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A customer might buy a team at 55 or 56 cents expecting the price to rise to 58 or 59 cents, he explains. If it falls to 45 cents instead, the trader may refuse to accept the loss and continue holding the position.

“People will lose money faster on exchanges for lots of reasons,” Marantelli says. “It inherently increases spend, volatility, lots of things. And you’re playing against a sharper audience than you’re playing against at the DraftKings sportsbook.”

He compares the effect with sportsbook cash-out features, which gave customers more apparent control over their bets but may also have encouraged greater spending. The crucial difference is that an exchange customer can be facing a specialist whose entire business is identifying inaccurately priced contracts.

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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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Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.

Taking a deeper look at these restrictive driving black market activity, up to 46% of the markets covered in the report enforced “significant advertising restrictions” on the regulated market, including in Belgium, Bulgaria, Coratia, Cyprus, Germany, Italy, Latvia, Lithuania, Montenegro, the Netherlands, Poland, Romania and Spain.

Additionally the report cited taxing consumers (in 29% of the 28 markets covered), and banned products (14%), were also propelling growth in illegal gambling. A lack of choice, due to monopolies in place in five markets has also driven the rise.