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The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.

Helios, a specialist consultant in gambling web traffic, analysed the number of black market websites actively marketing across the 28 markets included in the report, between March and May.

This data was cross referenced with SimilarWeb traffic analysis to confirm the scale of activity. In some markets, the number of illegal sites being actively marketed was much higher than those that have local licences to operate.

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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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The Commission’s investigation into what constitutes “informed choice” in gambling involved a multi-method approach. 

Researchers conducted a rapid desk review of 53 relevant sources, three deliberative focus groups segmented by gambling product type (sports betting, online casino/slots and land-based gambling) and four in-depth interviews with people identified as being at higher risk of harm (Problem Gambling Severity Index (PGSI) score of 8 or more). 

A total of 22 participants were purposely recruited to provide detailed insights.