The House · The Map

The house goes east

Most of the money in online gambling is somewhere its own government can't see or tax. Follow it — past the offshore two-thirds of America, past the fast-openers from Brazil to Finland, all the way to Asia, where the map is being redrawn in real time.


In the first two pieces I argued that everything is becoming a casino and that the casino is a magnificent business. This one is about a simpler, harder question: where in the world is all that money actually sitting? Because the answer is not where the laws are. There are two maps of online gambling — the map of where it's legal, which is small and moves slowly, and the map of where it actually happens, which is enormous and largely invisible. The whole game is the gap between them.

Start at home, in the most-regulated large market on earth, and the gap is already astonishing.

The offshore two-thirds

Americans wager tens of billions of dollars a year on online casinos that are entirely illegal where they live. By the estimate most often cited — from the Campaign for Fairer Gambling, using Yield Sec data, so read it as an advocacy figure rather than a regulator's — unlicensed offshore operators captured roughly two-thirds of all US online-gambling revenue in 2023: about $41 billion offshore against roughly $20 billion in the legal market. For 2024 the same source put the offshore share even higher, near three-quarters.1 Whatever the exact number, the shape is not in dispute: the legal, taxed, consumer-protected online casino is the minority of the American market. The majority runs through sites domiciled in Curaçao and Anjouan, paid in crypto, answerable to no US regulator.

Why? Because the United States legalized the worse business and mostly banned the better one. Seven years after the Supreme Court opened the door, sports betting is legal in 38 states and D.C. — 39 once Missouri went live on December 1.2 But online casino — the high-margin, no-season machine from the last piece — is legal in just seven: New Jersey, Pennsylvania, Michigan, West Virginia, Connecticut, Delaware, and Rhode Island, which was the last to launch back in March 2024. Not a single new state legalized online casino in all of 2025.3 States rushed to legalize the thin, seasonal, volatile product and balked at the fat one — spooked by lottery lobbies, by fears of cannibalizing their own keno, by the optics of a slot machine in every pocket. So two-thirds of the demand for the better product simply walked offshore.

WHERE US ONLINE-GAMBLING REVENUE GOES · LEGAL VS OFFSHORE 2023 $20B legal $41B offshore · ~66% 2024 $23B $67B offshore · ~74% LEGAL / REGULATED OFFSHORE / UNREGULATED
The legal US online casino is the minority of its own market. Source: Campaign for Fairer Gambling / Yield Sec (advocacy estimate).1

Hold onto that mechanism, because it is the master key to the rest of the map. Prohibition doesn't delete demand; it relocates it — offshore, into crypto, untaxed and unprotected. Everything that follows is a variation on how a given country answers that one fact.

The fast-openers

Outside the US, a wave of countries decided they'd rather capture the value than export it, and 2025 was the year the dam broke.

Brazil is the headline — and the cautionary tale. After years of grey-market chaos, its regulated betting-and-iGaming market went live on January 1, 2025, under a 12% tax on gross gaming revenue, and by autumn some eighty operators had licensed in.4 It is the largest market to open in a decade. It is also a live demonstration of what opening too fast can cost: Brazil's central bank found that, in a single month, billions of reais in Bolsa Família welfare payments had flowed to betting platforms; President Lula floated banning the whole thing; and the Supreme Court had to step in to bar welfare money from being gambled.4 Regulating the house and protecting the vulnerable from it turn out to be very different projects.

Elsewhere the openings are quieter but real. Finland — and the timing is almost poetic for this piece — voted just this week, on December 16, 2025, to dismantle the state's century-old Veikkaus gambling monopoly and license private online operators from 2027.5 The UAE stood up a federal gaming regulator in 2023 and handed Wynn the country's first commercial license for a resort casino opening around 2027 — a remarkable turn for the Gulf.6 New Zealand is mid-passage on a bill to auction fifteen online-casino licenses; Chile's senate advanced online-betting regulation in August; Mexico is debating its first new gaming law since 1947.7 The direction of travel is one-way: country by country, the grey market gets a front door. But the openings, however numerous, are not where the drama is. For that, you go east.

Asia is rewriting the map in real time

Asia is the center of gravity of global gambling, and in 2025 it became the center of gravity of gambling policy — a continent trying every possible answer to the prohibition-relocates-demand problem at once, often violently, often within the same quarter. Walk it market by market and you can watch all three strategies — capture, ban, leak — happen side by side.

The old capital is Macau, and it frames everything by contrast. The only place in China where casinos are legal pulled in about $28 billion of gaming revenue in 2024, up nearly a quarter year-on-year, recovering toward its pre-pandemic peak.8 And every dollar of it is land-based. Online gambling is illegal in Macau. The single greatest concentration of casino expertise on earth captures essentially none of the online value washing around it — a monument to how completely the action has moved from the floor to the phone.

Then the bans — and here Asia ran the cleanest natural experiment imaginable, because two countries banned online gambling in the same window and got opposite results.

India chose the hammer. In August 2025 its parliament passed the Promotion and Regulation of Online Gaming Act, in force from October 1, which outlaws all real-money online games — drawing no line between skill and chance, so fantasy sports, rummy, and poker all fell together.9 By the government's own numbers it shuttered an industry serving some 450 million users and worth on the order of $3 billion a year; unicorns like Dream11 and MPL halted their real-money products within days, and India's cricket team lost its shirt sponsor before the Asia Cup.9 A legal, taxpaying, venture-funded sector erased by statute overnight. Where did the demand go? Exactly where the US chart predicts: toward the offshore apps the ban can't reach.

The Philippines chose the scalpel, and it is the most instructive story on the continent. Manila banned the notorious offshore operators — the POGOs that served foreign (largely Chinese) bettors and had become a magnet for crime — ordering them shut by the end of 2024 and writing the ban into permanent law in October 2025.10 But at the very same time it channeled domestic players into a licensed onshore regime, and the result is the number that should be taped to every finance minister's wall in the region: the country's regulated e-games revenue grew 166% in 2024 to become 41% of all Philippine gaming, helping push total gaming revenue past ₱372 billion.10 Same prohibition impulse as India; opposite economic outcome. The Philippines killed the value it couldn't control and captured the value it could.

The rest of the region is mostly leaking. Japan keeps online casino flatly illegal, yet a 2025 police survey estimated some 3.65 million residents play on offshore sites, wagering on the order of ¥1.24 trillion a year — roughly eight billion dollars flowing straight out the door; Tokyo's response in September 2025 was to criminalize operating and promoting these sites rather than to license them.11 Singapore and South Korea run the tight-control model — physical resorts plus a single sanctioned online channel, with locals largely walled out and thousands of offshore sites blocked.12 The grey market across legal-and-illegal Asia is plausibly far larger than the $18–24 billion that commercial researchers size the legal online market at — because, as Japan and pre-ban India show, the unlicensed share is the iceberg, not the tip.13

ASIA · ONE WAVE, EVERY ANSWER (STATUS AS OF DEC 2025) MARKET STANCE SIGNAL Macau LAND-ONLY $28B GGR 2024 · online illegal China (mainland) BANNED all gambling illegal · vast offshore flow India BANNED 2025 real-money online banned Oct 2025 · ~$2.3B/yr Philippines OPEN · ONSHORED e-games +166% · POGOs banned Japan GREY ~¥1.24T offshore · crackdown Sept 2025 Vietnam GREY offshore football betting · locals pilot revived Thailand BANNED casino bill shelved Jul 2025 Singapore OPEN · TIGHT resorts + one channel · sites blocked South Korea LAND-ONLY locals barred except Kangwon Land OPEN GREY BANNED LAND-ONLY
Nine markets, every possible answer to the same wave. The Philippines — banning what it couldn't control, taxing what it could — is the one to study. Sources in notes.

Three doors, one fact

Step back and the whole map resolves into three responses to a single, stubborn fact: your citizens are going to gamble online whether or not you let them. You can capture the value (license and tax it), ban it (and watch it go offshore), or leak it (do nothing and let it bleed out). The money doesn't vanish under any of them. It just chooses an address.

Door 1 · Capture
License & tax
Brazil, the Philippines (domestic), the US iGaming seven, Finland-from-2027. Revenue and consumer protection onshore — if you can build the guardrails fast enough. Brazil shows the guardrails are the hard part.
Door 2 · Ban
Prohibit
India, Thailand, mainland China, the POGO side of the Philippines. Clean morally, leaky in practice: demand survives the law and migrates to operators you now control even less.
Door 3 · Leak
Do nothing
Japan (until recently), Vietnam, much of the region. The worst of both: all of the social cost, none of the tax, and the operators sit in Curaçao.

You can write the choice as a single line. A jurisdiction only taxes the share of play it keeps legal; everything else is exported, untaxed, to someone else's balance sheet:

$$ \text{tax captured} \;=\; \underbrace{s}_{\text{legal share}} \times \text{handle} \times \text{hold} \times \tau \qquad\Longrightarrow\qquad \underbrace{(1-s)}_{\text{offshore}} \;\to\; \text{exported} $$

Every government in this essay is really just choosing \(s\), the legal share — and pretending the other term is zero. It never is. The US chose a low \(s\) for casino and exported two-thirds. India just set \(s\) to zero and exported essentially all of it. The Philippines pushed \(s\) up where it could and watched the captured term grow 166% in a year.

$28B
Macau's 2024 gaming revenue — entirely land-based; it captures ~none of the online flow8
+166%
Philippine regulated e-games growth in 2024 — the dividend of onshoring demand10
~$2.3B
Annual Indian real-money market erased by the 2025 ban — and pushed offshore9
Capture, leak, ban — three numbers, three philosophies. Sources in notes.
From where I sit · Vietnam

Vietnam is door three, and you can feel it. Online gambling is illegal here, casinos were foreigner-only for years, and a licensed sports-betting regime has been "coming" since a 2017 decree that was never really implemented. Meanwhile the football betting never stopped — it just runs through offshore books the state can neither see nor tax. The one sign of movement came in late November 2025, when the government revived and widened the locals-allowed casino pilot, making Phú Quốc's Corona permanent and granting The Grand Ho Tram a new five-year trial. It's a land-based experiment in a world that long ago moved online. The leak keeps running while we debate the building.

What's hard — and what the map can't tell you

I've framed this as a value-capture problem because that's the honest description of the incentives. But I don't want the framing to do something it shouldn't, which is launder a harmful product into a fiscal opportunity.

"Someone will run it anyway, so it may as well be us, taxed and regulated" is the oldest argument in vice policy. It is often true — the offshore two-thirds is not a hypothetical — and it is also exactly what every operator who wants a license says, which should make you hold it at arm's length. The Brazil story is the necessary counterweight: capturing the value and protecting people from it are different jobs, and a government that nails the first while flunking the second has just built a more efficient machine for taking poor people's money. India's ban will fail on its own terms — the demand is already migrating offshore — but it is not irrational to decide some products are harmful enough that driving them into the shadows beats blessing them with a tax stamp. Reasonable people weigh those costs differently, and the spreadsheet doesn't settle it.

And a caution on the numbers themselves: almost every total in this piece is an estimate, several from advocacy groups or commercial researchers with a point of view, and the grey-market figures especially should be read as orders of magnitude, not precision. The direction is solid. The decimal places are not.

What the map does say, clearly, is this. The house is going east — and more than that, it is going everywhere the phone has gone, which is everywhere. The only real decision left to any finance minister, from Brasília to Hanoi, is not whether their citizens will gamble online. They already are, tonight, on an app the government has never heard of. The decision is whether the house they're playing at is one anybody can see. That question — who runs the legible, licensed venue when an entire category moves online — is the same one I keep circling from the prediction-markets side, where I think it has a far better answer. The casino is just where the stakes, and the externalities, are highest.

Three pieces ago we started with a phone glowing in a dark room. We end with a map of where all that glowing money goes when no one's set a place for it to land. Build the room, or export the revenue. There isn't a third option that makes the demand disappear — there's only the fiction that there is.

Notes
  1. Offshore share of US online gambling: Campaign for Fairer Gambling / Yield Sec estimated unlicensed offshore operators captured ~66% of US online-gambling GGR in 2023 (~$40.9B offshore vs ~$20.5B legal), rising to ~74% for 2024 (~$67.1B vs ~$23B) (Sports Handle, Jun 4, 2024; Covers, Apr 2025). These come from an advocacy group, not a regulator, and are cited as such; the broad "majority is offshore" conclusion is widely corroborated.
  2. Legal US sports betting operated in 38 states plus D.C. through most of 2025; Missouri's online launch on Dec 1, 2025 brought the live count to 39 (AGA; trade tracking). PASPA was struck down in Murphy v. NCAA (May 14, 2018).
  3. Legal US online casino (iGaming) as of December 2025: seven states — New Jersey (2013), Delaware (2013), Pennsylvania (2019), West Virginia (2020), Michigan (2021), Connecticut (2021), and Rhode Island (March 2024, the most recent). Nevada offers online poker only. No state legalized online casino during 2025 (casino.org; SBC Americas, Dec 2025). (An eighth state, Maine, legalized in 2026 — after this piece.)
  4. Brazil's regulated betting/iGaming market launched Jan 1, 2025 under Law 14,790/2023, with a 12% GGR tax; roughly 80 operators were licensed by October 2025 (Gaming Associates; SPA). On the backlash: Brazil's central bank found billions of reais in Bolsa Família welfare payments flowing to betting platforms (Aug 2024 data); President Lula publicly raised the prospect of a ban (Oct 2024); and the Supreme Federal Court barred the use of welfare funds for betting and tightened ad rules (Nov 2024) (SBC News; Covers; Casino News Daily). Proposals to raise the tax to 24% remained under debate, not enacted, as of Dec 2025.
  5. Finland's parliament passed a new Gambling Act on Dec 16, 2025 (158–8), ending the Veikkaus monopoly on betting and online casino; private B2C licences become available in 2026 and the licensed market opens July 1, 2027 (SBC News; Veikkaus Group).
  6. The UAE established the General Commercial Gaming Regulatory Authority (GCGRA) in September 2023 (chaired by former MGM CEO Jim Murren) and granted Wynn Resorts the country's first commercial gaming licence on Oct 4, 2024, for the ~$3.9B Wynn Al Marjan Island in Ras Al Khaimah, targeted to open around spring 2027 (not yet open as of Dec 2025) (Yogonet; Gambling News).
  7. New Zealand's Online Casino Gambling Bill passed its first reading July 16, 2025 (83–39), proposing 15 auctioned licences (in select committee as of Dec 2025); Chile's senate approved online-betting regulation in general on Aug 7, 2025 (not yet law); Mexico was debating a replacement for its 1947 Federal Gaming and Lotteries Law, with a 2025 fiscal package raising the iGaming tax from 30% to 50% (AGBrief; iGaming Brazil; iGaming Today; Sigma).
  8. Macau's 2024 gross gaming revenue was MOP 226.8B (~US$28.35B), up 23.9% year-on-year and ~77.5% of the 2019 record; the market is entirely land-based and online gambling is illegal in Macau (DICJ; Macau News; Casino.org).
  9. India's Promotion and Regulation of Online Gaming Act, 2025 received presidential assent on Aug 22, 2025 and took effect from Oct 1, 2025, banning all "online money games" with no skill/chance distinction; the government cited ~450 million users losing ~₹20,000 crore (~$2.3B) a year, against an industry valued near $3.2B. Dream11, MPL, and peers halted real-money operations within days, and India's cricket team lost its Dream11 shirt sponsor ahead of the Sept 2025 Asia Cup; a Supreme Court challenge was pending (deferred to late January 2026 as of mid-Dec 2025) (Al Jazeera, Aug 22, 2025; Business Standard, Aug 2025; TechCrunch).
  10. Philippines: President Marcos ordered the POGO (offshore gaming) ban in mid-2024 (Executive Order 74, Nov 5, 2024; cease operations by Dec 31, 2024), made permanent by Republic Act 12312 ("Anti-POGO Act of 2025," Oct 23, 2025). Domestically, PAGCOR reported total 2024 gaming GGR of ₱372.33B (+30.5%), with regulated e-games and e-bingo up 165.7% to ₱154.51B — 41.5% of the total — under the onshore PIGO framework (PAGCOR; GGRAsia; BusinessWorld).
  11. Japan keeps online casino illegal; a 2025 National Police Agency survey estimated ~3.65 million residents use offshore online casinos, wagering on the order of ¥1.24 trillion annually. Japan's revised Basic Act on Gambling Addiction took effect around September 2025, criminalizing the operation and promotion of online-casino sites; MGM Osaka, Japan's first integrated resort, is targeted to open around 2030 (NPA; Medianama; Yogonet).
  12. Singapore permits two integrated resorts (Marina Bay Sands, Resorts World Sentosa) with a local entry levy (S$150/day) and restricts online gambling to exempt operators (in practice Singapore Pools); the Gambling Regulatory Authority reported blocking thousands of unlicensed sites (~3,800 by end-2024). South Korea bars locals from all casinos except Kangwon Land and prohibits online gambling outside state-run channels (Gambling News; GRA reporting).
  13. Commercial researchers size Asia-Pacific's legal online gambling market at roughly $18–24B for 2024 (Market Data Forecast; Grand View; IMARC), with estimates varying widely by scope. The grey/illegal market is widely believed to be substantially larger — Japan's ~¥1.24T offshore wagering and India's pre-ban ~$3B legal sector (now driven offshore) illustrate why the unlicensed share dominates.
SL
Seeker Labs
An independent research practice — theses, trends, and where we see the next bets across markets, AI, and the technologies in between. By Viet Ho (Managing Partner) & John Nguyen (Founding Partner).
Viet Ho · vietho.me · @congviet
John Nguyen · jxhn.xyz · @jooohnng