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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.

“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

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This numbered structure works as a soft branding device. It signals to players that a title belongs to a familiar mechanical or presentational family, which can shorten the time it takes a returning player to feel oriented in a new game.

The approach also suits Spinomenal’s release rhythm. The provider ships titles at a steady clip across multiple themes at once, and a repeatable template makes that schedule far more sustainable over time. A useful shortcut, in other words.

Rather than building each slot from scratch, the studio appears to lean on recognizable frameworks it can dress in new themes. 3 Aztec Spells reads as another application of that model, not a departure from it.

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But while the ARGN intends to enhance collaboration between stakeholders across the continent, Akolade asserts the aim is to promote “common principles rather than identical regulations”.

Akolade explains: “Every African country has its own legal framework, culture, and level of market development, so a single model might not work everywhere.

“What we do believe is that basic principles should apply across all markets. These include protecting minors, providing effective self-exclusion options, promoting responsible advertising and ensuring that people affected by gambling harm can access support.