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The difference is all about the risk function. A sportsbook employs traders to price bets and manage its exposure. An exchange provides an API through which firms compete to quote prices and supply liquidity.

“Here’s an API. Bernard and 88 other people can market-make all these request-for-quotes (RFQs),” Marantelli says. “Some people might come in and just do esports because they’re esports experts. Others do everything. Some focus on same-game parlays. But it’s a sportsbook.”

The institutional layer is largely invisible to customers presented with a P2P proposition. Retail users may technically trade against one another, but the depth required by a mass-market product cannot be supplied by occasional customers alone. Professional firms must be prepared to quote continuously and commit substantial capital.

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But Playtech has claimed that the Spectrum report, which is now publicly available, was unable “to confirm or refute” some of Black Cube’s claims, “as Evolution failed to provide Spectrum with significant information it had requested”.

Evolution declined to provide a comment on the update.

Notably, Spectrum said within its report that it did not believe Evolution had engaged in any illegal practices. It also refuted allegations concerning cash payments and the use of Evolution’s games in sanctioned countries.

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On Wednesday, the Science and Technology Committee (CCT) approved a project furthering restrictions on advertising and sponsorship of betting.

The proposal also established criteria for risk classification of products and clarifying the obligations of operators and platforms. The measure would likely grant the illegal market the opportunity to continue expanding, as it would be unaffected by the new rules. The committee approved a request for urgency for analysis by the Senate Plenary.

Authored by Senator Damares Alves and six other senators, Bill 2.470/2026 amends the Betting Law, which regulates fixed-odds betting, with measures aimed at protecting mental health, consumers, and the family economy. The bill received a favourable opinion, in the form of a substitute from Senator Alessandro Vieira.