Cup Heroes

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“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”

For any consumer-facing businesses, a suspension is likely existential and such appears to have been the case here. But wider implications have to be considered before the two sites are binned forever.

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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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Illegal betting remained a central enforcement concern. In December 2025, the Gambling Authority and Financial Intelligence Agency were reported to be investigating eight foreign-based betting websites allegedly using local proxies to operate in Botswana.

Authorities were also reported to be working with communications and financial-sector bodies to restrict access to illegal platforms and disrupt associated payment channels.

With parliamentary approval secured, attention will now turn to presidential assent, commencement and implementation. The Gambling Authority will face the task of translating the proposed reforms into stronger digital oversight, more effective action against unlicensed operators and practical customer safeguards as Botswana’s regulated market continues to expand.