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What is Zombie Queen?
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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Despite those warnings, the tribe opened its “Preview Casino” on July 24, offering Class II gaming out of modular structures.
Six days later, Interior determined that the land did not qualify for gaming under the Indian Gaming Regulatory Act (IGRA), forcing the tribe to shutter the operation and take the federal government back to court.
The arguments came as Scotts Valley asked US District Judge Trevor McFadden to issue a preliminary injunction blocking Interior’s July 30 decision. The outcome of the dispute directly threatens the tribe’s much larger ambition for the site: a proposed $700 million casino resort and hotel.
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The timing of regulatory tightening coincides with a vigorous government campaign against scams and illicit financial activities linked to casinos.
According to Khmer Times, the Cambodian government has announced a landmark decision to suspend all online gambling activities at its casinos starting October 2026.
The move aims to clean up the gaming sector by cutting ties between casinos, cyber-fraud operations and untraceable money flows. Deputy Prime Minister and Minister of Interior Sar Sokha warned that any casino found breaching the suspension after it takes effect risks licence revocation and further legal consequences.