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It is important to stress that the Commission has not published detailed findings or established that breaches occurred. Customers can still access their accounts and withdraw funds. Following the closures the sites still provided messaging about the suspended licences.

Even so, suspension is an unusually forceful intervention.

“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

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Respondents identified several priorities for improving VIP operations. These included an integrated system combining player data, communication history and task management. 

Respondents also requested structured and consistent guidelines with key performance indicators aligned to relationship outcomes. Real-time, detailed data alongside predictive behavioural signals also came up as a frequent answer.

Managerial autonomy supported by senior leadership was also mentioned by respondents.

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“The Court should refuse the relief requested by … because it is manifestly contrary to the public policy of the United States based on the Debtors’ well-documented and pervasive bad faith conduct,” the petition said. “The Debtors are using the Israeli Action—a limited action which lacks many of the core characteristics of a collective insolvency proceeding—as a strategic tool to evade responsibility for their deceptive conduct.”

On Aug. 26, Tel Aviv District Court Judge Iris Lushi-Abudi rejected Papaya’s motion to pay down the Skillz judgment over 6.5 years with profits from its continuing operations.

Yaron Elhawi, an attorney based in Tel Aviv representing Skillz, said in court filings that Papaya has not proposed a reformulated debt arrangement, nor suggested how it intends to treat Skillz’s debt.