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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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Miller served on the forum for several years and was a key UK figure during a period when the Gambling Commission implemented extensive reforms to online gambling regulation and affordability checks. GREF expressed its gratitude for Miller’s contributions during his tenure.
Jean-Michel Costes has also left the board after concluding his role at France’s Autorité Nationale des Jeux (ANJ).
Costes was involved with GREF at a time when numerous European regulators, including the ANJ, focused on tightening advertising regulations and boosting player protection frameworks. The forum thanked Costes for his dedicated service.
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Within the report, Spectrum alleges “concerns around the availability of Evolution’s games in certain prohibited markets, the regulatory implications of its practices, and the lack of proactive monitoring of its customers”, Playtech has reported.
The report was commissioned by Evolution and was recently unsealed in the ongoing case. Evolution had tried to delay the report’s release, citing confidential and commercial sensitivity.
The case, which dates back to November 2021, was filed by Evolution against Black Cube, after the intelligence firm was found to have been secretly investigating Evolution’s activities from December 2020.