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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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It also said Spectrum was able to “specifically corroborate” Black Cube’s claims that Evolution’s games were accessible and generating revenue in several “prohibited locations”. These included Hong Kong, Singapore, the United Arab Emirates and Saudi Arabia.

Evolution has for several years denied any involvement in illegal activity. In a statement to iGB in November, the company said its defamation litigation aimed to hold Playtech and Black Cube “accountable for its wrongdoing” and to protect shareholder value.

The report also revealed that Evolution had ignored virtual currency risks, as they had accepted wagers in said currency without triggering the enhanced due diligence normally expected in such cases.

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Shuffle does not hold a licence to operate in the UK.

Meanwhile, Stake continues to feature on the sleeve of Everton’s kits, despite ceasing operations in the UK in early 2025 amid a Gambling Commission investigation into its advertising.

Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).