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Harris Tsangarides, executive director of the Gaming & Casino Supervision Commission, said his department had noticed spikes in gambling activity coinciding with GMI payment dates, prompting the regulator to consider “technical solution” to cross-reference GMI beneficiary lists with casino membership records.

An issue raised by Giannis Vasiliadis, director of WBAS, was the limited access to recipients’ banking information. This limited data can hint at suspicious activity but cannot conclusively verify gambling transactions.

Data Protection Commissioner Maria Christofidou said her office had reevaluated a 2022 legal opinion and now recognised a potential legal basis for more granular access to banking information.

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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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For now, the growth provides room for multiple market makers. Marantelli expects margins to “stay good during the growth period” before contracting as competition intensifies. The more complex RFQ and parlay markets may offer the best protection against that compression.

The result is an emerging ecosystem that looks less like millions of customers casually trading predictions with one another and more like an outsourced sportsbook trading room. Exchanges own the platform and recruit the customers; specialist firms price the risk and provide the money needed to make those markets function.

As Marantelli says: “Let’s call a spade a spade.”