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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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Various MPs voiced concerns about the risk of privacy violations in accessing this data, and the potential social stigma around the information being shared.
Christofidou also floated the idea of issuing GMI recipients with a special card for in-person verification at gambling venues, but several MPs warned this could stigmatise welfare recipients.
Current gambling legislation restricts participation for minors and those classified as “financially vulnerable”. However, GMI recipients are not yet formally classified as such for the purpose of these regulations.
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The review examined the gaming sector and associated money laundering, terrorist financing and proliferation financing risks.
Spillemyndigheden said it contributed actively to this work and sat on FATF’s gaming sector working group. The regulator confirmed that many of the indicators in the report carry relevance for operators licensed in Denmark.
FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history.
