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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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According to the German Press Agency, the Frankfurt public prosecutor’s office, together with the Frankfurt tax investigation unit, the State Office for the Combat of Financial Crime in North Rhine-Westphalia and Frankfurt police, executed coordinated searches across 11 premises on Tuesday.
Over 100 officers participated in the operation. Authorities seized several high-value vehicles, froze numerous bank accounts and imposed an asset restraint order valued at around €82 million. An arrest warrant was also executed.
Prosecutors allege that five suspects had operated internet-based gambling services without the required German licences from at least July 2021. The volume of bets placed on these platforms reportedly exceeded €5.8 billion between mid-2021 and the end of 2023.
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“Player protection is something I live and breathe and I look forward to implementing that passion at scale across Allwyn,” Rodano added.
He said that by operating in a number of markets, Allwyn had a unique opportunity to learn from each other.
The appointment also follows a period of leadership changes at Allwyn, including Phil Walker’s move to lead the UK business, Katie Harbron’s hiring as director of games in the UK and Khalid Reede Jones’ appointment as North America CEO.