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Gambling ads are currently monitored by ASA under the CAP 16.1 code. Just this week, Midnite received its third ASA ruling. The operator was told to remove a TikTok advertisement that featured a young-looking character. 

The report singled out several marketing tactics which had been flagged as particuarly concerning.

The first was direct marketing (emails, texts, push notifications). Citing randomised studies, the committee noted that limiting direct marketing resulted in reduced betting and fewer short-term harms. 

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Madsen is clear that Trace2Trace does not shut websites down. Instead it tracks domains, identifies connections and documents changes so that regulators, enforcement authorities or other customers can use the information.

That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”

The objective, he argues, is to make it harder for operators to simply replace a blocked domain with another one. “If they knew there was a tool that would find those new sites as well, they might become more cautious.”

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The company cited analyses from the Office for Budget Responsibility which suggested previous gambling tax rises had reduced expected tax receipts, including a £500m reduction in forecast receipts for 2029-30. This revenue, writes David, would flow to the black market. 

A new report commissioned by Euromat, and produced by Regulus Partners and Helios, has estimated 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.

Entain said it had requested meetings with government officials to present its concerns directly and facilitate engagement between ministers and frontline shop staff before final budget decisions are made.