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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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However, he may have indeed been able to spot the imperfection in the cards, which is an outcome completely different than what was ruled in the case of Phil Ivey, a popular poker pro who ended up using edge sorting to win millions of dollars, but had to forfeit or repay his winnings in the end.

Grant said, at the time of his own case against Star Casino, that he had noticed cards being asymmetrical, but that he had no way of knowing what the next card on his table would be – just like other players there.

How does this apply to Grant’s case against Royal Caribbean? Well, things may be different there; Royal Caribbean takes advantage of players in general, arguing that the practice is tantamount to cheating.

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Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website.