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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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The company also highlighted its own research that suggests over 80% of consumers cannot “confidently distinguish” licensed operators from unlicensed ones.

Stella David, Entain’s CEO, called for the government to move ahead with the ban immediately, arguing clubs were already aware of the planned changes.

“Premier League clubs that have struck new deals with unlicensed gambling operators knew the risks,” she said. “The government made clear in February that it would bring in a ban and it should do so immediately: even if that means clubs ordering new kit mid-season.

What is Phantom Family Prizematch?

Gambling ads are currently monitored by ASA under the CAP 16.1 code. Just this week, Midnite received its third ASA ruling. The operator was told to remove a TikTok advertisement that featured a young-looking character. 

The report singled out several marketing tactics which had been flagged as particuarly concerning.

The first was direct marketing (emails, texts, push notifications). Citing randomised studies, the committee noted that limiting direct marketing resulted in reduced betting and fewer short-term harms.