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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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Cruz, who chairs the Senate Commerce Committee, also co-authored the aforementioned Protect College Sports Act with Washington Senator Maria Cantwell. As cloture motion for floor debate of the act began this week, Cruz has expressed optimism that the bill will be signed into law.

The proposed bill seeks to prevent student-athletes from trading on prediction markets, but does not set any explicit standards on player harassment.

Separately, the two senators wrote a formal letter to a bevy of pro sport leagues last October requesting additional details on the leagues’ interaction with integrity monitors on suspicious wagering.

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A recent Fincord Intelligence report highlighted by the Betting and Gaming Council estimated that illegal online gambling generated around $50 billion in gross revenue globally in 2025. It estimated that around 5,000 operator structures were using more than 15,000 websites and apps.

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.