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

While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.

Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients. 

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“I’m trying to address every stage: prevention, support for people who are already struggling, and then action against the illegal sites.”

He does not believe illegal gambling can simply be eliminated. But he believes it can be made harder to operate. That may be the more realistic role for companies such as Trace2Trace as the illegal market evolves: not replacing regulators or enforcement agencies, but providing the intelligence needed to see beyond the individual URL. For Madsen, the motivation remains deeply personal: “I know very well what gambling addiction can do to people.”

The emergence of his company along with a string of others reflects a growing need in the industry: as illegal operators become more adept at moving, cloning and disguising their online presence, enforcement may increasingly depend on understanding the deep workings of the networks behind the screen.