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There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

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“[At] above roughly 150 players per manager, personal knowledge stops scaling. The fix is not fewer players or more managers – it is showing each manager which few accounts actually need them today,” she added. 

Satisfaction with existing tools scored an average of 6 out of 10. Co-author Gali Hartuv, CEO and co-founder at WarriorLab described this “middling satisfaction” as “the most expensive kind”.

While VIP managers welcomed AI for prioritising their workload, the report suggested they remained cautious about delegating a final judgment to opaque automated systems. 

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The KVA’s statement mirrors a broader European regulatory trend where authorities are increasingly scrutinising how major internet platforms facilitate traffic to unlicensed gambling services.

In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.

Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation.