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However, further tests found that while using a VPN, Spectrum could not access Evolution’s games in the sanctioned markets of Iran, Sudan and Syria, despite claims to the contrary made by Black Cube in its prior report.
“When we attempted to play games in those locales using VPNs, we were repeatedly denied access,” Spectrum states. It therefore said it found the allegations linked to these countries were “unsupportable and lacking credibility and proper foundation”.
Spectrum found that BitCasino.com and Stake.com were knowingly offering its games in these banned markets, which were specifically prohibited within their contracts with the supplier.
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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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A fraudulent ad directing consumers to an unlicensed offshore operator highlights the exact issue Alberta sought to address by adopting an Ontario-style regulated iGaming model.
Dale Nally, Minister of Service Alberta and Red Tape Reduction, has repeatedly emphasized that the primary objective of launching the province’s regulated market on July 13 was to offer consumers safe alternatives to illicit offshore sites operating out of jurisdictions like Malta and Curaçao.
“Standing still was not the responsible choice,” Nally said when the market launched. “Albertans were already gambling. What we’re putting in place is a regulated market that will put player safety and player responsibility first.”