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“We receive around 7,000 domains a day on average through the lists we monitor, including new and cloned sites,” he explains.

The system starts with domains that have already been identified by authorities. Trace2Trace then crawls them, looking for technical connections and similarities.

These include shared hosting, DNS clusters, source-code strings, tracking systems, logos and favicons. The system can also follow redirects and other mechanisms that may not be visible through a conventional web request.

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He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”

The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

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The charter does not create new regulatory obligations and was designed to complement legislation including the EU AI Act and GDPR.

Instead, it proposed a risk-based approach. It suggested lighter controls on use cases such as coding assistants, but strong checks on customer-facing functions, particularly those involving fraud and responsible gambling.

Kenneth Brincat, CEO of the MDIA, said companies needed “practical ways” to better understand where AI fits within their businesses.