Hainan Ice

What is Hainan Ice?

“What I do think is that deciding together, not only as operators, but together with politicians and stakeholders, that a legal market is very important to get that done. We’re not there yet, and that’s what we’re saying.

“An unregulated market doesn’t become a safe market. People will always gamble, so we have to make sure that we have a strong legal market. And so you also need to give us some room to exist. And of course, we need to be regulated. A regulated market is always better than an illegal market.”

She mentions an ongoing lawsuit against Meta, which will be expected to be very challenging. The VNLOK-filed litigation is seeking to take action against the illegal gambling ads allowed to filter through to consumers across Meta’s various platforms.

About Hainan Ice

While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.

Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients. 

The operator was also investigating the roles of the same trust firm in relation to Qbet and Skyhills, indicating further legal proceedings may be forthcoming once corporate structures are clarified.

How to play Hainan Ice

He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.

The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.