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“Therefore, we have been having this debate,” he added. “I have been to Congress, the Supreme Federal Court, and the Attorney General’s office to talk about the impact of betting on the lives of Brazilians.

“We have made progress, such as increasing the direct tax to 15% and including the activity in the Selective Tax. Those benefiting from social programmes and those who joined the Desenrola programme were also prohibited from betting.”

He also pointed to the self-exclusion mechanism adopted by the government.

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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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For James Curwen, chief executive at Yggdrasil, the tension between the industry’s need for fresh content and the commercial realities of producing it goes to the heart of the challenge.

“The industry has a content problem,” he says. “There are thousands of games being released and too many of them are variations of something that already exists.

“Part of the reason is economics. When games take months and significant money to develop, people naturally become risk-averse. Building on something that already works becomes the safer option.”