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“Why not use the dataset I already have on gambling sites to map the most problematic ones, identify how they are connected and build a deeper picture of the networks behind them?” That thought process eventually gave birth to Trace2Trace.

Trace2Trace is relatively new, but Madsen says its underlying dataset has already grown to around 620,000. And it continues to grow, highlighting the scale of illegal operations in the gambling industry.

“We receive around 7,000 domains a day on average through the lists we monitor, including new and cloned sites,” he explains.

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However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.

Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

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