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“Why not use the dataset I already have on gambling sites to map the most problematic ones, identify how they are connected and build a deeper picture of the networks behind them?” That thought process eventually gave birth to Trace2Trace.
Trace2Trace is relatively new, but Madsen says its underlying dataset has already grown to around 620,000. And it continues to grow, highlighting the scale of illegal operations in the gambling industry.
“We receive around 7,000 domains a day on average through the lists we monitor, including new and cloned sites,” he explains.
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Touch Sokhak, deputy spokesperson of the Ministry of Interior, emphasised that the operation seeks to prevent Cambodia from becoming “a safe haven or money-laundering base for technology-related criminals”.
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.
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Company creditors have alleged a shortfall of more than £1.3 billion ($1.7 billion), while administrators have accused Raja of orchestrating a scheme through which funds were systematically extracted from MFS and related entities.
A separate lawsuit brought on behalf of creditors alleges Raja received more than £408 million ($545 million) from funds managed by MFS into personal bank accounts across the UK, Monaco, Singapore, and the United Arab Emirates, according to The Telegraph.
Raja has also been accused of acquiring a fleet of luxury vehicles. The Telegraph reported these included six Ferraris, three Aston Martins, three Rolls-Royces, and two Mercedes-Benz vehicles.
