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Messaging and targeted advertising: The restriction also extends to instant messaging, SMS, email, notifications, advertising automatically targeted by algorithms, telemarketing – which shows ads again to people who have already been exposed to certain content – and profiling based on user behaviour.
Other means of dissemination: The prohibition includes advertising in electronic games and esports, sports uniforms and equipment, public transport and affiliate content, tipsters, comparison sites and other paid intermediaries.
Promotions and benefits: Bonuses, promotional credits, free bets, cashback, free spins, rewards and loyalty programmes used to encourage membership, retention or return to betting are prohibited.
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“Some of them [investors] that were looking at Japan were looking at a big IR licence or nothing. With Tokyo and Yokohama being out of the mix, maybe some weren’t as interested anymore and decided to sit back, and wait and see how regulation and licensing shake out.”
One concern for operators is “the short duration of licences and renewal of licences”, notes Leckert. For operators, the casino business licence is renewable every three years, while the IR development-plan authorisation runs for 10 years, in contrast to the 18-year IR licence term in the Philippines, for instance.
Limiting the duration of licence validity “puts the entire capital investment at risk”, says Klebanow. Further regulations, including limiting residents to 10 visits per month and requiring them to present a ‘My Number Card’ when gambling, further erodes project viability. “Ultimately, casino developers individually concluded that developing an IR was too risky, and they took their billions of dollars in potential capital investment and walked away,” observes Klebanow.
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Strip away the language of contracts, order books and event trading and Bernard Marantelli has a blunt description of what is happening inside US sports prediction markets. “Kalshi is a sportsbook that’s just not allowed to have an in-house risk team,” says the founder of White Swan Data, one of the specialist firms now making markets on prediction exchanges.
The difference is all about the risk function. A sportsbook employs traders to price bets and manage its exposure. An exchange provides an API through which firms compete to quote prices and supply liquidity.
“Here’s an API. Bernard and 88 other people can market-make all these request-for-quotes (RFQs),” Marantelli says. “Some people might come in and just do esports because they’re esports experts. Others do everything. Some focus on same-game parlays. But it’s a sportsbook.”