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About Halloween
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.
What is Halloween?
“In our judgment, Evolution’s ineffective compliance procesures have allowed these situations to develop and therefore need prompt reevaluation and enhancement in order to comply fully with the terms of the contracts,” the report reads.
“Evolution may be unwittingly susceptible to having its games played through third-party operators, in violation of its contracts…”
The firm goes on to confirm that Evolution had therefore received income from these unauthorised activities.
About Halloween
Dutch MPs have raised similar concerns before. In December 2025, CDA MP Straatman asked the state secretary whether websites advertising as “Beste casino’s zonder Cruks” should be taken offline immediately.
In a written response published in January 2026, Arno Rutte, the state secretary at the time acknowledged that enforcement against such sites remained limited, particularly for domains not registered under the .nl extension.
According to KVA, KT van Bruggen, the current state secretary for Justice and Security, has pointed out the urgency of implementing effective countermeasures to limit access to such illegal platforms.