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One Foundation’s operating licence was suspended for six days after the DIA identified accounting failures relating to gambling proceeds, as well as a failure to surrender a licence for one of its pokies venues when required by law.

The DIA also issued new financial guidance for class 4 operators, with the aim of providing greater clarity on their accounting requirements and an explanation of their obligations.

The department said the guidance had been designed to “improve consistency across the sector and help prevent similar issues from occurring in future”.

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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.

A customer might buy a team at 55 or 56 cents expecting the price to rise to 58 or 59 cents, he explains. If it falls to 45 cents instead, the trader may refuse to accept the loss and continue holding the position.

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In July the Commission said its investigation had discovered the supplier had failed to maintain adequate anti-money laundering and customer due diligence controls in the UK.

It considered suspending Evolution’s licence, but the supplier acted swiftly, carrying out ring-fencing controls across Europe to prevent its games from being used in grey markets.

Evolution’s case against Black Cube continues. It even sought to add Playtech as a defendant in April.