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How to play Hot Star
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%.
How to play Hot Star
Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains it carried out an extensive technical, operational and compliance review of Evolution’s “business practices, public record database research and an assessment of the company’s anti-money laundering compliance procedures and processes, as they related to the allegations contained in the ‘anonymous report'”.
Tests carried out using a VPN to access banned markets found Evolution’s games had been available to players in the prohibited jurisdictions of UAE, Singapore, Hong Kong and Saudi Arabia.
However, further tests found that while using a VPN, Spectrum could not access Evolution’s games in the sanctioned markets of Iran, Sudan and Syria, despite claims to the contrary made by Black Cube in its prior report.
About Hot Star
The responsibility for a piece of work increasingly extends from identifying the problem to building, releasing and measuring the result.
The transformation has not eliminated all of Cubeia’s concerns. And inevitably some coders are missing their original role.
“We still have people who loved the coding part – solving problems with code and writing beautiful code. They’re struggling with the change. For some people an important part of their work that they genuinely loved is now gone.”