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“There are valid arguments to be made in relation to raising the barriers to licensing, but this may come at a cost of diminishing competition and entrepreneurship,” he says.

In any event, successive regulatory tightening and tax increases have already created a “reasonably effective deterrent” to market entry.

There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

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Cambodia’s gambling regulatory authority, the Commercial Gambling Management Commission of Cambodia (CGMC), is advancing plans to introduce a formal suitability screening process for casino licence renewals. 

The CGMC reviewed a draft of the new evaluation framework during a meeting chaired by Secretary General Yeth Vinel on 4 September. 

The proposed “integrity and quality” framework aims to establish minimum conditions that operators must meet to maintain or obtain a licence, signalling a strengthening of oversight in the sector. The details of the scoring criteria and an official implementation date remain unpublished.

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An interview carried out by Black Cube with CEO of games developer Ezugi Kfir Kugler had allegedly confirmed that Evolution knowingly provided games in markets sanctioned by the New Jersey Division of Gaming Enforcement.

Spectrum conducted follow-up interviews with these employees who had “provided derogatory information relating to Evolution’s business practices”.

It said all interviewees had cooperated fully and some of them had “virtually little or no familiarity with the allegations contained in the report, as their job responsibilities fall outside the scope of these matters”.