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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
“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.
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Angelozzi, who is set to lead the combined company as CEO, told analysts on the post-announcement call that the deal was expected to be a “low-risk proposition” given the consistent growth demonstrated by both Lottomatica and Cirsa in recent years.
Between H1 2024 to H1 2026, Lottomatica and Cirsa have grown their revenues at CAGRs of 13% and 11% respectively.
“The combined entity will be able to deliver the same rate of growth and the same rate of shareholder distribution, but with a larger pro forma free float and liquidity,” Angelozzi outlined.
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One of the main concerns is Bill 560/2025, which is currently making its way through the council. The proposal prohibits advertising by betting companies at events in the city of São Paulo. This applies to events organised by public or private entities, whether for-profit or non-profit.
The bill prohibits signs, banners, or display panels in arenas, gymnasiums, stadiums and other sports event venues. It also bans advertising on public transport, such as the side panel, exterior or the rear window of buses. The bill imposes a fine of BRL50,000 ($10,000) and a ban on hosting events for up to two years.
The proposal does not explicitly prohibit the display of betting brands on team jerseys, but some city councillors want to include this in the bill.