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The framework also urged companies to implement rollback mechanisms and “kill-switch” controls for higher-impact systems.

For AI-powered customer support and chat, operators are encouraged to set clear parameters for when conversations should be moved to a human member of staff. These include repeated low-confidence responses, unresolved queries, indications of distress, or a customer simply asking to speak to a human.

The MGA said the charter will be reviewed periodically as technology and regulation develops.

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The Lalabet case, which reached a milestone in June, saw a Dutch court rule largely in favour of the lottery operator. 

It found Lalabet’s operators and directors had acted unlawfully by targeting Dutch players and ordered them to cease activities and provide detailed ownership and shareholder information.

The court also explored potential liabilities for trust administrators and local representatives who facilitate illegal gambling sites. 

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Madsen describes Trace2Trace as “a large search engine that continuously crawls websites”.

AI is used, but only towards the end of the process. First, the system gathers objective indicators; AI is then used to assess the overall pattern and probability of a connection. “We only provide evidence-based findings,” Madsen says. “We don’t say that something is a mirror site because we suspect it is. It is only reported when we are 100% confident there is a match.”

The timing is significant. The illegal gambling market is attracting growing attention from regulators and the wider industry, while estimates of its size vary considerably depending on definitions and methodology.