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“They are currently aggressively growing the Hard Rock Casino brand, with developments under way in Las Vegas, New York City, Greece, Puerto Rico and Jamaica. They will put forth an attractive development proposal, and it appears that they now have the support of local government,” Klebanow notes.

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.

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Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website. 

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The report assesses black market activity across 28 European jurisdictions, including the UK, Netherlands and Germany. According to estimates across a mature black market ecosystem, 25 operators account for approximately 64% of relevant black market traffic.

Thanks to the “rapid growth of crypto currencies” and globally recognisable branding through marketing and sponsorships, this handful of operators are generating the majority of illegal gambling traffic across Europe.

The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.