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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.
Madsen says investigators can also examine how sites appear from different jurisdictions. If a site is presented in a country’s local language, for example, that can indicate that the market is being targeted. The next question is whether the operator has the necessary licence.
The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.
What is Zeus Fortuna?
The Malta Gaming Authority (MGA), working alongside the Malta Digital Innovation Authority (MDIA), drafted the voluntary charter following extensive surveys and interviews with industry licensees.
That study found that AI adoption across the gambling industry remained uneven. It highlighted customer support, data analytics, fraud detection, and responsible gaming as areas where the technology was already being heavily used.
However, it also found that formal governance of AI was struggling to keep pace with its growing usage. Only a minority of organizations surveyed reported having a formal AI strategy or roadmap. Many said one remained in development.
What is Zeus Fortuna?
In a written response published in January 2026, Arno Rutte, the state secretary at the time acknowledged that enforcement against such sites remained limited, particularly for domains not registered under the .nl extension.
According to KVA, KT van Bruggen, the current state secretary for Justice and Security, has pointed out the urgency of implementing effective countermeasures to limit access to such illegal platforms.
Last week a committee made up of MPs from across the Netherlands’ political spectrum also raised concerns around the role of Meta and Google in supporting the black market.