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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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Instead, the report recommended that advertising regulation be placed on a statutory footing under the Gambling Commission.
This would grant the regulator enhanced powers to proactively enforce rules and restrict problematic advertising channels effectively.
Gambling ads are currently monitored by ASA under the CAP 16.1 code. Just this week, Midnite received its third ASA ruling. The operator was told to remove a TikTok advertisement that featured a young-looking character.
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Braun also argued that the public had been excluded from the preparatory finance committee meeting without justification.
But the court said that point did not affect the validity of the by-law, adding that it saw no evidence of a tax that would choke businesses.
The judges highlighted the number of gaming halls in the city remained largely stable after the increase.