The Grim Reaper

How to play The Grim Reaper

The report was commissioned by Evolution and was recently unsealed in the ongoing case. Evolution had tried to delay the report’s release, citing confidential and commercial sensitivity.

The case, which dates back to November 2021, was filed by Evolution against Black Cube, after the intelligence firm was found to have been secretly investigating Evolution’s activities from December 2020.

Playtech commissioned Black Cube’s investigation, which Evolution has described as a “smear campaign” involving secretly recorded interviews with staff members.

How to play The Grim Reaper

Prosecutors allege that five suspects had operated internet-based gambling services without the required German licences from at least July 2021. The volume of bets placed on these platforms reportedly exceeded €5.8 billion between mid-2021 and the end of 2023. 

In addition to illegal gambling, investigators suspect extensive tax evasion, with a projected tax shortfall of about €77.6 million for 2024.

The DSWV, representing licensed sports-betting operators, broadly welcomed the law enforcement action as a necessary response to the illegal market’s growth and associated risks. 

How to play The Grim Reaper

Operators must maintain permanent mechanisms for age verification, self-exclusion, voluntary time and wagering limits, and information on the user’s own gambling behaviour. Self-exclusion must be effective with all authorised operators. 

The text also prohibits bets placed using credit cards, the use of predictive models to identify moments of greater vulnerability, and platform design mechanisms that hinder a conscious decision to stop betting, leave the service, or activate limits and blocks. Operators must maintain permanent alerts about compulsive gambling, indebtedness and asset loss, and adopt verifiable protocols for identifying risky behaviour.  

The proposal establishes criteria for classifying products according to their potential for harm. Among the characteristics considered are instantaneous or short-lived results, continuous repetition at short intervals, use of random mechanisms to determine the outcome, intermittent rewards, near-miss incentives, incentives to recover losses and features that make it difficult to stop betting or induce successive, impulsive, or increasingly valuable bets.