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FATF released the report – Risks of Gaming and Gambling – on Wednesday. It updates the body’s 2009 analysis of the casino sector. In addition, it draws on questionnaire responses from 80 jurisdictions and written comments from a further 29, alongside industry consultation.

The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk. 

It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.

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Madsen is clear that Trace2Trace does not shut websites down. Instead it tracks domains, identifies connections and documents changes so that regulators, enforcement authorities or other customers can use the information.

That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”

The objective, he argues, is to make it harder for operators to simply replace a blocked domain with another one. “If they knew there was a tool that would find those new sites as well, they might become more cautious.”

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The participants suggested timely and relevant interruptions as well as enhanced onboarding processes and in-game assistance, which could include free-play modes, easy access to concise game rules and AI-driven help to clarify complex terms.

For land-based venues, unobtrusive and empathetic staff checks to identify signs of distress without creating a sense of surveillance was suggested.

The study drew parallels with evolving financial regulation, such as the Financial Conduct Authority’s Consumer Duty, which stressed the importance of providing information and ensuring customers understand and can act on it.