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What is Gates Of Troy?
A lot of bigger questions remain without the CLARITY Act. The bill aimed to establish a federal framework for digital commodities and delineate the roles of the SEC and the CFTC.
Its failure also leaves unresolved disputes over prediction markets and state and tribal gaming authorities, outside a comprehensive congressional framework. Those issues took on new significance during Senate floor debate over the bill, as concerns about federal commodities oversight extended to markets typically regulated at the state or tribal level.
The latest filing is an early step in filling some of that regulatory gap for the CFTC. The agency can issue regulations under its current statutory authority, but those regulations would not necessarily be as permanent as legislation passed by Congress.
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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.
How to play Gates Of Troy
Industry consultant Jari Vähänen, formerly a senior executive at Veikkaus, estimated the entire business could be valued at up to €4.5 billion following the liberalisation of the market.
Veikkaus is adjusting to a partial liberalisation of Finland’s gambling market under the new Gambling Act, which was ratified in January 2026.
From July 2027, the company will lose exclusivity over betting and iCasino products, which will become licence-based, while retaining exclusive rights for lottery games, scratchcards, slot machines and physical table games.
