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Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website. 

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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.

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In January 2024, before locally licensed online operators were active, the Authority said it had recorded about 510,000 monthly cases of Botswanans participating in illegal online gambling.

Sunbet Botswana launched its online sports-betting platform in February 2025 and reported a 4,700% increase in sign-ups during its first month. As this was an operator-reported figure, the company did not publicly disclose the comparison baseline or absolute number of registrations.

The Authority said licensed operators accepted P150 million in wagers in March 2025, paid P135 million in winnings and generated P15 million in gross gambling revenue. It also estimated that only about 40% of Botswana’s estimated 550,000 active bettors were using licensed local operators, leaving a substantial share of demand with unregulated platforms.