Crossword Genius

Frustrated European loudly had sex (10)

Ross

I believe the answer is:

checkmated

'frustrated' is the definition.

'european loudly had sex' is the wordplay.
'european' becomes 'czech' (Czech is an example).
'loudly' indicates a 'sounds like' (homophone) clue.
'had sex' becomes 'mated' (I've seen this before).
'czech' sounds like 'check'.
'check'+'mated'='CHECKMATED'

(Another definition for checkmated that I've seen is " Moved to victory".)

I've seen this clue in The Guardian.
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