You can always count on the Super Bowl to produce some mind-blowing statistics. For example, 111.5 million viewers tuned in to last year’s game, while 5.6 million people sent out 25.3 million tweets. And during the game each year, viewers consume 8 million avocados , 325 million gallons of beer, and 1.23 billion chicken wings.

The American Gaming Association added a new number to the list last week: $3.8 billion. That’s how much AGA estimates will be illegally wagered by Americans on this year’s Super Bowl between the New England Patriots and Seattle Seahawks. According to the group, that figure is 38 times higher than the $100 million that will be bet legally.

AGA based its estimate on past studies by the federal government and its own research.

“It’s a conservative estimate based on what we know to be true here in this sphere, and it shows that current law banning sports betting is clearly failing,” said Geoff Freeman, AGA’s president and CEO.

The release of the Super Bowl estimate is part of a larger AGA effort to separate its industry from what happens in underground gambling rings. In November, the group announced a new initiative to investigate the size and scope of illegal gambling in the U.S., and the next month it published a set of best practices to help its members curb money-laundering schemes within the industry.

“The purpose of all of our work is to draw a clear distinction between legal, regulated gaming and illegal gambling,” Freeman said. “It’s a responsibility that we have in protecting and promoting the value of the casino gaming that we represent in this country, and it’s a big priority for AGA in the years to come.”

Sports leagues like the NBA have called for the federal government to address the issue, and states are taking their own lead in trying to legalize sports betting, but AGA has yet to  take a formal stance. But that’s something the group plans to due in the near future, Freeman said.

“We’re bringing the industry together, and we have a number of very important discussions lined up in the coming weeks to figure out what we believe to be the best way forward,” he said. “From an association perspective, it’s very important to us that we do our due diligence so that we can work behind the scenes to get the industry aligned on a common point of view before we get out there and call for any specific actions. That’s an effort that’s taking up a lot of our time and attention, but it’s certainly time well spent.”

As for any future estimates on illegal sports gambling, Freeman said AGA will use the sports calendar to its advantage. (March Madness is just around the corner.)

“The Super Bowl creates a newsworthy time to discuss this issue,” he said. “You’ll see AGA actively engage at the appropriate times to continue to call attention to the amount of illegal gambling that’s taking place in this country.”

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