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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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Distributed gaming followed at 27%, then casinos at 25%.

Again highlighting his view that this was a low-risk merger, Angelozzi described Spain and Italy as “among the best globally” in terms of markets.

Angelozzi observed particular opportunity in Spain, where he estimated Cirsa holds 6% of the online market, suggesting it’s more fragmented and less developed than in Italy.

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