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The purpose of this article is to compare the different regulatory approaches taken by Finland and the Netherlands in response to the pressures of European Union law, unlicensed gambling, and the harmful effects which can arise from gambling. The two Member States represent two different models of gambling regulation. According to Kingma, the models refer to different attitudes and concerns towards gambling in different timeframes. We argue that Finland fits the “alibi model” of gambling regulation, whereas the Netherlands aligns with the “risk model”. Both countries have decided to restrict the cross-border movement of gambling services, even though Finland has opted for a monopoly system and the Netherlands is heading towards a licensing system. We employ the “Multiple Streams Approach” to explain why Finland and the Netherlands have taken different political and legislative paths in the regulation of gambling services. For several years, Finnish gambling policy has focused on channeling demand towards domestic online gambling sites, which have been represented as more secure than foreign online gambling sites. The Netherlands seeks to channel 80 percent of demand to locally licensed online operators. Both Finland and the Netherlands seek the same objective: to protect consumers from the excesses of gambling in part by reducing the presence of unlicensed operators in their respective national markets.
Littler et al. (Mon,) studied this question.