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It called for any such acts to be reported immediately to the Ministry of Finance and the Directorate General of Administrative, Judicial, State Property and Equity Revenues (DGRAD).

The DGRAD has been tasked with identifying and securing the cancellation of any irregularly issued payment notices.

The Ministry of Finance stated that any approval, authorisation, payment notice or other act issued by a department without authorisation was “devoid of legal effect”, with operators still liable for fulfilling their obligations to the DRC’s Public Treasury.

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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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Kesitilwe told iGB an important theme of the event was fostering year-round collaboration and turning conversations on safer gambling into practical measures.

“The initiative demonstrates that cooperation does not have to remain at the level of conference and policy discussion,” he said.

“It has to translate into practical action, educating players, engaging communities, protecting young people and highlighting the dangers of illegal and unlicensed gambling.”