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The charter also made a series of other recommendations. It suggested that companies should designate a senior member of staff responsible for governance of the technology. It additionally recommended an AI oversight or ethics committee.

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.

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The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

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“We also delivered a nigh-on limitless range of bet combinations, delivered in a more rapid and more seamless manner than we have been able to before.”

Kambi’s path to the 2026 World Cup began with its initial investment in AI trading technology in 2021. The platform was deployed at scale during the Qatar 2022 tournament and fully embedded within its trading operations by 2024.

By 2026, the technology had already been tested across several seasons of top-level competitions including the Premier League and Champions League. AI now trades more than 70% of bets across Kambi’s network, including all football and tennis.