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Alongside the recovery of NZ$11.5 million, the DIA also took action against the class 4 gambling society One Foundation.

One Foundation’s operating licence was suspended for six days after the DIA identified accounting failures relating to gambling proceeds, as well as a failure to surrender a licence for one of its pokies venues when required by law.

The DIA also issued new financial guidance for class 4 operators, with the aim of providing greater clarity on their accounting requirements and an explanation of their obligations.

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One concern is the measure might force clubs to host matches outside the city to maintain their advertising agreements.

Stakeholders have yet to determine their response to the bills, with educational campaigns and collective actions on the agenda. Coordination with political leaders in the city of São Paulo is also under way.

Reinaldo Carneiro Bastos, president of the São Paulo Football Federation, expressed concern about the bill, saying: “If the city’s clubs lose this revenue, it will create a disparity that extends to the pitch.”

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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.

Marantelli says the London-based White Swan is a significant market maker on several secondary exchanges, accounting for as much as 40% of activity on some platforms. Its particular focus is the RFQ, parlay market.

“Just better margins,” he says of that decision. “I think it’s more defendable. It’s the area that fewer people can do well. So I think it’s more defendable margin, more ability to get long-term contracts and beneficial positions.”