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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.
One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”
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The triumvirate of Netherlands, Germany and Sweden is often held up as an example of how not to regulate, with all three countries haemorrhaging players to waiting illegal operators. So what is public sentiment like towards operators? “My feeling is that if you look at public sentiment, they don’t see really the difference between online and land-based,” says Petra. “If you look into what they’re saying, they’re primarily talking online. But for the general public, there is no difference [between the channels] in that respect.”
She believes the sentiment towards gambling among the Dutch public is comparable to the UK, Finland, Germany, France. “So, very tense,” she says.
However the sentiment towards the Holland Casino brand has remained quite positive, while more generally the sentiment towards gambling is very critical.
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“Every other finding – portfolio overload, fragmented data, reactive workflow, no behavioural signal – resolves here, in revenue that walks out without notice, without warning and without anyone getting the chance to intervene.”
There was also strong interest in prioritisation tools, with 75% placing high value (8/10 or above) on daily prioritised action guidance for each player.
However, 38% expressed concern that adopting AI might reduce the personal, human touch in VIP management.
