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As such, the ad violated rule 16.3 of the CAP Code (Edition 12).

Midnite’s operator, Dribble Media Ltd, stated that the ad had not been authorised by their company. They cited discrepancies in branding and asserted that it was created and disseminated by an affiliate, Limay Media Ltd, without Midnite’s approval. 

Midnite confirmed it had terminated its contract with Limay and would reinforce compliance reminders to its partners.

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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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Bengtsson said momentum from the summer’s World Cup had continued into the second half of the year.

“The World Cup, as you know, is largely a customer acquisition opportunity, and it was also combined with a good turnover period for us,” he outlined. “Yes, that has continued.

“Now, having said that, we’ve also been in a low sportsbook activity environment during July when most football leagues have been closed. But we have that underlying improvement in momentum, and we continue that now throughout the rest of the year.”