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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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What distinguishes Santos’ penalty is the exchange’s allegation that he actively issued false or misleading statements to alter prices and profited materially, violating additional rules such as failure to cooperate and manipulative conduct. 

These breaches escalated his sanction to a permanent ban and a significantly larger fine compared to others involved.

The platform’s Rule 5.17(z), cited in all the matters, strictly prohibits trading in contracts where participants have decision-making power or can otherwise influence the underlying event, regardless of influence magnitude.

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Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.

Authorities were also reported to be working with communications and financial-sector bodies to restrict access to illegal platforms and disrupt associated payment channels.

With parliamentary approval secured, attention will now turn to presidential assent, commencement and implementation. The Gambling Authority will face the task of translating the proposed reforms into stronger digital oversight, more effective action against unlicensed operators and practical customer safeguards as Botswana’s regulated market continues to expand.