10 Kings

About 10 Kings

Skyhills is the third illegal operator targeted by Nederlandse Loterij, with prior legal action taken against Lalabet and Qbet. 

The Lalabet case, which reached a milestone in June, saw a Dutch court rule largely in favour of the lottery operator. 

It found Lalabet’s operators and directors had acted unlawfully by targeting Dutch players and ordered them to cease activities and provide detailed ownership and shareholder information.

What is 10 Kings?

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.

About 10 Kings

The charter does not create new regulatory obligations and was designed to complement legislation including the EU AI Act and GDPR.

Instead, it proposed a risk-based approach. It suggested lighter controls on use cases such as coding assistants, but strong checks on customer-facing functions, particularly those involving fraud and responsible gambling.

Kenneth Brincat, CEO of the MDIA, said companies needed “practical ways” to better understand where AI fits within their businesses.