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He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

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“This is unacceptable. It is encouraging to see Skyhills go offline immediately after our initial action.”

Skyhills is the third illegal operator targeted by Nederlandse Loterij, with prior legal action taken against Lalabet and Qbet. 

The Lalabet case, which reached a milestone in June, saw a Dutch court rule largely in favour of the lottery operator.