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This required operators to subject players to rigorous checks before signing up new VIPs, including having their betting behaviour being closely monitored.
Operators were also banned from incentivising customers based on losses, and reward programmes must be overseen by senior management. The code restricts any player under the age of 25 from taking part.
According to a GC report from 2025, the number of VIP customers in the market had dropped by 95% per operator since the strengthening of restrictions.
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Brazil is currently gearing up for a general election next month and Weizer said this had delayed Playtech’s launch in the regulated market, although he didn’t specifically name Caixa as its client.
“I’ll be very, very open and straightforward about it,” Weizer told analysts on Playtech’s post-Q2 earnings call. “There were certain concerns that because it is an election year, and obviously, gaming is a political issue or there were references by politicians throughout the elections about gambling.
“Given the sensitivity around that, we were kindly asked to collaborate with the government [and] with the prospective customer that we are in discussions with to wait until the elections.”
What is Trinity Impact?
Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.