that would be overseen and include a state-owned operator.

A monopoly model would potentially only go some of the way in terms of tackling the growth of the black market, with a monopolised system being limited without regulated competition.

In terms of comparisons, Uruguay may look to emulate the models of Chile and Argentina, which both take a hybrid online gambling framework approach.

Whilst both models have seen the dilution of state-owned operator dominance, providing players with a myriad of options has hindered the surge of the black market in both countries and boosted player protection – both of which are key prerogatives for Uruguay as it evolves its gambling ecosystem.

The timeline for the cementing of the online sector in Uruguay is unlikely to be confirmed until 2027, the upcoming year is a pivotal one for the country and its strategy in gambling evolution.

Debate and conjecture are set to be essential to the year ahead, as details around the next evolution of the market are examined and eventually uncovered – providing clarity on who will be able to enter the market and what their journey will entail.

Whilst there appears to be widespread commitment to the bill developing, there will still be caution given the faltering of a previous bill in 2021.

A key reason for the bill falling five years ago was fractions over the potential decision to enable operators to gain an online license without having a physical presence in the country.

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TOTO Online to reassess player files after Dutch AML ruling

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TOTO Online has promised to reassess player files to make sure its customer due diligence is enhanced following a notice being issued by the Dutch gambling authority, Kansspelautoriteit (KSA), over anti-money laundering violations.

The KSA recently investigated TOTO Online operations – TOTO and Winnitt – discovering violations of the Netherlands’ Money Laundering and Terrorism Financing (Prevention) Act (Wwft).

In response, the Dutch lottery Nederlandse Loterij, the parent company of TOTO Online, said in a statement that it wants to work with the KSA to combat money laundering and has worked with the regulator to improve its operations, a position that was echoed by the KSA.

The operator will also improve its customer due diligence by reassessing player files and making further changes where required.

“TOTO acknowledges the importance of effective supervision by the KSA. We continuously work to strengthen our position as the safest and most responsible operator, including with regard to anti-money laundering compliance.

“Together with the KSA, we are committed to achieving the best possible results in combating money laundering. In consultation with the Ksa, TOTO has already further tightened its processes, procedures and work instructions during the course of the investigation.

“As a result, we meet the regulatory requirements with regard to risk assessment, transaction monitoring and verification of the source of funds used, as is to be expected of us.

“The KSA has also indicated that our customer due diligence should be further improved. We are therefore reassessing player files and will take additional measures where necessary.”

Monitoring and documenting failures

According to the KSA, the investigation discovered that TOTO Online “failed to comply with the ongoing monitoring of business relationships and their transactions”, which is a requirement after initial client due diligence.

In addition, the regulator said the operator “does not sufficiently document why new facts or events do not lead to an adjustment of client risk classifications and why it takes certain control measures”, while also the investigation into player funds origins was inadequate.

While improvements have since been made by TOTO Online, a timeline of six months has now been set for the operator to resolve the outstanding violations, after which the KSA will conduct a re-inspection of its operations.

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Unibet takes aim at KSA interpretation of legacy Dutch iGaming rules

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FDJ United’s Unibet brand has told iGaming Expert that it “could have acted sooner” in some duty of care cases with players in the Netherlands, which resulted in a multi-million euro fine from the Dutch gambling authority, Kansspelautoriteit (KSA).

However, the operator has contested some of the conclusions the Dutch regulator has reached with its investigation, stating that the rules during the period of the failings “were less specific than they are now”.

Issuing its defence to the sanctions, Unibet has challenged the KSA over the clarity of Dutch iGaming regulations. The Netherlands’ iGaming framework has been subject to significant changes in the years since the online market was launched in 2021 and during which Unibet’s breaches occurred.

Duty of care failures

The KSA issued a €4m fine to Unibet’s operator in the Dutch market, Optdeck, for failing to comply with duty of care responsibilities between 14 July 2022 and 1 July 2024.

After requesting various player files from Optdeck, the regulator found that all files showed duty of care violations. These included depositing thousands of euros per day with no intervention upon signs of excessive gambling, as well as income information being requested weeks later, even after substantial losses occurred.

The KSA added that the interventions selected were “far too light”, such as easily dismissible pop-up windows, as well as that during financial checks, income streams that aren’t permitted, such as a company account, were included.

Michel Groothuizen, Chair of the KSA, commented: “When there are signs of excessive gambling behaviour and someone wagers a large amount of money in a short period of time, a provider must promptly investigate the source of the money. This can be done by requesting income information.

“It is essential that providers conduct this analysis properly, because not all financial resources can simply be included. The KSA takes violations of its duty of care very seriously and will continue to take strong action against them.”

Rules were less specific than they are now

FDJ United responded sharply to the fine against Unibet. Although acknowledging some mistakes, the French multinational has highlighted some key elements of the KSA investigation and subsequent decision which it disagrees with.

“Unibet takes this matter and its duty of care to provide a safe gaming environment at all times very seriously,” an FDJ United spokesperson told iGaming Expert.

“We acknowledge that, with the knowledge we have now, we could have acted sooner in the case of some of the players investigated. At the same time, we do not agree with some of the conclusions.

“The decision relates to the period June 2022–July 2024, when the rules were less specific than they are now. We applied those rules to the best of our knowledge. In its decision, the KSA applies a stricter interpretation than what was stated in the rules at the time. The legislation and regulations have since been tightened and, since October 2024, there has been a clearer framework for gambling limits.

“Since September 2024, we have been working with a new risk detection system that identifies risky gambling behaviour more quickly and leads to stricter interventions. We are also taking additional measures to protect players. The issues referred to by the KSA are no longer possible on our platform.”

Previous fines

This isn’t the first time Unibet has received disciplinary action from the KSA this year. Back in June, the regulator sent two warnings to the operator for advertising and autoplay failures linked to a cycling team sponsorship and a BonusBuy function in one of their titles.

Unibet noted at the time that the brand took the KSA’s warning “very seriously and took immediate action” to correct the errors, including adjusting branding and compensating affected players.

However, the FDJ United brand received another sanction in September for offering unauthorised sports betting – football betting on corner kicks and yellow cards, as well as on under-21 matches – on several occasions between October 2022 and May 2025.

Under the country’s gambling law, it is prohibited to offer betting on certain matches and event components to protect the integrity of the sport and prevent match manipulation.

The KSA said it repeatedly contacted Unibet about the offering but saw “insufficient improvement and a real risk of recurrence”, so a penalty of €75,000 per week on Unibet for each week in which a violation occurs was imposed, with €450,000 being the maximum penalty.

At the time, Unibet stated that following previously identified errors in its sportsbook offering, it collaborated with its sportsbook provider “to modify the systems to be compliant and aligned with the feedback from the KSA”.

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