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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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It said all interviewees had cooperated fully and some of them had “virtually little or no familiarity with the allegations contained in the report, as their job responsibilities fall outside the scope of these matters”.

Kugler told Spectrum “it was never his intention to provide incriminating information”. He said he had felt duped by Black Cube, and noted the person he had met with had disappeared after the report was released. He believed they had used a fake identity.

“Kugler’s position is that Evolution does not supply games to Iran. He stated that “I know we have players in Dubai”, Spectrum notes, in response to Black Cube’s claims.

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This could precipitate as many as 1,470 shop closures and the loss of up to 15,900 jobs, according to figures commissioned via the Betting and Gaming Council and consultancy firm EY.

David further emphasised the impact such a tax rise would have on high street workers and communities.

“They are people losing their jobs and communities losing long-established high-street businesses,” David wrote.