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Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.

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Digital gross gaming revenue represented 64.5% of the parent company’s total in H1, up 3.6 percentage points from the previous year.

Registered customers increased to approximately 2,672,000 at the end of June, an increase of around 50,000 from the previous year.

For the first half of 2026, lottery and land based gaming generated €317.9 million in gross gaming revenue, remainin flat compared with H1 2025. 

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The charter does not create new regulatory obligations and was designed to complement legislation including the EU AI Act and GDPR.

Instead, it proposed a risk-based approach. It suggested lighter controls on use cases such as coding assistants, but strong checks on customer-facing functions, particularly those involving fraud and responsible gambling.

Kenneth Brincat, CEO of the MDIA, said companies needed “practical ways” to better understand where AI fits within their businesses.