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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

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Bentley believes regulated operators are genuinely trying to do the right thing but says some mistakes could be mitigated through better automation and continuous monitoring. Enforcement statements also provide lessons that businesses should use to test their own exposure.

“It would be crazy to say that these cases are positive for the industry,” he says. “They will no doubt continue, but as an industry we need to try to reduce their frequency.”

Enforcement publicity may lack context, and some settlements may involve errors rather than systemic recklessness. But the sector cannot control how its opponents use these cases. It can only reduce the supply.

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