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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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Catalist initially received a list of fewer than 10 potential market makers from Kalshi. It has since completed agreements with close to 20 and is engaging with approximately another 20.
That growth reflects the expanding number and variety of sports contracts. ITF tennis is particularly dependent on official data because its more than 60,000 annual matches are not generally televised. Unofficially monitoring a tour moving between locations such as Bogotá and Bali would be difficult, Monk noted.
Streaming is also becoming part of the product. Monk said prediction market interfaces had moved beyond their earlier trading-led presentation to incorporate streams, player propositions and combinations resembling sportsbook bet builders.
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“Our investigation revealed certain clients had allowed for Evolution’s game content to be provided on their online gaming websites in clear violation of their contracts, which expressly prohibited such game play in specified regions,” the report states.
Spectrum blames Evolution’s “ineffective complaince procedures”, noting these activities appeared to go undetected by the supplier.
“In our judgment, Evolution’s ineffective compliance procesures have allowed these situations to develop and therefore need prompt reevaluation and enhancement in order to comply fully with the terms of the contracts,” the report reads.
