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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%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

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The reforms, announced at the end of August, introduced a package of what it referred to as “evidence-based” legislation. 

As well as a statewide exclusion register, the package also set out to reduce the number of poker machines from the current figure of 87,000 across 2,100 clubs and hotels. 

The government said it aims to achieve this by increasing the forfeiture rate when gaming machine entitlements are traded from one in three to one in two. 

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An issue raised by Giannis Vasiliadis, director of WBAS, was the limited access to recipients’ banking information. This limited data can hint at suspicious activity but cannot conclusively verify gambling transactions.

Data Protection Commissioner Maria Christofidou said her office had reevaluated a 2022 legal opinion and now recognised a potential legal basis for more granular access to banking information.

Various MPs voiced concerns about the risk of privacy violations in accessing this data, and the potential social stigma around the information being shared.