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One of the proposals could be voted on next week by the city council and would directly affect the city’s clubs.
The meeting brought together 40 professionals from the clubs’ legal, communications and marketing departments, as well as executives from companies in the betting sector. Club officials are concerned about the financial impact of the measures, which could impact sponsorship contracts signed with betting companies.
One of the main concerns is Bill 560/2025, which is currently making its way through the council. The proposal prohibits advertising by betting companies at events in the city of São Paulo. This applies to events organised by public or private entities, whether for-profit or non-profit.
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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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The report assesses black market activity across 28 European jurisdictions, including the UK, Netherlands and Germany. According to estimates across a mature black market ecosystem, 25 operators account for approximately 64% of relevant black market traffic.
Thanks to the “rapid growth of crypto currencies” and globally recognisable branding through marketing and sponsorships, this handful of operators are generating the majority of illegal gambling traffic across Europe.
The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
