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One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

Madsen says investigators can also examine how sites appear from different jurisdictions. If a site is presented in a country’s local language, for example, that can indicate that the market is being targeted. The next question is whether the operator has the necessary licence.

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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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