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About The Equalizer
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.
What is The Equalizer?
It noted the role of machine gaming revenue in sustaining shops outside of race days, which in turn supports local economic activity, including around £50 million annually devoted to British horse racing.
Entain warned that a sharp rise in MGD could prompt customers to migrate out of the regulated market, estimating that up to £1 billion in gambling stakes could shift to the black market.
The company cited analyses from the Office for Budget Responsibility which suggested previous gambling tax rises had reduced expected tax receipts, including a £500m reduction in forecast receipts for 2029-30. This revenue, writes David, would flow to the black market.
About The Equalizer
Trace2Trace is relatively new, but Madsen says its underlying dataset has already grown to around 620,000. And it continues to grow, highlighting the scale of illegal operations in the gambling industry.
“We receive around 7,000 domains a day on average through the lists we monitor, including new and cloned sites,” he explains.
The system starts with domains that have already been identified by authorities. Trace2Trace then crawls them, looking for technical connections and similarities.
