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That effort has led the government to Baldwin, Scott, and Bridge Capital, even though none was personally named as owing the money in the arbitration awards.

Laos argues they were effectively indistinguishable from the companies that were ordered to pay and should therefore be held responsible for the debt.

A federal judge previously rejected Laos’ attempt to pursue Baldwin and Bridge Capital because they had not been parties to the original arbitrations.

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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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The CGMC reviewed a draft of the new evaluation framework during a meeting chaired by Secretary General Yeth Vinel on 4 September. 

The proposed “integrity and quality” framework aims to establish minimum conditions that operators must meet to maintain or obtain a licence, signalling a strengthening of oversight in the sector. The details of the scoring criteria and an official implementation date remain unpublished.

The timing of regulatory tightening coincides with a vigorous government campaign against scams and illicit financial activities linked to casinos.