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However, due to its role as a a state-owned bank, and ongoing scrutiny around betting in Brazil, Caixa has come under political pressure, and its launch in the market has been postponed on several occasions despite it having paid the BRL30 million ($5.9 million) licence fee.

In April, under pressure from Brazil’s President Luiz Inácio Lula da Silva, Caixa postponed its launch until 2027 at the earliest.

Brazil is currently gearing up for a general election next month and Weizer said this had delayed Playtech’s launch in the regulated market, although he didn’t specifically name Caixa as its client.

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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.”

The institutional layer is largely invisible to customers presented with a P2P proposition. Retail users may technically trade against one another, but the depth required by a mass-market product cannot be supplied by occasional customers alone. Professional firms must be prepared to quote continuously and commit substantial capital.

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FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history. 

The case highlighted how illegal operators disguise their presence through multiple site variations, a tactic the FATF report also flags as a red flag indicator. 

Denmark’s approach reflects a wider pattern that FATF has tracked for years through its own grey and black listing system. Under this system, jurisdictions with weak AML/CTF controls face increased monitoring or reputational sanction.