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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.

A recent Fincord Intelligence report highlighted by the Betting and Gaming Council estimated that illegal online gambling generated around $50 billion in gross revenue globally in 2025. It estimated that around 5,000 operator structures were using more than 15,000 websites and apps.

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They have also been advised to thoroughly review their Know Your Customer, fraud detection protocols and contractual terms to reflect the guide’s recommendations. 

They must also evaluate their current technical safeguards to ensure alignment with regulator expectations and certification standards.

Safeguarding has reappeared as a focal point for the regulator. In July of this year, ANJ imposed a €500,000 ($572,797) fine on an unnamed online betting operator, referred to as Company X, for not adequately identifying and supporting customers exhibiting signs of problematic gambling. 

About 25 Coins

Large and demanding portfolios were highlighted as a key challenge, with 64% of managers overseeing 100 or more VIPs, while one in five managed more than 500. 

The report highlighted the intense workload by estimating that a manager looking after 250 players would have roughly 100 seconds to commit to each player each day if their time was split equally. Data quality and fragmentation were also issues. 

Grygorenko emphasised that prioritisation was the key to adapting these portfolio sizes.