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Rossi believes the ISC in Peru is an example of a government implementing new taxes without truly understanding how the industry works, and the potential impacts on channelisation to licensed offerings.
“Peru has been quite successful in channelling customers into the regulated framework,” Rossi comments. “The risk is that this channelisation can decrease in favour of the black market. We know the black market won’t have any consumption tax.
“There should be, in my opinion, a review of the whole ISC or consumption tax framework and find a kind of alignment or a better way to get an income in terms of taxes, but that should be balanced in order to avoid the disruption of businesses and a migration of customers to the illegal market.”
How to play Halloween Egypt Quest
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%.