Agent Ace

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“You have to follow that chain,” Madsen says. In some cases, that chain can involve multiple layers. “A site might redirect ten times before reaching the actual destination.”

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.”

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Taken together, the cases provide further ammunition for the anti-gambling lobby at a time when it is already facing political pressure, tax increases and demands for tighter restrictions. Each apparently avoidable failure makes it harder for the industry to argue that existing regulation is sufficient.

Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.

“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.

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