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Limay Media acknowledged that the person depicted was an AI-generated fictional character rather than a real individual and claimed the design was intended to appear as an adult.
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.
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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk.
It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.
Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds.
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ACMA’s investigation revealed multiple compliance breaches, primarily concerning account management and marketing controls.
The regulator noted that several inactive accounts remained open long after users requested exclusion.
Specifically, 156 out of 229 accounts with no pending bets remained linked to BetStop users seven days after self-exclusion registration. Some accounts were non-compliant for periods extending up to 200 days.
