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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.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

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Shuffle does not hold a licence to operate in the UK.

Meanwhile, Stake continues to feature on the sleeve of Everton’s kits, despite ceasing operations in the UK in early 2025 amid a Gambling Commission investigation into its advertising.

Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).

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Lottomatica CEO Guglielmo Angelozzi described its merger with Cirsa as a “low-risk proposition”, during an investor call detailing the deal on Wednesday.

The Wednesday announcement promised the merger of the two listed gaming giants would create the second-largest listed global gaming and sports betting operator, with a pro forma adjusted EBITDA of approximately €2 billion ($2.3 billion).

Angelozzi, who is set to lead the combined company as CEO, told analysts on the post-announcement call that the deal was expected to be a “low-risk proposition” given the consistent growth demonstrated by both Lottomatica and Cirsa in recent years.