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The Loterij suggested around 200,000 Dutch citizens already engage with unauthorised platforms.

Earlier this summer, the Dutch Online Gaming Providers (VNLOK) trade body initiated legal action against Meta and lodged a formal complaint with the European Commission, accusing the social media giant of failing to prevent the widespread display of illegal online gambling advertisements targeting Dutch users on Facebook and Instagram. 

According to VNLOK, the illegal online gambling market in the Netherlands now matches the size of the regulated sector, with estimated annual revenues in excess of €1 billion ($1.1 billion).

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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk. 

It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.

Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds. 

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Tunisia has competing bills to prohibit or regulate online betting, neither of which has advanced. Egypt has relied on enforcement measures.

In all three, private online betting has no licensing route. Governments are tackling offshore demand through blocking, prohibition and criminal enforcement.

The contrast with land-based gambling is striking. Casinos in Morocco and Egypt operate within recognised frameworks and, in Morocco, attract international investment. Private online betting remains outside the legal market.