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Rather than a crackdown across the board, what emerged was a more regulated renewal framework.
Of the KSA’s update, Fuchs said: “If you [as an operator] have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.”
He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.
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As the NFL season begins, a state in close proximity to the New England Patriots became the latest to attempt to curb the influence of the trading platforms. On 10 September, one day after the Pats’ season-opening loss to the Seattle Seahawks, Connecticut Governor Ned Lamont addressed the growth of the markets during a speech in downtown Hartford. On the same day, the Connecticut Department of Consumer Protection issued cease-and-desist orders to nine unregulated operators, including Polymarket, Robinhood and Underdog Predict.
“Prediction markets have branded themselves as legal and safe, but the reality is they are not adhering to Connecticut’s consumer protection standards,” Lamont wrote in a statement.
While such orders have become customary around the nation this year, Connecticut’s missive took it one step further. The department also issued nearly 30 subpoenas to licensed gaming service providers and a bevy of media outlets. Those issued subpoenas include ones served to PayPal, Sportradar Solutions and Plaid, a payment processing app that holds a gaming licence. Although those companies are not under investigation, the subpoenas appear to be the first against service providers that conduct business with prediction markets in some form.
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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.”