TWIN WINS

What is TWIN WINS?

Advertising prohibited: Direct or indirect marketing communication regarding betting on radio and television, newspapers, magazines, outdoor media, streaming services, podcasts, social networks, video platforms, apps, websites, blogs, forums, search engines and other internet environments is prohibited.

Messaging and targeted advertising: The restriction also extends to instant messaging, SMS, email, notifications, advertising automatically targeted by algorithms, telemarketing – which shows ads again to people who have already been exposed to certain content – and profiling based on user behaviour.

Other means of dissemination: The prohibition includes advertising in electronic games and esports, sports uniforms and equipment, public transport and affiliate content, tipsters, comparison sites and other paid intermediaries.

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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%.

What is TWIN WINS?

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

Tailored, behaviour-triggered messages were seen as more effective than generic warnings, but many participants simultaneously expressed mistrust towards operators collecting behavioural data.

Finally, the study found that these needs and preferences varied widely by product type.