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As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”
In its market-specific breakdown, the report noted a “rapid reduction in channelling” in the UK, following the increased use of affordability checks.
The remote gaming duty hike from 21% to 40% in April is also expected to have a significant impact on the black market, with Regulus estimating it could drive the market to be worth up to €1 billion, as consumers choose illegal offerings to access unrestricted bonuses.
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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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It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.
Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds.
Giles Thomson, FATF president, said unregulated sectors risk becoming “attractive gateways for fraudsters, professional money launderers and organised criminal networks”. He called on governments to strengthen oversight, crack down on illegal and offshore operators and deepen public-private cooperation.
