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He began watching regulators shut down individual gambling sites, only for mirror sites, cloned domains and replacement URLs to emerge in thier place. The problem, he concluded, was not necessarily the individual website. It was the network behind it.

“Why not use the dataset I already have on gambling sites to map the most problematic ones, identify how they are connected and build a deeper picture of the networks behind them?” That thought process eventually gave birth to Trace2Trace.

Trace2Trace is relatively new, but Madsen says its underlying dataset has already grown to around 620,000. And it continues to grow, highlighting the scale of illegal operations in the gambling industry.

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For Curwen, tackling the problem therefore means changing the risk-reward equation behind game creation. If creators can develop and test ideas more quickly and at significantly lower cost, an unsuccessful experiment becomes less consequential – and taking a chance on something genuinely different becomes easier to justify.

“Technology changes the equation,” he says. “If we can make development faster and significantly more cost-efficient, creators can afford to experiment again.

“I’ve said before that I think we’re moving towards the end of the traditional reskin model. Players don’t need another 100 versions of effectively the same game.”

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“Most operators have worked constructively with us to address historical issues and improve their practices,” Scott said.

“While we’ve made substantial progress, our work is not finished. We’ll continue working with operators to recover funding for communities, improve compliance and maintain public confidence in the integrity of class 4 gambling.”

Alongside the recovery of NZ$11.5 million, the DIA also took action against the class 4 gambling society One Foundation.