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Taken together, the cases provide further ammunition for the anti-gambling lobby at a time when it is already facing political pressure, tax increases and demands for tighter restrictions. Each apparently avoidable failure makes it harder for the industry to argue that existing regulation is sufficient.
Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.
“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.
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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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While the audience data did not conclusively define the website’s age demographics, the regulator noted small percentages of under-18s in HLTV’s social channels but found the website’s content and presentation clearly targeted adults.
Ultimately, the ASA ruled that the ads did not breach CAP Code rules 16.1 or 16.3.13 and took no further action.
Kathryn covers bitesize breaking news with a primary focus on EMEA and US legislation. A proud North Walian, fluent Welsh speaker and lifelong Wrexham FC fan – long before Hollywood came calling.