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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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Meanwhile, Stake continues to feature on the sleeve of Everton’s kits, despite ceasing operations in the UK in early 2025 amid a Gambling Commission investigation into its advertising.

Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).

Entain highlighted data from H2 Gambling Capital that warned black market stakes in the UK are expected to nearly double from £17 billion ($22.7 billion) in 2025 to over £33 billion by 2028.

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However, the latest filing does not create such a system right away. Its OIRA entry describes the action as a preliminary measure and says it is not economically significant under the relevant review criteria. No legal deadline has been listed for review either. 

It could, therefore, take quite a bit longer than the timing of the initial filing indicates. The CFTC would have to publish its action and solicit public comment after White House review before writing a formal proposed rule. Any final rule would have to undergo another review and comment period before it could take effect. 

The distinction matters for crypto businesses. The filing shows regulatory work is moving forward, but exchanges and other market participants cannot yet consider it a set of rules they must adhere to.