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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.
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Kemorwale said Botswana needed to modernise oversight as the sector developed, including through a central electronic monitoring system and stronger enforcement capability. “Truth be told, this industry is evolving as the sun rises. You snooze, you lose,” Kemorwale said. He added that the Authority still relies on outside specialists for some technical regulatory work because domestic expertise is limited.
Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.
Authorities were also reported to be working with communications and financial-sector bodies to restrict access to illegal platforms and disrupt associated payment channels.
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Black Cube, an intelligence firm hired by Playtech in 2020 to look into alleged illegal behaviour at its rival Evolution, released a divisive report into Evolution’s actions. Evolution denied and refuted much of its findings.
Evolution then commissioned Spectrum Gaming Group to produce a report on its actions and the validity of the Black Cube report. Produced in 2022, the report has long been subject to confidentiality despite Evolution claiming the report exonerated the company.
Playtech on Wednesday published a statement highlighting what it claimed were compliance failures at Evolution, written into the Spectrum report.