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“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”

For any consumer-facing businesses, a suspension is likely existential and such appears to have been the case here. But wider implications have to be considered before the two sites are binned forever.

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In a third publication, he “teaches” the gambler to observe patterns in the game interface, such as an animation on the tiger’s face, a specific glow that appears or a sequence of supposed events that indicate that the big win is about to happen.

On the Instagram profiles of gambling operators, the content varies according to the brand’s strategies. It ranges from the use of humorous and entertaining videos to the generic use of AI in banners advertising promotions, available casino games and important sporting events with betting odds.

Most of the accounts recommended by Instagram’s algorithm are irregular, especially those from international companies that, although they may be legal in their country of origin, do not have authorisation from the SPA to operate in Brazil, and are therefore illegal.

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The regulator concluded that the central figure’s youthful facial features, casual styling and excited demeanour gave the impression he was in his late teens or early twenties. 

As such, the ad violated rule 16.3 of the CAP Code (Edition 12).

Midnite’s operator, Dribble Media Ltd, stated that the ad had not been authorised by their company. They cited discrepancies in branding and asserted that it was created and disseminated by an affiliate, Limay Media Ltd, without Midnite’s approval.