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“If policymakers once again impose onerous policies that limit a property’s profit potential, then most developers will not take the risk of investing upwards of $10 billion in an IR development,” says Klebanow.

One exception, he notes, could be the Seminole Tribe of Florida and their proposed Hard Rock Resort Casino in Tomakomai, Hokkaido.

“They are currently aggressively growing the Hard Rock Casino brand, with developments under way in Las Vegas, New York City, Greece, Puerto Rico and Jamaica. They will put forth an attractive development proposal, and it appears that they now have the support of local government,” Klebanow notes.

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Speaking to iGB at the time, Bjorn Fuchs, chairman of VNLOK Fuchs noted “there was a sigh of relief going through the room when it was presented”.

Rather than a crackdown across the board, what emerged was a more regulated renewal framework.

Of the KSA’s update, Fuchs said: “If you [as an operator] have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.”

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For each category, the guide explained pertinent legal provisions and recommended operational actions. 

In cases of identity fraud, operators were advised to close accounts upon establishing fraud and to reserve balances when bank account ownership cannot be confirmed.

Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.