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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 framework also urged companies to implement rollback mechanisms and “kill-switch” controls for higher-impact systems.
For AI-powered customer support and chat, operators are encouraged to set clear parameters for when conversations should be moved to a human member of staff. These include repeated low-confidence responses, unresolved queries, indications of distress, or a customer simply asking to speak to a human.
The MGA said the charter will be reviewed periodically as technology and regulation develops.
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It called for any such acts to be reported immediately to the Ministry of Finance and the Directorate General of Administrative, Judicial, State Property and Equity Revenues (DGRAD).
The DGRAD has been tasked with identifying and securing the cancellation of any irregularly issued payment notices.
The Ministry of Finance stated that any approval, authorisation, payment notice or other act issued by a department without authorisation was “devoid of legal effect”, with operators still liable for fulfilling their obligations to the DRC’s Public Treasury.
