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Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.
“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.
Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.
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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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According to local reporting on Monday, the Interior Ministry confirmed that accounts connected with the suspects had exhibited suspicious financial activity amounting to 17.75 billion lira ($365.8 million).
Coordinated efforts between the government’s cybercrime and anti-smuggling units, the Financial Crimes Investigation Board (MASAK) and local prosecutors led to raids in the provinces of Adıyaman, Konya, Manisa, Muğla, Tekirdağ, Siirt, Muş and Çorum.
Officials alleged that the individuals involved had been operating illegal betting websites and had facilitated the movement of proceeds from gambling through Türkiye’s financial system.