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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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“Technology changes the equation,” he says. “If we can make development faster and significantly more cost-efficient, creators can afford to experiment again.

“I’ve said before that I think we’re moving towards the end of the traditional reskin model. Players don’t need another 100 versions of effectively the same game.”

“The ambition is to give talented creators the freedom to try more ideas.”

What is Roulette - Casino Style!?

The report highlighted the intense workload by estimating that a manager looking after 250 players would have roughly 100 seconds to commit to each player each day if their time was split equally. Data quality and fragmentation were also issues. 

Grygorenko emphasised that prioritisation was the key to adapting these portfolio sizes. 

“[At] above roughly 150 players per manager, personal knowledge stops scaling. The fix is not fewer players or more managers – it is showing each manager which few accounts actually need them today,” she added.