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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk. 

It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.

Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds. 

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Holland Casino calls this Next Zone, and as Petra elaborates: “It’s an innovation we made a few years ago to see how we can develop a casino product because I think in the industry, we are very well known for what we have, but how do you innovate?”

Like most operators, slots make up the bulk of Holland Casino’s income, but it’s worth remembering that Holland Casino has a monopoly on table games, poker and bingo. “I would say those are also our hero products that make us attractive because in the Netherlands we are the only one offering land based live table games,” says Petra.

“Maybe they’re not so dominant in the results, but it is dominant in our identity. But figures-wise, slots are bigger than table games.”

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“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.

The board is hoping that the proposal drafts or more or less finalised, though there will likely be input from stakeholders during the comment period and at the hearing. One group that typically weighs in on such matters, the Association of Gaming Equipment Manufacturers, did not respond to a request for comment by Friday’s deadline for publication. Depending on the amount of feedback or potential objections from the Nevada Gaming Commission, the new standards could be adopted and published by year’s end.

Overall, it’s been a busy stretch for the board since the start of 2025. In that time the regulator has issued five multimillion-dollar anti-money laundering fines to entities on the Las Vegas Strip, an unprecedented run of sanctions for America’s gambling capital.