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The DIA also issued new financial guidance for class 4 operators, with the aim of providing greater clarity on their accounting requirements and an explanation of their obligations.

The department said the guidance had been designed to “improve consistency across the sector and help prevent similar issues from occurring in future”.

In May, an investigation under the title “Operation Turbo” charged an Auckland man on eight counts under the Gambling Act.

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The comment period opened shortly after several members of a Senate subcommittee alluded to the rise of prediction markets and the subsequent risk of a spike in harassment cases at a May federal sports betting hearing. The hearing, commenced by a US Senate Committee on Commerce, Science and Transportation subcommittee, was held at the Russell Senate Building during the heart of the NBA and NHL Playoffs.

Cruz, who chairs the Senate Commerce Committee, also co-authored the aforementioned Protect College Sports Act with Washington Senator Maria Cantwell. As cloture motion for floor debate of the act began this week, Cruz has expressed optimism that the bill will be signed into law.

The proposed bill seeks to prevent student-athletes from trading on prediction markets, but does not set any explicit standards on player harassment.

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For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.

One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.