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Shuffle does not hold a licence to operate in the UK.
Meanwhile, Stake continues to feature on the sleeve of Everton’s kits, despite ceasing operations in the UK in early 2025 amid a Gambling Commission investigation into its advertising.
Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).
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Kendrick sees a warning in the history of betting exchanges. In their early growth phase, there was sufficient retail liquidity for numerous market makers to profit. As that retail pool weakened, the sharper firms increasingly found themselves trading against one another.
His analogy is a poker table at which the weaker participants sustain the game. If those players disappear, the fourth-best professional at the table can suddenly become a loser because only the three strongest remain.
The US addressable market is vastly larger and customer recruitment remains strong. Marantelli says Kalshi increased its number of clients fivefold during the World Cup, while White Swan predicts that NFL prediction markets could generate between $5 billion and $7 billion of liability in a single week.
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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.
