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“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”

For any consumer-facing businesses, a suspension is likely existential and such appears to have been the case here. But wider implications have to be considered before the two sites are binned forever.

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Application providers, digital platforms, hosting services and media intermediaries must remove irregular advertisements and campaigns after notification from the competent authority. The rapporteur’s version requires that the notification clearly and specifically identifies any content deemed irregular and ensures the right to a fair hearing and full defence. Journalistic, academic, parliamentary, artistic and opinion content are expressly protected. 

Operators and companies linked to them are also prohibited from acquiring, licensing, or exploiting rights to sporting events held in the country. In the area of ​​administrative penalties, the rapporteur’s text incorporates the new infractions into the existing sanctions system in Law 14.790 of 2023, which provides for fines of up to BRL2 billion ($392.8 million). 

One of the main changes made by Vieira is the creation of the crime of promoting unauthorised betting operators. The penalty is one to five years imprisonment. This may be increased by one-sixth to two-thirds when the promotion is done by a digital influencer, athlete, or well-known person, due to their greater ability to reach the public. 

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The group highlighted potential risks posed by Google’s organic search features beyond paid advertising, which include autocomplete and suggested queries. 

Using data collected primarily through Chrome’s incognito mode to exclude personalised search histories, the KVA identified several autocomplete and pre-fill search queries that directly suggested illegal gambling platforms to users.

Examples included phrases like “online casino zonder Cruks” (online casino without CRUKS, the Dutch self-exclusion registry for problem gamblers) and “beste online casino buitenland” (best online casino abroad).