American bettors moved between $11 billion and $34 billion through unlicensed offshore prediction market platforms between April 2025 and May 2026, according to a report released June 11 by the Coalition for Prediction Markets (CPM), an industry lobbying group. The findings arrive one day after the US Commodity Futures Trading Commission (CFTC) published its first proposed formal rules for the sector, setting up a notable convergence of industry pressure and regulatory action in Washington.

Readers should weigh the report's conclusions with its origins in mind. CPM is an advocacy organization, not an independent research body, and its membership includes licensed US prediction market operators such as Kalshi, Crypto.com, Coinbase Global, Robinhood Markets, and Underdog, all of whom stand to benefit directly if offshore volume shifts to regulated domestic platforms. The research was conducted in collaboration with Harry Crane, a sports betting and statistics professor at Rutgers University, which lends analytical credibility, but the framing and funding are industry-directed. The New Republic has characterized CPM's approach as "borrowing from the addiction industry's playbook of using credentialed advocates to normalize high-risk financial products." CPM President Sean Patrick Maloney, a former US Congressman, former Chair of the House Commodity Markets and Digital Assets subcommittee, and former US Ambassador to the OECD, said in a statement that "the offshore and unregulated prediction market industry could grow to $133 billion by 2030, surpassing the combined size of America's video game and recorded music industries." CPM Senior Advisor Patrick McHenry, former Chair of the House Financial Services Committee, adds further institutional weight to the group's Washington presence.

Polymarket, a decentralized platform (meaning it operates on a public blockchain rather than a central server), accounts for nearly two-thirds of the offshore volume identified in the CPM study. The picture is more complicated than that framing suggests, however. Polymarket now operates two distinct products: a CFTC-regulated interface made available to US users following regulatory approval in November 2025, and a separate international exchange that remains outside CFTC jurisdiction. The distinction is material. In April 2026, the US-facing product generated $1.3 billion in trading volume while the international exchange generated $9 billion, a ratio of roughly seven to one. The offshore volume figures in the CPM study refer to that international exchange. The platform runs on Polygon, a layer-2 Ethereum network, and settles trades in USDC, a dollar-pegged stablecoin issued by Circle. That infrastructure makes it technically accessible to anyone with an internet connection and a crypto wallet. On-chain data tracked by TRM Labs shows monthly unique wallets on Polymarket reached roughly 840,000 as of February 2026, up from around 4,000 active traders in January 2024, according to data published by independent analyst Bagster. A single day, February 28, 2026, saw $425 million in trading volume across decentralized prediction markets, coinciding with news of US airstrikes. The CPM report also notes that licensed US operators, including Kalshi, Robinhood Markets, Crypto.com, Coinbase Global, and Underdog, grew 4.8 times faster than unregulated counterparts between 2024 and 2025, suggesting regulated infrastructure is scaling rapidly even as offshore activity remains dominant. Notably, the offshore share of total prediction market turnover has already declined, from 84% to 54%, as regulated US platforms have grown, indicating the gap is narrowing even if it remains large.

The CFTC's proposed rules, published June 10, would prohibit contracts tied to terrorism and assassinations while permitting most political and sports event markets. The agency has also asserted federal jurisdictional primacy over prediction market contracts in an amicus brief filed in February 2026, specifically opposing Nevada's attempts to regulate them at the state level. The timing of the CPM report, released the day after the CFTC's announcement, reflects a clear lobbying strategy: use volume data to argue that inaction simply redirects American money to platforms outside US consumer protection frameworks rather than eliminating demand.

The regulatory gap the CPM report describes is already generating real-world consequences in other parts of the world. India's Ministry of Electronics and Information Technology issued an internet service provider-level blocking order against Polymarket on May 21 to 22, 2026, citing the country's Promotion and Regulation of Online Gaming Act 2025 (PROGA), which classifies prediction markets as prohibited "money games." PROGA received Presidential assent in August 2025 and took effect on May 1, 2026, meaning formal enforcement followed the law's activation by just three weeks. The move came after both Polymarket and Kalshi continued allowing Indian users to sign up and trade despite earlier government advisories. On April 25, 2026, India's Ministry of Electronics and Information Technology sent letters to VPN providers warning that their services were being used to circumvent access controls on blocked platforms. Whether that pressure is working remains uncertain: reporting from Sportico found that multiple people in the US could still access the international prediction market using inexpensive VPN subscriptions, suggesting circumvention remains broadly accessible. For Indian developers building Web3 products, any protocol that routes event contract trading to Indian users now faces potential blocking and legal exposure under PROGA.

In Africa, the picture is different but urgent. Most prediction markets operate in a legal vacuum across the continent, with no formal classification as gambling or financial instruments in the majority of jurisdictions. Kenya and South Africa have high betting participation rates (79% and 83% of the population, respectively, according to 2025 survey data cited by TechLabari), and analysts describe prediction markets as a natural extension of existing sports betting culture in the region. Ghana presents a particularly stark picture: 71% of young people report placing bets, 84% exhibit problematic gambling behavior, and 68.8% report clinical anxiety related to gambling, according to research cited in the CPM brief. Kevin Ngugi, writing for Techweez, has argued that "prediction markets like Polymarket and Kalshi could change Kenya's betting culture by blending speculation, finance, and politics," a framing that captures both the appeal and the risk for regional regulators. A local platform, Predicta Markets, already offers contracts on Nigerian elections and the Naira to US dollar exchange rate. Analysts have urged African regulators to act before informal markets scale to the point where an abrupt crackdown, similar to what occurred in India, becomes the only available option. Some policy researchers have pointed to New Zealand's approach of classifying prediction markets as gambling under existing law as a potential template for the region, and have recommended co-authored regulatory frameworks between gaming commissions and securities regulators that treat prediction markets as high-risk hybrids of gambling and derivatives.

The CFTC's rulemaking process is now open for public comment, and CPM's report appears designed to feed into that process, framing offshore volume as evidence that inaction pushes American traders toward platforms beyond the reach of US consumer protection law. Whether expanded regulated access draws offshore volume home or simply adds a licensed tier alongside a persistent grey market remains the central open question. For the roughly 840,000 wallets that were active on Polymarket's underlying blockchain infrastructure as of February 2026, the answer will depend less on Washington than on whether regulators in their own jurisdictions move first.