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What is Jungle Queen?

The letter argues that the proposed increase would hit the workers and communities Labour’s “Makerfield Test” is supposed to protect, while potentially costing the Exchequer money rather than raising it.

Entain stressed the importance of its retail networks in providing local employment and community engagement. 

It noted the role of machine gaming revenue in sustaining shops outside of race days, which in turn supports local economic activity, including around £50 million annually devoted to British horse racing. 

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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.

“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.