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The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.
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.”
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Last year, the DRC’s Minister of Finance Doudou Fwamba estimated iGaming operators generated around $1.7 billion in annual revenue, yet contributed approximately $1 million in taxes.
A CEO of a prominent operator in the DRC last year told iGB the tax system largely operates on a declaration basis of how much operators report to the government.
“Operators do pay, yes, but they pay whatever suits them,” they said. “In other words, we effectively pay what benefits us. All the while, the state has no means of monitoring its regulatory policies.”
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Touch Sokhak, deputy spokesperson of the Ministry of Interior, emphasised that the operation seeks to prevent Cambodia from becoming “a safe haven or money-laundering base for technology-related criminals”.
However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.
Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements.
