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The pair established Sanum Investments and partnered with Laotian conglomerate ST Group. Baldwin later testified that the investors initially committed around $7.5 million to the venture, which envisaged two casino resorts and several slot clubs.

Their biggest success was Savan Vegas, strategically located near the Friendship Bridge linking Laos with neighboring Thailand across the Mekong River. A planned second resort, Paksong Vegas, was never built.

Within several years, however, the partnership had soured.

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“If a customer finds black market sites that have all their preferred betting and gaming options, convenience dictates they will transfer a broad range of their expenditure there. Consumer recycling means that banning or restricting key products has a broader distortive impact on the entire market,” the report noted.

Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.

As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”

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Entain emphasised offshore operators do not employ the same player protection measures and anti-money laundering standards that licensed companies must.

The company also highlighted its own research that suggests over 80% of consumers cannot “confidently distinguish” licensed operators from unlicensed ones.

Stella David, Entain’s CEO, called for the government to move ahead with the ban immediately, arguing clubs were already aware of the planned changes.