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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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In a separate case, the ASA examined display advertising for White Hat Gaming’s Casimba and The Grand Ivy Casino brands, which had appeared on HLTV.org – a specialist Counter-Strike 2 e-sports website – in March 2026.
Two banner ads promoted a “100% match bonus up to £100 on 1st deposit” and displayed the mandatory 18+ logo. The ads appeared alongside live match coverage featuring betting odds and sponsor logos, including a link to Casimba’s website.
A complaint suggested that such placements were inappropriately targeted at under-18s.
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In a written response published in January 2026, Arno Rutte, the state secretary at the time acknowledged that enforcement against such sites remained limited, particularly for domains not registered under the .nl extension.
According to KVA, KT van Bruggen, the current state secretary for Justice and Security, has pointed out the urgency of implementing effective countermeasures to limit access to such illegal platforms.
Last week a committee made up of MPs from across the Netherlands’ political spectrum also raised concerns around the role of Meta and Google in supporting the black market.