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“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.

Marantelli says the London-based White Swan is a significant market maker on several secondary exchanges, accounting for as much as 40% of activity on some platforms. Its particular focus is the RFQ, parlay market.

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One of the main concerns is Bill 560/2025, which is currently making its way through the council. The proposal prohibits advertising by betting companies at events in the city of São Paulo. This applies to events organised by public or private entities, whether for-profit or non-profit.

The bill prohibits signs, banners, or display panels in arenas, gymnasiums, stadiums and other sports event venues. It also bans advertising on public transport, such as the side panel, exterior or the rear window of buses. The bill imposes a fine of BRL50,000 ($10,000) and a ban on hosting events for up to two years.

The proposal does not explicitly prohibit the display of betting brands on team jerseys, but some city councillors want to include this in the bill.

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Her previous leadership roles include chairing the Independent Parliamentary Standards Authority (IPSA), the Bar Standards Board and acting as a lay member of the General Medical Council. 

Evans also served as a non-executive director of the Serious Fraud Office. She led the steering group responsible for a voluntary industry code that reimburses victims of authorised push payment (APP) scams, introduced in 2018.

Ahead of his departure Counsell said the Commission was developing a new strategy and ramping up its work to tackle illegal gambling, with Evans set to play a “pivotal” role as it also finalises measures from the Gambling Act review’s subsequent white paper.