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The regulator of gambling in New Zealand announced on Friday that the funds returned by operators will be directed towards community organisations.

Under Section 106 of New Zealand’s Gambling Act 2003, a class 4 licence holder, also known as a “corporate society” by the regulator, “must apply or distribute the net proceeds from class 4 gambling only to or for an authorised purpose specified in the corporate society’s licence”.

The DIA worked directly with class 4 gambling operators (commonly known as pokies trusts), and discovered ‘widespread issues’ such as cases where money that should have been available for community grants was instead spent on society expenses, such as the purchase of additional gaming machines.

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Other estimates are considerably higher, illustrating how difficult the market is to measure. As an example, separate research from Gaming Compliance International put the value of unregulated online gambling at $5.9 trillion in wagering value in 2025, while estimating that unregulated operators accounted for 78% of global online gaming GGR.

Another report, commisisoned by Euromat, estimates that Europe’s black market has sustained a compound annual growth rate of 18% between 2019 and 2026, and will be worth up to €13 billion by the end of the year.

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.

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The Telegraph noted that it does not claim any funds allegedly misappropriated from MFS were used to finance Raja’s gambling.

Company creditors have alleged a shortfall of more than £1.3 billion ($1.7 billion), while administrators have accused Raja of orchestrating a scheme through which funds were systematically extracted from MFS and related entities.

A separate lawsuit brought on behalf of creditors alleges Raja received more than £408 million ($545 million) from funds managed by MFS into personal bank accounts across the UK, Monaco, Singapore, and the United Arab Emirates, according to The Telegraph.