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Managerial autonomy supported by senior leadership was also mentioned by respondents.

“VIP operations is the most human function in iGaming, run by the smallest teams, on the least purpose-built technology, against the shortest-horizon metrics,” said Grygorenko.

“The findings show that VIP managers are asking for a clearer signal on who needs attention, what has changed and where their judgment can have the greatest impact.”

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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.