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Patrick Bergin, an attorney for Scotts Valley, rejected that argument, noting the difficulty of converting a site explicitly planned and built for gaming into something like an auto dealership.

Bergin also emphasized that the tribe had formally notified Interior twice about its launch timeline for the Preview Casino, providing regular progress updates without ever receiving a directive from federal officials to halt the project.

The conflict stems back to January 2025, when the outgoing Biden administration initially determined that the Vallejo parcel was eligible for gaming.

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The text also bans exploiting situations of economic crisis, unemployment, debt, emotional distress, grief, anxiety, depression, loneliness, or other conditions of vulnerability to attract, retain or reactivate gamblers. 

Operators must maintain permanent mechanisms for age verification, self-exclusion, voluntary time and wagering limits, and information on the user’s own gambling behaviour. Self-exclusion must be effective with all authorised operators. 

The text also prohibits bets placed using credit cards, the use of predictive models to identify moments of greater vulnerability, and platform design mechanisms that hinder a conscious decision to stop betting, leave the service, or activate limits and blocks. Operators must maintain permanent alerts about compulsive gambling, indebtedness and asset loss, and adopt verifiable protocols for identifying risky behaviour.  

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“Peru has been quite successful in channelling customers into the regulated framework,” Rossi comments. “The risk is that this channelisation can decrease in favour of the black market. We know the black market won’t have any consumption tax.

“There should be, in my opinion, a review of the whole ISC or consumption tax framework and find a kind of alignment or a better way to get an income in terms of taxes, but that should be balanced in order to avoid the disruption of businesses and a migration of customers to the illegal market.”

Atucha warns there is a tipping point where higher taxes can undermine channelisation, citing the UK and Germany as important case studies.