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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.

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But he acknowledges the possibility that faster customer losses could eventually test the sustainability of the model.

“They lose quicker, dry up quicker, recruitment or re-recruitment,” he says. “If the recruitment of players dries up, then what are you going to do? Definitely there can be components like that.”

For now, the growth provides room for multiple market makers. Marantelli expects margins to “stay good during the growth period” before contracting as competition intensifies. The more complex RFQ and parlay markets may offer the best protection against that compression.

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Carolyn Lidgerwood, an ACMA member, stressed the importance of respecting self-exclusion decisions, stating “providers must respect that decision” and “must have robust systems in place”. 

These remarks align with a broader regulatory focus on harm-minimisation within online gambling, where adherence to self-exclusion protocols is under closer scrutiny.

“These were serious breaches by Dabble. Wagering providers must have robust systems in place to protect people who have chosen to self-exclude,” Lidgerwood added.