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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.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

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The competition between prediction markets and sportsbooks is intense and there is some evidence that the former is encroaching on the latter’s customer base.

A survey by Fullstory, a behavioral data analytics company, says that amid the evolution of yes/no exchanges, 60% of bettors said prediction markets are altering how they use sportsbooks with 35% admitting that they’ve reduced usage of traditional sports wagering platforms as access to sports event contracts increased.

“Consumers are being presented with more options for how they can participate in online gaming, creating a more competitive landscape where a seamless digital experience is increasingly becoming part of the value proposition,” said Jason Wolf, president of Fullstory, in a statement. “The brands that understand how consumers are navigating, comparing, and engaging with their platforms in real-time can identify where friction is getting in the way of trust and retention.”

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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.