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Notably, it has also provided insight into the evidentiary standards French courts expect operators to meet before taking corrective actions that could be subject to legal challenge.

The regulator identified six key categories of fraud frequently encountered in online gambling. These included identity fraud, payment fraud and abusive chargebacks. It also covered in-game cheating, money-dumping and sporting event manipulation

For each category, the guide explained pertinent legal provisions and recommended operational actions. 

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The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.

“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.

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Enda Kendrick, chief executive of service provider Veltium, similarly says the largest UK and European sharp-betting groups have moved rapidly into US prediction markets. He believes there are also more than 100 smaller operations, ranging from individual traders to teams of around 10, interested in entering the regulated US market.

Yet the presence of professional counterparties complicates the customer-facing idea that prediction markets merely allow users to trade opinions with one another. As Kendrick puts it, two ordinary customers are not going to place $10 million or $20 million behind the Philadelphia Eagles. Markets at that scale require institutions.

For Marantelli, the exchange format could also cause some customers to lose money faster than they would with a conventional sportsbook. The ability to enter and exit positions creates a perception of flexibility, but that optionality can encourage users to commit more of their bankroll.