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He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”

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.

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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.

Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation. 

This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.

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The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.

In June, one of the operators, TOTO online BV, was reported for violating the ban on featuring role models in advertising materials.

This was not the first time TOTO has been in trouble with KSA. The platform was fined in 2022 for a similar endeavour – gambling advertisements that were seemingly aimed at young people.