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However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.
Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements.
The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.
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Ben Robinson, managing partner at Corfai, argues that the American listing achieved what it was supposed to achieve. The problems came afterwards. “The question was which arm of the K-shaped market Flutter would end up on. We have the answer now. Capital is concentrated in a narrow band of technology names and everything else is being marked on earnings.”
A US listing can improve access to capital without making the underlying business more attractive. London has a capital-markets problem. Gambling has an investment problem. The two overlap, but they are not the same thing.
Frank Fantini, founder and publisher emeritus of Eilers-Fantini, thinks the change began before Covid. “There is a tendency to look at the world as pre-Covid and post-Covid,” he says. “But the decline in gaming began earlier than that with the slowdown in new jurisdictions and new projects.”
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The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.
Madsen is clear that Trace2Trace does not shut websites down. Instead it tracks domains, identifies connections and documents changes so that regulators, enforcement authorities or other customers can use the information.
That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”