Howling Wolves

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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.

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Raja denies wrongdoing and maintains there was no fraud or dishonesty.

MFS operated as a non-bank lender—often termed a “shadow bank”—that borrowed funds from institutional investors to finance property loans for its clients.

The company experienced rapid expansion prior to its collapse, with its loan book reaching approximately £2.4 billion ($3.2 billion) by the end of 2024. Its creditors included major international financial institutions and private equity firms.

What is Howling Wolves?

“Our investigation revealed certain clients had allowed for Evolution’s game content to be provided on their online gaming websites in clear violation of their contracts, which expressly prohibited such game play in specified regions,” the report states.

Spectrum blames Evolution’s “ineffective complaince procedures”, noting these activities appeared to go undetected by the supplier.

“In our judgment, Evolution’s ineffective compliance procesures have allowed these situations to develop and therefore need prompt reevaluation and enhancement in order to comply fully with the terms of the contracts,” the report reads.