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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.
Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.
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The Authority said licensed operators accepted P150 million in wagers in March 2025, paid P135 million in winnings and generated P15 million in gross gambling revenue. It also estimated that only about 40% of Botswana’s estimated 550,000 active bettors were using licensed local operators, leaving a substantial share of demand with unregulated platforms.
By December 2025, Kemorwale said gambling revenue had exceeded P700m, and the Authority expected the industry to surpass P1 billion by the end of the 2026/27 financial year in March 2027.
Kemorwale said Botswana needed to modernise oversight as the sector developed, including through a central electronic monitoring system and stronger enforcement capability. “Truth be told, this industry is evolving as the sun rises. You snooze, you lose,” Kemorwale said. He added that the Authority still relies on outside specialists for some technical regulatory work because domestic expertise is limited.
How to play Solitaire Collection
Spectrum Gaming Group’s 2022 report, which sits at the heart of the long-running dispute between the major games suppliers, has been unsealed as part of Evolution’s legal case against Black Cube.
Black Cube, an intelligence firm hired by Playtech in 2020 to look into alleged illegal behaviour at its rival Evolution, released a divisive report into Evolution’s actions. Evolution denied and refuted much of its findings.
Evolution then commissioned Spectrum Gaming Group to produce a report on its actions and the validity of the Black Cube report. Produced in 2022, the report has long been subject to confidentiality despite Evolution claiming the report exonerated the company.