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“Operators do pay, yes, but they pay whatever suits them,” they said. “In other words, we effectively pay what benefits us. All the while, the state has no means of monitoring its regulatory policies.”
In response to these issues, earlier this year the DRC Ministry of Finance outlined plans for a new gambling monitoring platform to enhance its supervision of the sector.
The DRC government is also developing a new legal framework for the gambling industry, designed to modernise existing rules and strengthen oversight of tax collection.
About The Flintstones
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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Technical data such as odds and rules were often obscured by delivery timing that came too late to influence decisions.
This sense of understanding was also described as something that needed to be maintained continuously, rather than achieved only once and then relied upon.
Consumers reiterated that being informed is an ongoing process, and that fast-paced and immersive gambling formats can rapidly erode awareness.