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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.
Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation.
This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.
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However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.
Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements.
The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.
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When asked which operator will be willing to take the risk and ultimately win Japan’s next “licence lottery”, Klebanow contends that it depends on how restrictive – or attainable – the regulations and requirements imposed by the government will be.
“If policymakers once again impose onerous policies that limit a property’s profit potential, then most developers will not take the risk of investing upwards of $10 billion in an IR development,” says Klebanow.
One exception, he notes, could be the Seminole Tribe of Florida and their proposed Hard Rock Resort Casino in Tomakomai, Hokkaido.