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The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators. 

An ongoing review of the Interstate Treaty on Gambling, which is meant to conclude by the end of this year, should introduce a nationwide licensing model for online casino games, the group added.

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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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Dunn pointed out that ICE saw the same demand last year, with the Innovator Challenge alongside Microsoft and keynotes from the likes of AWS and Huawei.

This year, the team is responding with a new initiative, Hall 7. The launch of Hall 7 represents a stronger platform to drive the next phase of iGaming innovation.

Tech Race in Warsaw this September and Hall 7 at ICE in Barcelona this January are set to become sequential chapters of the same conversation. CTOs, CSOs and data leaders can expect to pick up where they left off four months later.