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Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools. 

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.

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Platforms were generally constructed for one person operating one account, rather than trading organisations requiring separate permissions and controls. According to Gonzalez, some teams still share a single login.

“Whether it’s a 10-person or 100-person fund, they log in through the same Google email and share the same login credentials, which makes no sense,” he said.

ParlayX is developing individual logins, delegated permissions and subaccounts for such teams. Other gaps include unified execution across exchanges, prime brokerage and common resolution standards.

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