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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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The group highlighted potential risks posed by Google’s organic search features beyond paid advertising, which include autocomplete and suggested queries. 

Using data collected primarily through Chrome’s incognito mode to exclude personalised search histories, the KVA identified several autocomplete and pre-fill search queries that directly suggested illegal gambling platforms to users.

Examples included phrases like “online casino zonder Cruks” (online casino without CRUKS, the Dutch self-exclusion registry for problem gamblers) and “beste online casino buitenland” (best online casino abroad).

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