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It called for any such acts to be reported immediately to the Ministry of Finance and the Directorate General of Administrative, Judicial, State Property and Equity Revenues (DGRAD).

The DGRAD has been tasked with identifying and securing the cancellation of any irregularly issued payment notices.

The Ministry of Finance stated that any approval, authorisation, payment notice or other act issued by a department without authorisation was “devoid of legal effect”, with operators still liable for fulfilling their obligations to the DRC’s Public Treasury.

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“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.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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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.