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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.

One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

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“Most operators have worked constructively with us to address historical issues and improve their practices,” Scott said.

“While we’ve made substantial progress, our work is not finished. We’ll continue working with operators to recover funding for communities, improve compliance and maintain public confidence in the integrity of class 4 gambling.”

Alongside the recovery of NZ$11.5 million, the DIA also took action against the class 4 gambling society One Foundation.

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The operator was also investigating the roles of the same trust firm in relation to Qbet and Skyhills, indicating further legal proceedings may be forthcoming once corporate structures are clarified.

The crackdown on illegal gambling sites coincided with a broader policy debate in The Hague. The Dutch House of Representatives is set to discuss gambling regulation reforms this week. 

Nederlandse Loterij has welcomed government proposals aimed at expanding the Gambling Authority’s powers to combat illegal operators but has cautioned that comprehensive legislative changes could take years to become effective.