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However, that responsibility does not lie with the Central Bank. It is the role of the Secretariat of Prizes and Bets to monitor and regulate the sector. Betting companies submit detailed daily reports on bettors’ financial transactions with the sites. A specific module within Brazil’s betting management system detects recurring transfers.

“Today I met a young man who made 1,400 Pix transfers in three months, and the Central Bank didn’t detect that this was an excessive number of transfers to the same company?” Lula said.

“Are we remaining passive while society drowns in debt? Are we remaining passive while society is driven to madness – because this is an illness? People lose their minds; they contemplate suicide or abandoning their homes. So, we are going to take serious action.”

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Her previous leadership roles include chairing the Independent Parliamentary Standards Authority (IPSA), the Bar Standards Board and acting as a lay member of the General Medical Council. 

Evans also served as a non-executive director of the Serious Fraud Office. She led the steering group responsible for a voluntary industry code that reimburses victims of authorised push payment (APP) scams, introduced in 2018.

Ahead of his departure Counsell said the Commission was developing a new strategy and ramping up its work to tackle illegal gambling, with Evans set to play a “pivotal” role as it also finalises measures from the Gambling Act review’s subsequent white paper.

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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.