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“The market is moving beyond rapid expansion and becoming increasingly quality-driven. Operators will need to compete not only through marketing investment, but also through technology, product innovation, responsible gaming and customer experience.

Rossi takes a somewhat different view, describing Peru as a mature betting market while pointing to mobile penetration and a growing generation of digital consumers as sources of further growth.

“In my opinion it’s a mature market,” Rossi states. “Because historically, I believe Peru was one of the first betting markets in all of Latin America. Although the regulation was not there, betting was quite tolerated in the past.

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The distinction matters for crypto businesses. The filing shows regulatory work is moving forward, but exchanges and other market participants cannot yet consider it a set of rules they must adhere to. 

The CFTC’s move also comes as other US regulators continue to craft their own crypto policies. The agency and the Securities and Exchange Commission (SEC) jointly issued an interpretation in March on how certain crypto assets would be treated under federal securities laws. 

A lot of bigger questions remain without the CLARITY Act. The bill aimed to establish a federal framework for digital commodities and delineate the roles of the SEC and the CFTC. 

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“It was still very much a trading kind of UX,” he said of Kalshi at the beginning of the year. “The actual product offering has come a long way.”

Andrew Gonzalez, founder of prediction market infrastructure startup ParlayX, believes the ability of small teams to provide liquidity is one of the sector’s defining features. “Anyone can be a market maker,” he said. “You have these two- or three-man shops.”

Jefferies described market makers as the ecosystem’s “liquidity backbone”. They post executable bids and offers, manage inventory and provide prices when customer activity is heavily weighted to one side.