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The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

“There are significant checks on individuals and businesses before a licence is granted,” he says. “The UK Gambling Commission has set out what it expects. If you want a licence in the UK, you need to meet those expectations.”

Bentley believes regulated operators are genuinely trying to do the right thing but says some mistakes could be mitigated through better automation and continuous monitoring. Enforcement statements also provide lessons that businesses should use to test their own exposure.

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The committee’s previous 2020 report had recommended banning gambling ads on team shirts, training kits, stadium advertising and broadcasts, although on-course advertising for horse and greyhound racing was exempt.

The report rejected argumentswarning that advertising restrictions would drive consumers to illicit gambling sites. They citied weak evidence for mass migration to illegal operators following advertising limits. 

“Interviews [ … ] with representatives of state monopoly operators across European jurisdictions consistently suggested that advertising restrictions did not lead to consumer migration towards illegal operators,” the report said. 

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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.