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As highlighted by Klebanow, Japan’s fragmented approach to gambling regulation may impact the development of Japan’s IR gambling industry, and Suzanne Perilloux Leckert, co-founding partner of Convergence Strategy Group somewhat agrees.

“Japan is acting cautiously, after observing missteps from other jurisdictions. They are proceeding in the way that best suits them,” she adds.

The factor that led some operators to drop out of the licensing race could be the “uncertainty” created by regulations that “didn’t seem set in stone”, says Leckert.

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Shuffle does not hold a licence to operate in the UK.

Meanwhile, Stake continues to feature on the sleeve of Everton’s kits, despite ceasing operations in the UK in early 2025 amid a Gambling Commission investigation into its advertising.

Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).

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The department said the guidance had been designed to “improve consistency across the sector and help prevent similar issues from occurring in future”.

In May, an investigation under the title “Operation Turbo” charged an Auckland man on eight counts under the Gambling Act.

The man was charged in connection with two illegal poker venues allegedly operating in central Auckland.