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Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.

For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.

The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.

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The president is not seeking to introduce the measures through a full bill, as the legislative process in Congress could reduce their immediate political impact ahead of the elections.

Some factions within the government, especially the Ministry of Finance, are resisting more drastic measures. The Ministry of Finance, responsible for regulating sports betting and online gaming, understands the sector’s importance to the economy. Finance Minister Dario Durigan’s difficulty lies in convincing Lula that a well-regulated activity is important for public finances. Lula has said, in line with critics of the sector, that if it were up to him, he would end betting in Brazil.

The president’s critical view of betting is on par with other candidates. Studies by the Workers’ Party (PT) indicate that three out of four Brazilians are against betting establishments. This is the president’s justification against the sector.

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Its noisy and crowded parlours, he notes, do little to attract Japan’s critical demographic of women aged 40 and over. They “do not find pachi facilities comfortable or appealing”.

Given that women account for nearly 60% of gaming customers in the US, Klebanow argues that Japan’s IRs should instead offer environments where this demographic feels “safe and comfortable”. The key lesson from pachinko, he concludes, is therefore “not to create gaming environments that mimic them”.

Ultimately Leckert remains positive on Japan’s IR opportunity. “Stringent regulation really supports a strong industry,” she says. “I don’t see those being at odds with one another, because it’s been done very successfully elsewhere.”