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Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.

“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.

Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.

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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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He said Cirsa wass already a well-managed company and in previous deals, it had tried to make too many changes to an asset. “First of all, in many cases you had M&A which was of assets that were second tier. The promise was to completely change the nature and the competitive position of the asset, in many cases, a turnaround.

“In this case, it’s a completely different situation. You have a group, not a single company in a single country, a group which has been a solid group for 10 years and delivering. There’s no turnaround to be made. It’s already very well managed. It’s number one in its markets.”

The combined company will be listed on stock exchanges in both Spain and Italy, which Cirsa and Lottomatica are already market leaders in.Italy accounted for 57% of a combined group pro format adjusted EBITDA in H1. Spain made up 23% of that figure, with Rest of World at 20%.