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He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”
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.
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Speaking at the 2026 South East Region Staff Excellence Awards in Gaborone, Kemorwale said unlicensed platforms were diverting an estimated P850m ($63.2 million) from Botswana’s economy each year and exposing children and teenagers to unregulated gambling.
He described the rapid growth of the illegal online market as one of the sector’s most serious challenges.
The bill would amend the Gambling Authority Act to align it more closely with the Financial Intelligence Act and Financial Action Task Force standards. Its memorandum says the changes are intended to strengthen anti-money laundering requirements and reduce financial crime risks.
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The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.
Helios, a specialist consultant in gambling web traffic, analysed the number of black market websites actively marketing across the 28 markets included in the report, between March and May.
This data was cross referenced with SimilarWeb traffic analysis to confirm the scale of activity. In some markets, the number of illegal sites being actively marketed was much higher than those that have local licences to operate.