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“You have to follow that chain,” Madsen says. In some cases, that chain can involve multiple layers. “A site might redirect ten times before reaching the actual destination.”
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.”
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In cases of identity fraud, operators were advised to close accounts upon establishing fraud and to reserve balances when bank account ownership cannot be confirmed.
Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
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Scotts Valley filed suit in response. In October 2025, Judge McFadden ruled that Interior had violated the tribe’s due process rights by rescinding the approval without giving prior notice or an opportunity to respond.
However, McFadden’s ruling left the door open for Interior to formally reconsider the underlying gaming eligibility question.
Scotts Valley has maintained that federal officials reversed course under intense political pressure from the Yocha Dehe Wintun Nation, a neighboring tribe that opposes the Vallejo casino development.