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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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These include shared hosting, DNS clusters, source-code strings, tracking systems, logos and favicons. The system can also follow redirects and other mechanisms that may not be visible through a conventional web request.
A website might initially appear to be a normal local site, while behind it sits an iframe, JavaScript redirect or a chain of other pages leading to the actual gambling destination.
“You have to follow that chain,” Madsen says. In some cases, that chain can involve multiple layers. “A site might redirect ten times before reaching the actual destination.”
