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Other estimates are considerably higher, illustrating how difficult the market is to measure. As an example, separate research from Gaming Compliance International put the value of unregulated online gambling at $5.9 trillion in wagering value in 2025, while estimating that unregulated operators accounted for 78% of global online gaming GGR.
Another report, commisisoned by Euromat, estimates that Europe’s black market has sustained a compound annual growth rate of 18% between 2019 and 2026, and will be worth up to €13 billion by the end of the year.
For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.
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“There are significant checks on individuals and businesses before a licence is granted,” he says. “The UK Gambling Commission has set out what it expects. If you want a licence in the UK, you need to meet those expectations.”
Bentley believes regulated operators are genuinely trying to do the right thing but says some mistakes could be mitigated through better automation and continuous monitoring. Enforcement statements also provide lessons that businesses should use to test their own exposure.
“It would be crazy to say that these cases are positive for the industry,” he says. “They will no doubt continue, but as an industry we need to try to reduce their frequency.”
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Bengtsson said the split between casino and sports betting for SunBet was roughly 90% to 10% in favour of casino, with Sun International “under-indexing on sportsbook”.
But Sun International views that as an opportunity, with Bengtsson stating: “We think the market overall is probably somewhere around 35%-40% sportsbook.
“So that is the delta we have to close by delivering a better product and better operational intensity in our sports business.”
