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The report was commissioned by Evolution and was recently unsealed in the ongoing case. Evolution had tried to delay the report’s release, citing confidential and commercial sensitivity.
The case, which dates back to November 2021, was filed by Evolution against Black Cube, after the intelligence firm was found to have been secretly investigating Evolution’s activities from December 2020.
Playtech commissioned Black Cube’s investigation, which Evolution has described as a “smear campaign” involving secretly recorded interviews with staff members.
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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.
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.”
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For Japan, the question is whether this broader proposition could make casino resorts more socially and culturally palatable by giving visitors reasons to come, other than gambling.
But for Klebanow, the lesson Japan should take from Macau and Singapore extends beyond the importance of non-gaming attractions. It is also about how regulation should work. Policymakers, he argues, should establish basic legal and commercial guardrails, while giving operators sufficient “latitude” to “propose and develop projects that best serve both the residential and tourism markets”.
He points to Macau’s Cotai Strip and Singapore’s Marina Bay Sands and Resorts World Sentosa as examples of how regulatory discipline can coexist with considerable freedom for developers to innovate. “At its core, Japan’s policies need to be pragmatic and allow for developments to succeed – not constrain them to the point that they risk failure.”
