Great 27

About Great 27

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%.

How to play Great 27

Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds. 

Giles Thomson, FATF president, said unregulated sectors risk becoming “attractive gateways for fraudsters, professional money launderers and organised criminal networks”. He called on governments to strengthen oversight, crack down on illegal and offshore operators and deepen public-private cooperation. 

The Danish Gambling Authority said on Friday that the report stems from a broader review by FATF member countries over the past year.

What is Great 27?

There’s no singular culprit for the Mid-Atlantic’s August casino woes but several likely factors.

The first is the ongoing cannibalization of in-person gaming by online casinos. The Mid-Atlantic is home to four of the country’s eight legal iGaming states: Delaware, New Jersey, Pennsylvania, and West Virginia.

While in-person casino revenue declined in Delaware, New Jersey, and Pennsylvania, iGaming reported GGR growth in each jurisdiction. iGaming revenue in New Jersey was up 4.4%, Pennsylvania’s online casinos saw GGR climb almost 6%, and Delaware iGaming surged 35%.