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The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.

“We had various iterations of the drafts internally probably going back at least a decade, and just never made it to the finish line for various reasons,” he explained.

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The charter does not create new regulatory obligations and was designed to complement legislation including the EU AI Act and GDPR.

Instead, it proposed a risk-based approach. It suggested lighter controls on use cases such as coding assistants, but strong checks on customer-facing functions, particularly those involving fraud and responsible gambling.

Kenneth Brincat, CEO of the MDIA, said companies needed “practical ways” to better understand where AI fits within their businesses.

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He was a teenager when he started gambling habitually. For several years, it remained entertainment. Then, when he was in his early twenties, came a large win on a foreign unlicensed gambling site: around €22,000.

“I remember gambling all of it back the same day because they couldn’t pay it out in full immediately,” he says.

The win completely changed his relationship with gambling. In Madsen’s words: “That jackpot was really the beginning of my gambling addiction.”  It was an addiction that was propelled by a constant exposure to illegal sites, he explains.