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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.
The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.
All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.
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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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A memorandum of understanding, signed on Monday, aims to tackle rising gambling exposure among schoolchildren through smartphones. The aim is to integrate preventative education with broader school-based initiatives.
The agreement was signed at Osan Seongho Middle School and links gambling prevention education with a “phone free” strategy alongside RAS education. RAS is an approach combining reading, arts and sports and is designed to occupy students’ time with structured, screen-free activities.
The dual approach seeks not only to limit access to gambling content on smartphones but also to provide meaningful alternatives that reduce overall reliance on digital devices.
