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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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On Wednesday, the Science and Technology Committee (CCT) approved a project furthering restrictions on advertising and sponsorship of betting.

The proposal also established criteria for risk classification of products and clarifying the obligations of operators and platforms. The measure would likely grant the illegal market the opportunity to continue expanding, as it would be unaffected by the new rules. The committee approved a request for urgency for analysis by the Senate Plenary.

Authored by Senator Damares Alves and six other senators, Bill 2.470/2026 amends the Betting Law, which regulates fixed-odds betting, with measures aimed at protecting mental health, consumers, and the family economy. The bill received a favourable opinion, in the form of a substitute from Senator Alessandro Vieira.