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There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.
“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.
He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.
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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.
How to play Shark Wash
A massive steel truss weighing about 180,000 pounds has been lifted into place at Durango Casino in southwest Las Vegas as construction reaches the halfway point of its $385 million expansion.
The huge structure, measuring nearly 140 feet long and 20 feet tall, was installed Friday, September 18, as part of the second expansion of Station Casinos’ Durango property.
Suffolk Construction, the project’s general contractor, used a crane weighing roughly 650,000 pounds for the lift, with a second crane assisting with the operation.
