Dice Puzzle - Dice Merge Game

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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.

That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”

The objective, he argues, is to make it harder for operators to simply replace a blocked domain with another one. “If they knew there was a tool that would find those new sites as well, they might become more cautious.”

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Kugler told Spectrum “it was never his intention to provide incriminating information”. He said he had felt duped by Black Cube, and noted the person he had met with had disappeared after the report was released. He believed they had used a fake identity.

“Kugler’s position is that Evolution does not supply games to Iran. He stated that “I know we have players in Dubai”, Spectrum notes, in response to Black Cube’s claims.

Another claim made by Black Cube’s report was that Evolution had accepted wagers in virtual currencies and cash. Spectrum confirms that wagers were made by end users using crypto currencies, however it was the operator, and not Evolution accepting these bets.

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Kemorwale said Botswana needed to modernise oversight as the sector developed, including through a central electronic monitoring system and stronger enforcement capability. “Truth be told, this industry is evolving as the sun rises. You snooze, you lose,” Kemorwale said. He added that the Authority still relies on outside specialists for some technical regulatory work because domestic expertise is limited.

Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.

Authorities were also reported to be working with communications and financial-sector bodies to restrict access to illegal platforms and disrupt associated payment channels.