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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.”
Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.
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Across the market, operators delivered high double-digit gains compared with Labor Day weekend, which featured a full slate of college football games but no NFL contests. Two operators, DraftKings and Underdog each saw triple-digit growth, delivering weekly increases of 125% and 119%, respectively. Three others, Polymarket, Crypto.com and Novig, saw gains of at least 30%, led by Polymarket with a weekly increase of 46%.
One interesting nugget surrounds weekend figures at Kalshi, where volume on Sunday only surpassed prior daily activity by $34 million, BofA data shows. Typically, Sunday volume for the quarter dwarfs that of College Football Saturdays due to the voracious demand for NFL offerings. BofA analyst Shaun Kelley attributes the irregularity to the possibility that Kalshi is “over indexing” on college sports.
Kelley also cited improvements at Robinhood as a possible factor for the regression at Kalshi. Just before the NFL season, Robinhood took a minority stake in Crypto.com and struck a deal to begin routing NFL contracts to OG.com, the site’s regulated prediction market platform.
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The decision is not yet legally binding, with a further opportunity to appeal the denial of ‘leave to appeal’ open to the applicants. This will be reviewed by the Federal Administrative Court of Leipzig.
In his original complaint, Braun also cited a study that found that nearly half of respondents were thinking of using illegal gambling services due to legal restrictions.
In recent weeks, German authorities conducted a crackdown on an alleged illegal online gambling operation suspected of facilitating wagers totalling approximately €5.86 billion over a 30-month period.