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The dispute over the legal gambling age comes as the Gambling Authority steps up its warnings about illegal online betting.
Speaking at the 2026 South East Region Staff Excellence Awards in Gaborone, Kemorwale said unlicensed platforms were diverting an estimated P850m ($63.2 million) from Botswana’s economy each year and exposing children and teenagers to unregulated gambling.
He described the rapid growth of the illegal online market as one of the sector’s most serious challenges.
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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.
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However, until very recently the report was kept confidential by Evolution, as it contained commercially sensitive material, the supplier said.
But this week the 2022 report was released in full by the court. Playtech, for its part, has celebrated a number of findings in the document, which it says supports and corroborates findings from Black Cube.
Notably, the Spectrum report does acknowledge that Evolution did not knowingly allow games in prohibited territories, however, it has also flagged a number of compliance issues, which resulted in its games being provided in markets where online gambling is, or has been, prohibited.