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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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She mentions an ongoing lawsuit against Meta, which will be expected to be very challenging. The VNLOK-filed litigation is seeking to take action against the illegal gambling ads allowed to filter through to consumers across Meta’s various platforms.

“There are about 70,000 ads every single month for illegal operators or offerings – and there’s only two or three thousand from the legal market. It’s really unbalanced and they should regulate more.

“As a trade organisation we are trying to work together with our regulator because we feel that we have a shared interest of getting a good legal market. And of course we’re talking to politicians to do something about putting illegal operators on notice. I think it is really positive at the moment in the Netherlands that the operators have really teamed up,” Petra continues.