Cai Shen 168

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“Why not use the dataset I already have on gambling sites to map the most problematic ones, identify how they are connected and build a deeper picture of the networks behind them?” That thought process eventually gave birth to Trace2Trace.

Trace2Trace is relatively new, but Madsen says its underlying dataset has already grown to around 620,000. And it continues to grow, highlighting the scale of illegal operations in the gambling industry.

“We receive around 7,000 domains a day on average through the lists we monitor, including new and cloned sites,” he explains.

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Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.

“There are valid arguments to be made in relation to raising the barriers to licensing, but this may come at a cost of diminishing competition and entrepreneurship,” he says.

In any event, successive regulatory tightening and tax increases have already created a “reasonably effective deterrent” to market entry.

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The timing of regulatory tightening coincides with a vigorous government campaign against scams and illicit financial activities linked to casinos. 

According to Khmer Times, the Cambodian government has announced a landmark decision to suspend all online gambling activities at its casinos starting October 2026. 

The move aims to clean up the gaming sector by cutting ties between casinos, cyber-fraud operations and untraceable money flows. Deputy Prime Minister and Minister of Interior Sar Sokha warned that any casino found breaching the suspension after it takes effect risks licence revocation and further legal consequences.