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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.
Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.
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The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.
Madsen is clear that Trace2Trace does not shut websites down. Instead it tracks domains, identifies connections and documents changes so that regulators, enforcement authorities or other customers can use the information.
That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”
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Atucha praises the regulation and the regulators themselves for making entry into the market easy, as well as allowing them to be competitive against illegal operators. But the market hasn’t been without its challenges.
A 1% selective consumption tax (ISC) on the value of every online bet has been in force since 1 July 2025, after the original policy was scrapped from proposed regulations in July 2021.
Atucha warns that regulations are often perceived as operator-friendly at the start before governments begin looking to squeeze licensed sectors, likening the process to “boiling a frog”. He has observed similar scenarios in other LatAm markets, with tax increases occurring in Brazil, Colombia and Mexico in the last couple of years.
