Hard to say for sure. They certainly seem to get more penalties than their opponents during any game they play (thus prompting me to ask this question myself during many Raiders games), but this doesn't mean they have the most.
This is a pretty open question. How far back should we look? All the way back to 1960 when they first started? That could take a while.
You can look up the statistics per season on www.nfl.com/stats and go nuts. For fun, I decided to look up how many penalties they have incurred recently.
From 2000-2008, the raiders have received 1109 penalties. That is an average of about 123 per season, or about 8 penalties per game.
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