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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.
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.
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Meanwhile, Tunisian gambling law rests on Decree-Law 74-20 of October 1974. The only lawful sports betting channel is the state company Promosport. Pari-mutuel horse race betting is managed by the Agence Tunisienne de Solidarité.
Parliament is now considering two competing approaches to online gambling. But neither has produced a licensing framework.
A private members’ bill, 2026/009, was put forward on 20 January by 23 deputies and referred to the General Legislation Committee on 29 January. It would amend the 1974 decree-law to prohibit all online gambling and require internet and payment providers to block it.
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The court also explored potential liabilities for trust administrators and local representatives who facilitate illegal gambling sites.
While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.
Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients.