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But he acknowledges the possibility that faster customer losses could eventually test the sustainability of the model.

“They lose quicker, dry up quicker, recruitment or re-recruitment,” he says. “If the recruitment of players dries up, then what are you going to do? Definitely there can be components like that.”

For now, the growth provides room for multiple market makers. Marantelli expects margins to “stay good during the growth period” before contracting as competition intensifies. The more complex RFQ and parlay markets may offer the best protection against that compression.

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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%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators. 

What is Three Kingdoms?

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