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Grant argues that he has booked five Royal Caribbean cruises that were valued at a total of AUD 22,000. He booked the cruises with money he won playing at the Royal Caribbean’s ships’ casinos. 

However, before he could even board the first cruise, Grant was told that he would not be able to proceed onboard. Grant had his son and partner along with him. The company only then went to inform Grant that he had been placed on a “no sail” list, effectively a ban, because of “breaking the house rules” in the casino.

Royal Caribbean informed Grant that he had broken various casino rules. While Grant filed a legal action against Royal Caribbean with the Queensland Civil and Administrative Tribunal, he has enjoyed qualified success so far.

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Madsen describes Trace2Trace as “a large search engine that continuously crawls websites”.

AI is used, but only towards the end of the process. First, the system gathers objective indicators; AI is then used to assess the overall pattern and probability of a connection. “We only provide evidence-based findings,” Madsen says. “We don’t say that something is a mirror site because we suspect it is. It is only reported when we are 100% confident there is a match.”

The timing is significant. The illegal gambling market is attracting growing attention from regulators and the wider industry, while estimates of its size vary considerably depending on definitions and methodology.

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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

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%.