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All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.

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The NLRB ruled after the election that Red Rock took steps to prevent a fair union vote, and Red Rock sued in response, although the ruling was upheld by the US Court of Appeals for the District of Columbia last month. After the court denied a rehearing request on 6 August, it also subsequently denied Station’s request for a stay pending SCOTUS relief on 24 August.

Red Rock may still petition SCOTUS to hear the case, and the court could still choose to do so, but in the meantime the casino must comply with the NLRB ruling. The ruling requires the casino to recognise and bargain with the union upon request, post employee rights notices and other measures.

“The NLRB decision overturned the clear vote of Red Rock team members rejecting the Culinary Union,” Station said in a statement. “The decision prevents any company from granting benefits to its employees if it is aware of union interest in unionising the company’s employees and nullifies the Red Rock team members’ vote to be union-free, all because Station Casinos treated its team members too well.”

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Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

Madsen says investigators can also examine how sites appear from different jurisdictions. If a site is presented in a country’s local language, for example, that can indicate that the market is being targeted. The next question is whether the operator has the necessary licence.

The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.