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The company admitted to lapses in its internal approval process, described the error as isolated and noted the ad was removed within a few hours.
Limay reported implementing new safety measures for AI-generated gambling creatives, including specifying age-related prompts and reviewing the perceived age of AI outputs.
Despite these measures, the ASA found that the character’s age was not credibly verified. The prompts used to generate the AI image did not explicitly require the character to appear aged 25 or over. Without an independent verification process, the regulator determined the character still “seemed to be under 25”.
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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.
A recent Fincord Intelligence report highlighted by the Betting and Gaming Council estimated that illegal online gambling generated around $50 billion in gross revenue globally in 2025. It estimated that around 5,000 operator structures were using more than 15,000 websites and apps.
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The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.
All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.
It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.
