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That would also shift the basis on which studios compete. If sophisticated development capabilities become accessible to a wider range of creators, scale alone becomes less of an advantage.

“It becomes less about how many developers you employ and much more about how creative you are and how well you understand the player,” Curwen says.

For an industry already producing content at enormous scale, that distinction is important. The promise of Game in a Box and Studio in a Box is not simply that they can help put even more games into an already crowded market.

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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.

In June, one of the operators, TOTO online BV, was reported for violating the ban on featuring role models in advertising materials.

This was not the first time TOTO has been in trouble with KSA. The platform was fined in 2022 for a similar endeavour – gambling advertisements that were seemingly aimed at young people.   

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Prosecutors allege that five suspects had operated internet-based gambling services without the required German licences from at least July 2021. The volume of bets placed on these platforms reportedly exceeded €5.8 billion between mid-2021 and the end of 2023. 

In addition to illegal gambling, investigators suspect extensive tax evasion, with a projected tax shortfall of about €77.6 million for 2024.

The DSWV, representing licensed sports-betting operators, broadly welcomed the law enforcement action as a necessary response to the illegal market’s growth and associated risks.