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The charter also made a series of other recommendations. It suggested that companies should designate a senior member of staff responsible for governance of the technology. It additionally recommended an AI oversight or ethics committee.

The framework also urged companies to implement rollback mechanisms and “kill-switch” controls for higher-impact systems.

For AI-powered customer support and chat, operators are encouraged to set clear parameters for when conversations should be moved to a human member of staff. These include repeated low-confidence responses, unresolved queries, indications of distress, or a customer simply asking to speak to a human.

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During immersive play, however, they wanted operators to take a more active role, through mechanisms such as pop-ups and reality checks.

After play, some looked to banks or regulatory bodies for oversight on total spend across platforms.

Within this shared model, there was a clear preference for personalised interventions over generic ones. 

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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%.