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“This successful investigation clearly demonstrates the scale that the illegal gambling market has now reached,” said Mathias Dahms, president of the DSWV.

Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools. 

He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”

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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.

How to play payment methods for nigerian online casinos

The institutional layer is largely invisible to customers presented with a P2P proposition. Retail users may technically trade against one another, but the depth required by a mass-market product cannot be supplied by occasional customers alone. Professional firms must be prepared to quote continuously and commit substantial capital.

Marantelli says the London-based White Swan is a significant market maker on several secondary exchanges, accounting for as much as 40% of activity on some platforms. Its particular focus is the RFQ, parlay market.

“Just better margins,” he says of that decision. “I think it’s more defendable. It’s the area that fewer people can do well. So I think it’s more defendable margin, more ability to get long-term contracts and beneficial positions.”