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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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Lula said he intends to discuss the matter with his team and analyse potential measures to consider the social impact of online betting.
What the president does not acknowledge is that the government relies on revenue from the sector. In just the first seven months of 2026, BRL8.747 billion generated by sports betting has already flowed into public coffers. The Federal Revenue Service estimates the total could reach BRL16 billion by the end of the year. In 2025, nearly BRL9 billion was collected from sportsbooks.
The burning question is where such funds will come from if Lula shuts down the betting industry. Yet, no one points out to him that players will simply migrate to the illegal market. Betting will continue to exist, but without formal tax revenue, oversight or player protections.
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“In this case, it’s a completely different situation. You have a group, not a single company in a single country, a group which has been a solid group for 10 years and delivering. There’s no turnaround to be made. It’s already very well managed. It’s number one in its markets.”
The combined company will be listed on stock exchanges in both Spain and Italy, which Cirsa and Lottomatica are already market leaders in.Italy accounted for 57% of a combined group pro format adjusted EBITDA in H1. Spain made up 23% of that figure, with Rest of World at 20%.
Once the deal is completed, 80% of its EBITDA is expected to come from those two markets.