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The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.

“We had various iterations of the drafts internally probably going back at least a decade, and just never made it to the finish line for various reasons,” he explained.

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The research, published by The Intercept Brasil on Monday, analysed more than 55,000 Instagram accounts and cross-referenced the results with the official list of authorised operators from the Secretariat of Prizes and Bets (SPA).

According to the survey, the problem arises when a user follows a single account related to betting. The platform’s recommendation system then starts showing other profiles in the same segment, including betting sites, influencers and specialised pages.

Among the 100 most recommended profiles are accounts that, together, have accumulated more than 6 million followers and 114,000 posts. There are three main types of profiles recommended by Instagram: operators, content creators and media specialising in the betting market.

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The court also explored potential liabilities for trust administrators and local representatives who facilitate illegal gambling sites. 

While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.

Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients.