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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. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website. 

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For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.

One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

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On the surface, Week 1 appeared exceptionally bettor-friendly, as Casino.org reported.

According to LSR, NFL teams combined for 791 points—tying 2012 for the highest opening-week total ever—while setting Week 1 records for total touchdowns (93), offensive touchdowns (90), and rushing touchdowns (37). Favorites went 12-4 straight up, while the Over hit in nine of 16 games (9-6-1).

At Caesars Sportsbook, seven of eight early afternoon favorites won outright, and six games went Over the total—many hitting the mark by halftime.