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“I’m trying to address every stage: prevention, support for people who are already struggling, and then action against the illegal sites.”

He does not believe illegal gambling can simply be eliminated. But he believes it can be made harder to operate. That may be the more realistic role for companies such as Trace2Trace as the illegal market evolves: not replacing regulators or enforcement agencies, but providing the intelligence needed to see beyond the individual URL. For Madsen, the motivation remains deeply personal: “I know very well what gambling addiction can do to people.”

The emergence of his company along with a string of others reflects a growing need in the industry: as illegal operators become more adept at moving, cloning and disguising their online presence, enforcement may increasingly depend on understanding the deep workings of the networks behind the screen.

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The conflict stems back to January 2025, when the outgoing Biden administration initially determined that the Vallejo parcel was eligible for gaming.

Interior temporarily rescinded that determination just two months later after newly appointed Secretary Doug Burgum raised concerns over whether the tribe’s historical connection to the land had been thoroughly evaluated.

Scotts Valley filed suit in response. In October 2025, Judge McFadden ruled that Interior had violated the tribe’s due process rights by rescinding the approval without giving prior notice or an opportunity to respond.

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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk. 

It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.

Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds.