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“Silent churn” was prevalent, with nearly half (46%) stating that VIP players often or very often became inactive without prior warning. Around 48% had no indicators of players’ behavioural signals or health. Co-author Viktoriia Grygorenko, CEO at The Playa, called this finding the “clearest commercial case in the report”.

“Every other finding – portfolio overload, fragmented data, reactive workflow, no behavioural signal – resolves here, in revenue that walks out without notice, without warning and without anyone getting the chance to intervene.” 

There was also strong interest in prioritisation tools, with 75% placing high value (8/10 or above) on daily prioritised action guidance for each player. 

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As well as a statewide exclusion register, the package also set out to reduce the number of poker machines from the current figure of 87,000 across 2,100 clubs and hotels. 

The government said it aims to achieve this by increasing the forfeiture rate when gaming machine entitlements are traded from one in three to one in two. 

The NSW government initiated its first formal review of ClubGRANTS in over a decade after taking office in 2023. Although the final report was submitted in January 2025, it has yet to be released publicly. 

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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%.

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