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How to play Divine Divas
The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.
Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.
They have also been advised to thoroughly review their Know Your Customer, fraud detection protocols and contractual terms to reflect the guide’s recommendations.
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“The bottleneck becomes the person reviewing everything. That does not mean we never review the code itself. For sensitive or critical parts of the system, we still look more closely at the implementation, particularly from an architecture, performance, security and reliability perspective. But we no longer apply that level of manual code review to everything.” Grenstad says.
The shift to AI is also changing how Grenstad thinks about recruitment. A team working on the player journey, for example, needs people who understand casinos, iGaming and what a strong player experience should look like.
“I would not necessarily prioritise senior Java or front-end specialists in the same way as before,” Grenstad explains. “Technical skills remain important, particularly for people who can assess architecture and ensure systems remain reliable, but domain knowledge is becoming increasingly valuable. I’d rather take someone who’s good in the domain but doesn’t know any Java.”
How to play Divine Divas
The report assesses black market activity across 28 European jurisdictions, including the UK, Netherlands and Germany. According to estimates across a mature black market ecosystem, 25 operators account for approximately 64% of relevant black market traffic.
Thanks to the “rapid growth of crypto currencies” and globally recognisable branding through marketing and sponsorships, this handful of operators are generating the majority of illegal gambling traffic across Europe.
The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
