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Below the largest exchanges, he sees numerous operators competing for relatively small shares of a fast-growing category. “If you get 1% of this market, I think it’s a huge opportunity,” Patel said. “There are a lot of people fighting to get 1%.”
Jefferies estimates exchanges can retain approximately 65% of explicit transaction fees, with the balance distributed across clearinghouses, brokers and liquidity providers. It therefore expects more operators to bring parts of the infrastructure in-house.
For the independent suppliers growing alongside them, however, the opportunity expands with every new exchange, contract and market maker. The consumer-facing platforms may attract the users, but their products cannot trade at scale without the data, liquidity and operational machinery developing behind the screen.
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Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.
Authorities were also reported to be working with communications and financial-sector bodies to restrict access to illegal platforms and disrupt associated payment channels.
With parliamentary approval secured, attention will now turn to presidential assent, commencement and implementation. The Gambling Authority will face the task of translating the proposed reforms into stronger digital oversight, more effective action against unlicensed operators and practical customer safeguards as Botswana’s regulated market continues to expand.
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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.”
