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Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.
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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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“Silent churn” was prevalent, with nearly half (46%) stating that VIP players often or very often became inactive without prior warning. Around 48% had no indicators of players’ behavioural signals or health. Co-author Viktoriia Grygorenko, CEO at The Playa, called this finding the “clearest commercial case in the report”.
“Every other finding – portfolio overload, fragmented data, reactive workflow, no behavioural signal – resolves here, in revenue that walks out without notice, without warning and without anyone getting the chance to intervene.”
There was also strong interest in prioritisation tools, with 75% placing high value (8/10 or above) on daily prioritised action guidance for each player.