Second Thunder

How to play Second Thunder

Madsen says investigators can also examine how sites appear from different jurisdictions. If a site is presented in a country’s local language, for example, that can indicate that the market is being targeted. The next question is whether the operator has the necessary licence.

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.

How to play Second Thunder

The restriction does not extend to strictly institutional communication made through the authorised operator’s own official channels, such as websites, apps, internal platform areas and customer service channels. In these spaces, information should be limited to company identification, official channels, access rules, self-exclusion and blocking mechanisms and mandatory warnings.

These channels may not contain promises of winnings, bonuses, invitations to bet, boosting or features designed to attract and retain user attention. The operator will also be responsible for the actions of affiliates, agencies, influencers, and other third parties who are paid or incentivised for commercial promotion. 

Sponsorship by betting companies would be prohibited for clubs and other sports entities, federations, leagues, competitions, sports broadcasts, cultural events, shows, educational and social projects, philanthropic entities, civil society organisations, political parties, candidates and election campaigns, as well as digital influencers, athletes, artists and celebrities.

What is Second Thunder?

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.