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There are also strategic questions around dependence on AI providers.

Cubeia is currently heavily reliant on Claude, and Grenstad questions what could happen if AI providers raise prices or if quality changes. For now, however, Grenstad sees the uncertainty as something Cubeia can learn to manage.

“We’re confident that the question marks will be solved as we work through them. We’ll see the problems, learn how to manage them, and adapt.”

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The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.

Helios, a specialist consultant in gambling web traffic, analysed the number of black market websites actively marketing across the 28 markets included in the report, between March and May.

This data was cross referenced with SimilarWeb traffic analysis to confirm the scale of activity. In some markets, the number of illegal sites being actively marketed was much higher than those that have local licences to operate.

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The framework also urged companies to implement rollback mechanisms and “kill-switch” controls for higher-impact systems.

For AI-powered customer support and chat, operators are encouraged to set clear parameters for when conversations should be moved to a human member of staff. These include repeated low-confidence responses, unresolved queries, indications of distress, or a customer simply asking to speak to a human.

The MGA said the charter will be reviewed periodically as technology and regulation develops.