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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%.
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The studio has also carried its side-bet layer into the sequel. The slot also introduces a Side Hustles system, which functions as an optional stake increase tied to specific outcomes. Taken together, the expanded upgrades, buy options, and side bets suggest Nolimit City is refining a repeatable framework across sequels rather than reinventing its approach each release.
For players familiar with the first Duck Hunters, the takeaway is continuity with a raised ceiling. For those tracking Nolimit City’s portfolio, the sequel is evidence of a studio comfortable returning to proven mechanical families and layering additional monetization and volatility on top. That pattern fits the broader direction of a slots market increasingly built around recognizable, iterated math models rather than one-off novelties.
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In 2025, Brazil collected almost BRL10 billion ($1.97 billion) in tax revenue from the licensed sector. In the first seven months of this year alone, BRL8.7 billion generated by the activity was delivered to public coffers. The Federal Revenue Service itself estimates that the sector should reach BRL16 billion in revenue during 2026.
Besides revenue collection, another concern is legal and economic. Companies have paid over BRL2.5 billion for licences since the sector’s regulation. Certainly, the end of the activity would lead to litigation to recover the amounts paid and compensation for investments made. Furthermore, the revenue from betting is already included in the Annual Budget Law and the Budget Guidelines Law, which define the priorities for federal government spending.
What worries the sector is not just the threat of drastic measures against legalised betting. So far, the government has consistently fallen short in its attempts to curb the illegal market, which still represents almost half of the segment.