Casino & Gaming International: Issue 30 by Casino & Gaming International

2017 ISSUE 30

WELCOME ::

Publisher’s Note Publisher Jamie Kean jkean@cgimagazine.com Client Services Director Tracie Birch tbirch@cgimagazine.com Editorial Assistant Harry Wainwright hwainwright@cgimagazine.com Production Designer Nancy Rae nrae@cgimagazine.com Circulation Manager Natasha Harvey nharvey@cgimagazine.com Commercial Director Daniel Lewis dlewis@cgimagazine.com Account Manager Nathan Charles ncharles@cgimagazine.com

Editorial Contributors Julian Harris, Melanie Ellis, Fiona Palmer, Dr. Jason Lane, Helen Hedgeland, Nimrod Ifrach Alessandro Fried, Bernard Marentelli Jure Rejec, Dr. Mark Griffiths

Annual Subscription Rates (4 Issues - Published Quarterly)

Includes all Printed + Digital Versions

£80 £90 £100 £110

UK Europe & Middle East USA & Canada Rest of the World

E: subscribe@cgimagazine.com

Published by DANANCY MEDIA LIMITED

T: +44 (0) 845 257 8300 E: contact@cgimagazine.com W: cgimagazine.com

ISSN 2398-4252

© 2017 Danancy Media Limited. The opinion expressed in each article is the opinion of its author and does not necessarily reflect the opinion of the publisher. Any form of reproduction of any content in this publication without the written permission of the publisher is strictly prohibited.

lthough the summer is generally a quiet time of the year from an

industry events perspective, the planning and build up to the

heavy autumn schedule is well under way. As ever, G2E leads the

way at the beginning of October, which is quickly followed by a

whole host of events including EiG, SAGSE and SiGMA among others (for further details, take a look at our forthcoming events on page 50).

In this, our 30th edition of CGi, we are delighted to have been joined by

both Julian Harris and Melanie Ellis (Harris Hagan) with Julian looking at how

the Gambling Commission are dealing with the ever changing regulatory issues

it is being faced with, whilst in a separate piece, Melanie takes in depth look at

misleading advertising and how the Gambling Commission and Competition and

Markets Authority in particular, are tackling the issue.

Fiona Palmer (GAMSTOP) joins us for the ﬁrst as she explains the purpose

of GAMSTOP and how it provides consumers with the option of self-excluding

themselves from all Gambling Commission remote licensed operators.

Dr. Jason Lane (Jersey Gambling Commission) takes in depth a look at

gambling as a form of charitable fund raising, whilst Helen Hedgeland

(Evolution Gaming) joins us again to discuss the ever growing live casino and

convergence market.

Nimrod Ifrach (Optimove) goes all data science on us and provides us with

a detailed analysis of recommended systems in iGaming, which is followed by

two leadership insight feature articles by Alessandro Fried (Chairman, BtoBet)

and Bernard Marantelli (CEO, Colossus Bets), who share their Sportsbetting

expertise with us.

And to wrap things up, Jure Rejec (Oulala) discusses Daily Fantasy Sports

whilst Dr. Mark Griﬃths (Nottingham Trent University) looks at the

psychosocial impact of it.

Jamie Kean, Publisher

The next edition (Issue 31 of CGi will be published on 1st November 2017.

You can also connect with us via...

CGiMAGAZINE.COM

CONTENTS ::

FEATURES 7

WORRYING INFLUENCES ON THE GAMBLING COMMISSION

MISLEADING ADVERTISING AND UNFAIR PROMOTIONS â&#x20AC;&#x201C; REGULATORS ARE UPPING THE ANTE

Julian Harris, Harris Hagan

Melanie Ellis, Harris Hagan

GAMSTOP: TURNING A VISION INTO REALITY

GOOD INTENTIONS AND OTHER REFLECTIONS ON THE ROAD: GAMBLING AS A FORM OF CHARITABLE FUND RAISING

Fiona Palmer, GAMSTOP

Dr.Jason Lane, Jersey Gambling Commission

A CONVINCING CASE FOR CONVERGENCE Helen Hedgeland, Evolution Gaming

CGiMAGAZINE.COM

CONTENTS ::

43 39

47 35

FEATURES 31

RECOMMENDATION SYSTEMS IN IGAMING: A HANDS-ON STRATEGY

STAYING AHEAD IN THE TECHNOLOGY BATTLE

SPORTS VENTURING INTO THE UNKNOWN: A TALE OF DAILY FANTASY AND SAVING FACE IN AN UNFORGIVING INDUSTRY

Nimrod Ifrach, Optimove

Alessandro Fried, BtoBet

Bernard Marentelli, Colossus Bets

POKER AND DFS: FAST MOVER ADVANTAGE

THE PSYCHOSOCIAL IMPACT OF DAILY FANTASY SPORTS GAMES

Jure Rejec, Oulala Network

Dr. Mark Griï¬&#x192;ths, Nottingham Trent University

CGiMAGAZINE.COM

REGULATORY ::

WORRYING INFLUENCES ON THE GAMBLING COMMISSION T

he Gambling Commission recently published its annual report and accounts for 2016/17. These, together with a recent speech by Tim Miller, Executive Director, Corporate Aﬀairs and Research at the Commission, provide insight into current and future regulatory policy inﬂuences at the Commission. There are some potentially worrying indicators here, which seem to suggest that the Commission is at risk of being led – or leading itself – astray. It is worth starting with a reminder of the Commission’s statutory duties, under the Gambling Act 2005, which are to permit gambling in so far that is consistent with the licensing objectives: • • •

Julian Harris Partner Harris Hagan

Preventing gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime; Ensuring that gambling is conducted in a fair and open way; Protecting children and other vulnerable persons from being harmed or exploited by gambling.

The Chairman’s message in the Report repeats those statutory objectives, but then refers to “wider contextual aspects that we should not ignore”. He then refers to the problem gambling cost to the economy and to individuals and families, the scale of which he claims is poorly understood. He further suggests that public opinion needs to be taken into account. He asks, “what kind of gambling market does Britain want?.......does the country want gambling to be a constantly growing industry operating within a light touch regulatory approach” or, “is the public inclined to be less supportive for growth and increasing its sociability, and more supportive of a tightening of regulations?”. He then refers to evidence indicating that “public attitudes to gambling are hardening” with 69% of people believing that gambling is CGiMAGAZINE.COM

:: REGULATORY

<< If 39% of the public believe that gambling is associated with crime, what does that actually demonstrate? >> dangerous to family life, and 55% that gambling should be discouraged. He concludes that public attitudes towards gambling have become less tolerant and therefore that: “this is a trend which we must recognize and will influence our approach to regulation”. In fairness, the Chairman accepts that the scale of gambling related harm is “not at all clear”. On that at least we can agree. However, he then refers to the Commission’s estimate that there are approximately 320,000 problem gamblers and a further 2.5 million at risk of experiencing gambling harm. The Commission intends, he says, in conjunction with the Responsible Gambling Strategy Board, to develop definitions and estimates that “command general confidence”. Tim Miller spoke at the International Association of Gaming Advisors (“IAGA”) Summit in New York in May, on which David Clifton has commented. In very brief summary, Mr Miller said that the gambling industry needed to perform better both in relation to social responsibility, but also as to its public image, as reflected in the press. He prayed in aid of his comments similarly depressing statistics from the Commission’s survey “Gambling Participation in 2016: Behavior, Awareness and Attitudes”. In particular, these were that 66% of people interviewed thought gambling was unfair and that the industry was untrustworthy, and that 39% believe that gambling is associated with crime. In line with the thinking of his Chairman, Mr Miller said that such surveys would help the Commission determine its regulatory policy I have grave concern about these figures, the way in which they are being used to influence the way in which the industry is to be regulated and the apparent willingness of the regulator to determine its policy based on the views of the anti- gambling lobby, media tittle tattle and half-baked statistics. When Tim Miller spoke at IAGA, it was to a room packed not only with lawyers and other advisors, but senior figures representing the global gaming industry, many representing licensees subject to the Commission’s regulation, none were prepared to challenge him or ask a question: understandably so. It falls to those of us who are independent advisors and consultants to voice our concern as to where the Commission and Government may be headed. Returning for a moment to the Commission’s annual report, it states on page 28 that “our regulatory approach is evidenced led”. I would personally question whether the survey upon which the Commission’s Chairman and Tim Miller place so much weight constitutes reliable evidence. Surveys conducted regularly may be indicative of a trend, but can it really be right that a survey of 4,000 people, or 40,000, or indeed any other number, should dictate the regulation or policy adopted by a regulatory authority set up under statute towards an entire industry? Apart from the now notorious unreliability of opinion polIs, highlighted in the referendum and in the last three general elections in the United Kingdom, it seems to me that the unreliability of such evidence can be demonstrated by

CGiMAGAZINE.COM

the worrying 39% who think that gambling is associated with crime. In reality, that is probably lower than it was 10 or 20 years ago, but, like much else to do with gambling, it is a belief perpetuated by the media, in particular the British press and American film companies, whose portrayal of the industry is generally associated with crime. It seems not to have occurred to Tim Miller and his colleagues at the Gambling Commission that public opinion as expressed by the sample of 4,000 people may have been influenced by media hype, sensationalism and misinformation. To that point, if 39% of the public believe that gambling is associated with crime, what does that actually demonstrate? The reality is that gambling has been legal in this country since the beginning of the 1960s. Apart from occasional incidents and inevitable regulatory breaches, there has been no serious crime associated with gambling in Great Britain since George Raft, Hollywood film star and mobster, was deported in 1962 and his Club (the original Colony Club) was closed. It took many years for crime to be extinguished from gambling in the United States; it is a tribute to the successful regulation of gambling in Great Britain that it has been generally crime free for more than half a century. If 39% of people still believe that it is associated with crime, it is probably indicative of ignorance on their part, prejudice on the part of the press and lobbying groups and a failure by both Government and regulator to try to set the record straight. And the fact that the public believe something which is untrue does not make it true. If it were true this would be a very serious reflection on the efficacy of the regulator. Frankly, whatever that percentage, how can it predicate any particular regulatory response? It is for the regulator to determine whether there is any crime in the gambling industry and to deal with it irrespective of whether anyone else believes it is there: the erroneous opinion of a section of the general public is irrelevant to the exercise by the Commission of its statutory duty. Interestingly, only 0.7% of those surveyed identified as problem gamblers, from which the Commission calculate that 1.3% of gamblers have a problem. This very low percentage has been relatively consistent over many years, though if anything it has fallen since 2004, before the passing of the 2005 Act. This fact is at best generally glossed over by the Commission. Instead the Commission now claim that 10% of gamblers – some 2.5 million people – are “at risk” of becoming problem gamblers. It may be that the Commission is clear as to what constitutes “at risk”, and how this number is calculated, but I for one am not aware of it and have seen no explanation. But whatever that may be, without a definition, this estimate is meaningless and serves only to act as a red top or Daily Mail headline: i.e to scare and to cause an overreaction. One wonders where this will end; after this category, of those “at risk”, will the next on which the industry has to be regulated be those “at risk of becoming at risk” of becoming problem gamblers? Is there not an argument that the moment a

REGULATORY ::

person buys the first lottery ticket, has the first drink or swallows the first pill is the moment they become to some degree at risk of addiction? Coming back to the Chairman’s message and his search for regulatory guidance in statistics, he takes from the percentage of people who believe that gambling is dangerous and should be discouraged, that this must be reflected in the Commission’s approach to regulation. How can this be achieved? The Commission’s statutory duty is to permit gambling subject to the licensing objectives. Whilst it is true that the Commission also has a duty to advise Government on the provision of gambling, this is a very different matter from its regulatory function. Even in this regard, I question whether its advice should be dictated by a survey of 4,000 people. But the approach to regulation is not a matter that has anything to do with how much people like or dislike gambling. Government by public opinion, otherwise known as the tyranny of the majority, is a dangerous concept; regulation by public opinion is a terrifying one. Sir Winston Churchill referred to statistics being “like a drunk with a lamppost: used more for support than illumination”. No one would expect the Gambling Commission to be a flag bearer for the industry which it regulates. By the same token, no one would claim that the industry is in all respects perfect: far from it. The Commission is fulfilling its statutory duty in seeking to ensure that gambling is conducted fairly and openly. Its recent campaign challenging the fairness of some operators’ terms and conditions of business and identifying AML failings is perfectly proper. So too is the Commission’s campaign to persuade the industry, or parts of it, to improve its approach to social responsibility measures, and to design tools for players that help them manage their gambling in the new ways that technology makes possible. Raising standards is a laudable aim, but let us not ignore the fact that compliance with existing standards, as reflected in the LCCP, is not a breach of any regulatory requirement. There are times when it seems that every utterance, every publication, every statistic produced by the Commission continues the necessarily one way stream of criticism of the industry. In particular the press, or sections of it, have for many years waged a campaign against the gambling industry, as have certain religious organisations. Stories designed to scare rather than inform are of course reflected in the figures quoted by the Commission, and now are being used by the Commission to develop policy. We therefore have a vicious circle of misinformation. In pursuing this route the Commission are heading into dangerous territory. Aside from giving the impression that they are perhaps seeking out and using statistics in the way described by Churchill, their policy is dictated by statute; not by surveys, not by the press, not by statistics and not by research into what some group thinks it wants. It isn’t just the use or misuse of statistics that is worrying. In Tim Miller’s speech he spoke of how the 2005 Act was actually a “social contract” between the gambling industry and the British public. He stated his belief that: “there is still public support for the existence of gambling as a leisure activity but growing concern about the way it is being offered.” And asked: “Society wants to change the terms of its contract with the gambling industry. The question is ‘Are you ready’?” Interesting though Tim’s foray into questions of jurisprudence and sociology were, they are not the stuff of which regulators should speak; it goes beyond their remit as regulators. In any event, the argument is obviously flawed. The

suggestion was being made that the industry needs to change. However, if it were the case that the 2005 Act is a social contract, which I do not accept, and if that contract requires change, then that can only properly be achieved by changing the Act. Tessa Jowell, then Secretary of State, in her introduction to “A Safe Bet for Success”, the Government white paper setting out its intentions prior to the 2005 Act, referred to wanting to see a successful gambling industry: “…building on its existing reputation for quality and integrity…”. Clearly much has changed since then, as the Commission would have us believe. But I ask whether this is the reality, or a chimera. Most of the industry is compliant with the law, regulations and the LCCP. If and when licensees are not compliant, it is for the Commission to address that by appropriate means in pursuit of the licensing objectives. If it decides to pursue other objectives based on its perceived interpretation of public opinion, and half-baked sociological and jurisprudential theories, it is in danger of stretching those licensing objectives to breaking point. So what should the Commission be doing? In my view, there is plenty to do regulating the largest gambling industry in the world, without seeking new and additional issues with which to grapple, or perceived new faults to criticize, especially when garnered from the pages of the press or research. The industry is constantly being urged to talk to its customers, a mantra repeated by Tim Miller. Of course it does so, all the time, as any successful industry would. Can the Commission say the same about its informal discussions with the industry? I would recommend that the Commission spend more time developing an understanding of the industry and how it operates. I might also add that perhaps, just occasionally, and in terms that are not too gushing, the Commission might just draw attention to the fact that it does such a good job that this industry is better regulated, better conducted and more trustworthy than many others that have appeared in the news recently. Oh, and it also pays its taxes! :: CGi

JULIAN HARRIS

Recognised as a leading expert in national and international gambling and licensing law, Julian Harris is highly regarded by both operators and regulators throughout the world. Harris Hagan is the ﬁrst and only UK law ﬁrm specialising exclusively in legal services to the gambling and leisure industries. With over 30 years experience of gambling law Julian has advised some of the world's largest gaming industry corporations. He and his team have also advised governments, trade associations and private equity houses in both online and land based gaming. Julian is an experienced advocate, a respected and sought after conference speaker and author. He is recommended in all guides to the legal profession, and has been described by Chambers Guide as “the best gaming lawyer in London”. Harris Hagan was awarded “Gaming Law Firm of the Year” in 2013. Julian is past President of the International Association of Gaming Advisors.

CGiMAGAZINE.COM

REGULATORY ::

MISLEADING ADVERTISING AND UNFAIR PROMOTIONS – REGULATORS ARE UPPING THE ANTE A

Melanie Ellis Senior Associate Harris Hagan

s part of its focus on consumer protection and the “fair and open” licensing objective, the UK Gambling Commission (the “Commission”) has recently begun imposing penalties on operators due to advertising failings which it considers have resulted in customers being misled. In April 2017, the Commission concluded its review of BGO Entertainment’s licence which followed two rulings against the operator by the Advertising Standards Authority (“ASA”), one of which related to failing to make significant conditions of free bet offers clear to customers. A £300,000 financial penalty was imposed. Then, in June 2017, the Commission published an agreed public statement in connection with advertising failings by Lottoland, which again followed a complaint being upheld by the ASA. Lottoland agreed to a voluntary settlement of £150,000. Similar issues with misleading adverts and promotions have now also led to enforcement action against several gambling operators by the Competition and Markets Authority (“CMA”). On 23 June 2017, the CMA announced that it was commencing action against operators which it considered had broken the law by imposing unfair play-through conditions and game rules, and failing to provide clear information to customers. In a statement by Nisha Arora, Senior Director for Consumer Enforcement, the CMA indicated that it considered “the dice are loaded against [customers]”. As shown by its action following ASA rulings, the Commission may have the appetite to commence its own regulatory action against the operators under investigation, following whatever action is taken by the CMA. Gambling Commission Chief Executive Sarah Harrison warned that “the gambling industry should be under no illusion that if they don’t comply with consumer law, we will see this as a breach of their operating licence, and take decisive action”. The issues which led to both the ASA action against BGO and the CMA action against the as-yet unnamed operators stem from CGiMAGAZINE.COM

:: REGULATORY

the terms and conditions applicable to free bet and bonus promotions. Whilst the ASA focuses on whether signiﬁcant conditions of promotions are made clear to customers, the CMA’s remit relates more to the fairness of the conditions themselves. The outcome of the CMA cases is not yet known, but it is likely that it is considering both the content of the conditions and the way in which they are presented to customers, as unfairness can arise from complexity and bad presentation of T&Cs as well as from their provisions.

Potentially unfair rules that restrict certain play strategies, which operators rely on to deny customers a pay-out.

The CMA’s concerns primarily relate to unfairness to the customer, for example customers being unable to properly evaluate whether they should take up an oﬀer due to inadequate information being provided. However, there is also a social responsibility element to the CMA’s concerns. Extensive play-through requirements raised the concern that customers are being denied “the opportunity to quit while they are ahead and walk away”, the implication being that problematic gambling behaviour may be encouraged by the need to play through a bonus amount a large number of times in order to withdraw the amount in cash. The CMA stated in relation to this action that it has “a range of powers at its disposal to bring any illegal activities to an end”. To put this into context, the CMA’s consumer protection powers include:

The Commission’s powers Compliance with the provisions of the CAP and BCAP advertising codes which relate to making significant conditions of an offer clear is a “social responsibility code provision” within the Licence Conditions and Codes of Practice (“LCCP”) applicable to a UK operating licence. Unlike the lower status “ordinary code provisions” of the LCCP, compliance with social responsibility code provisions is a condition of the licence. This means that any breach of these provisions can lead to a licence review and financial penalty or even suspension or revocation of the licence in the most serious cases. Compliance with the remainder of the CAP and BCAP advertising codes (including the gambling specific provisions such as that advertising must not be socially irresponsible or appeal to children) is an “ordinary code provision”, which means that non-compliance is not a breach of the licence. However, compliance is regarded as good practice and failure to comply may be taken into account should a licence review take place for other reasons. Noncompliance with an ordinary code provision cannot, in itself, lead to a financial penalty. The Commission also has a broad remit to review an operating licence in any circumstances where it suspects the licensee may be unsuitable to carry on the licensed activities. Both the BGO and Lottoland cases involved misleading advertising and therefore breaches of the social responsibility code provision. However, in the future the Commission might conduct licence reviews due to serious breaches of other advertising provisions or more generally in relation to failure to promote the “fair and open” licensing objective, on the basis that the conduct by the licensee has put its suitability into question. In the past, the ASA’s powers have been seen as lacking teeth, given that it is limited to telling the advertiser not to repeat the offending advert, but if the Commission continues to use its powers to review licences following advertising breaches, a much wider range of sanctions are available for non-compliance by gambling operators. The CMA, by contrast, does have a remit to take court action in relation to infringements of consumer protection laws and can obtain an order for a business to compensate affected customers or pay equivalent amounts to charity.

The CMA indicates in its Consumer Protection: Enforcement Guidance document that before taking court action it will normally attempt to stop and prevent repetition of what it considers to be an infringement by consulting with the business. The CMA also highlights that it is committed to proportionate regulation, this statement being backed up by the fact that only twelve consumer enforcement cases over the past decade have led to court orders, with these cases relating to issues such as illegal pyramid schemes and fraudulent sales practices, or businesses refusing to make the requested changes to their practices. A recent area of consumer enforcement work by the CMA was an investigation into retailers involved in publishing fake positive customer reviews and suppressing negative reviews. One retailer, which had instructed staﬀ members to only approve reviews of four stars and above, agreed to give undertakings to the CMA which included that it would publish all genuine reviews. Another retailer, which had arranged for third parties to write positive reviews, again reached agreement with the CMA to give undertakings not to continue this practice. The case against both retailers was closed following the relevant undertakings being given.

– Play-through conditions attached to sign up bonuses, requiring customers to complete extensive wagering requirements before being allowed to withdraw money;

In light of the guidance document published by the CMA and the outcome of this recent consumer enforcement action, it seems likely that the cases against the gambling operators will be resolved in a similar way, with them giving undertakings not to continue or repeat the concerning type of promotional activity, rather than any formal court action taking place.

CMA action The issues which led to the CMA action against operators related to:

–

Inadequate or unclear information about the restrictions and conditions that apply to promotions before sign-up; and

CGiMAGAZINE.COM

–

Civil powers to stop infringements under the Consumer Protection from Unfair Trading Regulations 2008 (CPRs) and Consumer Rights Act 2015 (CRA), by seeking an enforcement order from the courts.

–

Criminal powers to prosecute businesses that engage in the most unfair commercial practice under the CPRs.

–

The power under Schedule 3 of the CRA to seek an injunction to stop businesses using unfair terms.

ASA action Of the 38 adverts by gambling operators which were subject to rulings by the ASA in the past year, 30 raised issues relating to

REGULATORY ::

misleading advertising and/or failure to make significant conditions of a promotion clear. It appears from these numbers that adverts giving misleading information about free bets and promotions have been a particular issue, but in fact a very similar proportion – around 80%- of all the ASA’s rulings in the past year looked at issues relating to misleading advertising. These statistics can be read in two ways – is it that advertisers are generally able to keep their adverts from being offensive or harmful but struggle to make conditions of their offers clear, or is it that consumers in the UK are more likely to complain about being misled or cheated than they are about being offended or harmed? Whichever is the case, the focus on misleading advertising by the ASA mirrors that by the Commission on the “fair and open” licensing objective and the CMA’s enforcement action. The key CAP and BCAP code provisions in this area are: 3.1 - Advertisements must not materially mislead or be likely to do so. 3.2 - Advertisements must not mislead consumers by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner. 3.10 - Advertisements must state significant limitations and qualifications. Qualifications may clarify but must not contradict the claims that they qualify. Within the last year, the following types of conditions were all held by the ASA on at least one occasion to be significant enough to appear in the advert itself as well as the T&Cs: -

Play-through requirements e.g. that a bonus must be wagered 20 times before winnings may be withdrawn;

Limitations on the type of bet that are eligible for an oﬀer or bonus, including that they must be at certain odds, at the starting price rather than current price, or that they must be accumulator bets; -

Limitations on when customers can use a “cash out” feature, when the advert implies they can use it whenever they want to;

The fact that a bonus takes the form of free bets or spins rather than cash, where the advert indirectly implies the bonus may be withdrawn immediately in cash;

- Maximum free bet stake rules, including a case where bets using bonus funds were void if they exceeded 30% of the bonus amount; -

Limitations on the time an oﬀer will run for including expiry dates and time of day restrictions;

Where winnings from a promotional bet are paid as free bets rather than cash.

The Lottoland advert, which ultimately led to the voluntary

settlement with the Commission, was a radio advert which the ASA considered misleadingly implied that customers would be participating in a lottery rather than betting on the outcome of a lottery. Whilst the term “bet” was used in the voiceover, the initial statements that “at Lottoland the EuroMillions still costs just £2” and “with Lottoland you can win the big jackpot for less” created a misleading impression. This is a somewhat diﬀerent complaint to those against other operators as it did not relate to bonus terms, however it did deal with the failure to make key information clear to customers. The overall takeaway is that any matter which a customer would reasonably expect to be aware of before making a decision whether to take part in a gambling opportunity must be displayed in the advert itself, rather than in linked T&Cs.

Safety in numbers? Most gambling operators, particularly those licensed by the Commission, have broadly similar conditions attaching to free bet and bonus promotions. For example, extensive wagering requirements are commonplace as is the ability to void bets or refuse to pay out winnings if irregular betting patterns are discovered. It is unlikely that those operators currently subject to CMA action were doing anything particularly out of the ordinary. Once the results of the CMA action are made public, operators will have certainty as to the changes that need to be made, but in the meantime it is certainly worth reviewing terms with a view to heading off further action. In terms of advertising, again given the volume of ASA rulings in this area it is not uncommon for a gambling operator to fail to make all of what the ASA considers to be “significant conditions” clear in every advert. Despite these failings not being uncommon, immediate action to rectify the issues in future adverts is essential. The reason BGO’s advertising failings led to a licence review was because it did not take prompt action to address the issues and prevent recurrence – the Commission continued to find breaches in BGO’s advertising for a number of months after it engaged with the operator on this issue. Whilst further action by the CMA cannot be ruled out (and it is turning its attention to unfair withdrawal policies next), if operators take prompt action to amend their bonus terms both now and once its rulings and the operators’ undertakings are made public, they may avoid similar action and potential investigation by the Commission. :: CGi

MELANIE ELLIS

Melanie Ellis is a senior associate in the gambling law team at Harris Hagan. After graduating from St Hilda's College, Oxford in 2003, Melanie trained as a barrister before joining Harris Hagan in 2005 and qualifying as a solicitor in 2008. Melanie has developed expertise in dealing with all aspects of gambling law advising major casino operators, online betting and gaming operators and start up companies. She has advised on establishing operations in the UK and in oﬀshore jurisdictions, on issues relating to advertising in the UK, on lotteries and prize competitions and 'due diligence' on the licensing aspects of corporate acquisitions. She regularly contributes to gaming law publications.

CGiMAGAZINE.COM

SELF-EXCLUSION ::

GAMSTOP: TURNING A VISION INTO REALITY A

fter many months having been spent discussing the intricacies of what could constitute a national online self-exclusion scheme, we are about to witness the emergence of GAMSTOP, the UK’s ﬁrst national online self-exclusion scheme.

Fiona Palmer GAMSTOP

What’s it all about? Self-exclusion is an important harm minimisation tool for those who wish to exercise greater control over their gambling, by enabling them to block themselves from accessing specific gambling activities. Currently, if an individual wishes to selfexclude entirely from gambling online, within the UK, they need to do so separately with each remote operator they might gamble with. In February 2015, the Gambling Commission introduced a new social responsibility licence code1 that would require all relevant remote licence holders to participate in the national multi-operator self-exclusion scheme. Without any such scheme being in existence, a new one would need to be set up, a note was included on the new licence code stating it would come into force one month after the Commission had notified all relevant licence holders of the establishment of a national online multioperator self-exclusion scheme. Turning the clock back to May 2014, the Gambling Commission set up a working group, involving representatives from remote licensed operators, to determine how a national online multi-operator self-exclusion scheme could work. A year later a briefing paper2 was issued providing a high-level overview of the proposed solution including reference to an impending consultation. While the consultation never materialised, in mid February 2016 the Commission wrote to all of its remote gambling operator licensees to inform them that although “many of you would prefer the Gambling Commission to manage the CGiMAGAZINE.COM

:: SELF-EXCLUSION

<< The primary purpose of GAMSTOP is to provide a single interface to enable consumers, resident within the UK, to self-exclude from all Gambling Commission remote licensed gambling operators. >> scheme […] we have concluded that the industry is best placed to lead and manage the ﬁnal scheme and DCMS agree”. The letter went on to say that “We are therefore pleased that the RGA has now agreed to take this work forward on behalf of the online sector and we will continue to liaise closely with them throughout the process”.

Back to the drawing board There is a world of diﬀerence between a national scheme being operated by a regulator, such as the Gambling Commission, which is the case in Spain and Denmark, and a private sector body such as the Remote Gambling Association (RGA). Whilst a number of technical issues are very similar, there are a whole range of issues such as legal, funding and governance that are not. Consequently, the RGA had to hit the ground running and appointed KPMG to undertake a thorough scoping study. A Steering Group was formed, comprising of RGA member operators and a decision was quickly made that a new corporate entity was required in order to run the scheme; this marked the incorporation of The National Online Self Exclusion Scheme Limited (NOSES Ltd). Following three months of intensive analysis by KPMG, the Steering Group approved the proposed corporate structure and accompanying business case; all eyes were then focused on Phase 2 which would see the plans being turned into reality culminating in the selection of a key technology vendor. “Ping” versus “Push” became a hot topic of discussion regarding the underlying technology solution for the scheme. o

“Ping”: Operators ‘ping’ the GAMSTOP database by submitting customer details to GAMSTOP and GAMSTOP return a result as to whether or not that customer is on the self-exclusion register.

“Push”: The GAMSTOP database ‘pushes’ out the full list of GAMSTOP customers (registered self-excluders) to all Operators on a periodic basis and it is the responsibility of Operators to perform the record matching locally/themselves.

With the General Data Protection Regulations looming on the horizon, following expert advice, it was agreed the “Ping” approach was the most appropriate option; Operators would be

CGiMAGAZINE.COM

required to send their customer details to screen against the national online self-exclusion scheme database. The proposed structure for the solution was put out to tender, with prospective technology vendors putting forward their recommended designs for delivering the scheme. A vendor selection panel was set up and an intense 6-week period ensued culminating in the appointment of a preferred technology vendor; this also marked the conclusion of KPMG’s phase of work. Callcredit were appointed, in April 2017, to carry out an initial scoping phase of work to delve into the design details of the solution and provide the necessary technical documentation to enable operators to commence preparation for integration with the scheme. In parallel to the focus on technology solution, it became increasingly apparent that the national online self-exclusion scheme needed its own meaningful identity. The brand would need to resonate with consumers and operators alike, as such it would need to be easily recognisable. With the help of WDC Creative3 GAMSTOP was launched as the trading name for the scheme in June 2016.

How will it work? The primary purpose of GAMSTOP is to provide a single interface to enable consumers, resident within the UK, to self-exclude from all Gambling Commission remote licensed gambling operators. From a consumer perspective, GAMSTOP will be a single interface online where they can block themselves for a minimum duration, from all Gambling Commission licensed UK facing online gambling sites. Consumers will be required to register with GAMSTOP and have their registered details verified. Once verified they will be able to select a minimum duration, ranging from 6 months to 5 years which they wish to be excluded from all Gambling Commission licensed remote operators; during the selected duration the consumer will not be able to remove the self-exclusion. Upon confirmation of the self-exclusion, the consumer’s details will be added to the central GAMSTOP database. The self-exclusion will be active for at least the minimum duration selected by the consumer, after which point it will remain active until either the individual takes positive action to remove it or the duration of the published data retention period. Relevant licensed operators will be required to integrate with the scheme, via an API, and perform real time checks to make

SELF-EXCLUSION ::

sure their customers are not registered with GAMSTOP. Checks will need to be performed upon each customer login as well as new customer registrations to ensure self-excluded consumers are not able to access gambling activities. GAMSTOP will return one of three responses to the operator, advising that the individual is either registered on the database with an active selfexclusion, registered on the database with an expired self-exclusion that has been successfully removed by the individual, or has never been registered on the database. Operators will be required to sign up to join GAMSTOP and will be expected to pay an annual fee, in advance, for the service. The fees payable will be fair and proportionate to the size of operation and will be based on revenue bands, comparable to the Gambling Commission fee structure.

Dispelling the myths Operators are currently required to offer their customers the ability to self-exclude directly from their own sites; GAMSTOP will not be replacing operators’ existing self-exclusion schemes, the national scheme will be provided in addition to existing responsible gambling tools currently available to consumers online. Operators will not be expected to transfer details of their own self-excluded customers to GAMSTOP for the purpose of being added to the database. It is important that consumers are aware of the significance of the action they are taking therefore are required to register directly with GAMSTOP. Due to the RGA being tasked with setting up and running GAMSTOP there could be a misconception that the scheme will only be available to members of the RGA; GAMSTOP will not solely be available to RGA members, it is a national scheme that will be available to all c250 remote licensed operators; once the scheme is live to consumers it will become a licence requirement for remote licensed operators to sign up and be involved in it. Consumers will not be able to select which operators they exclude from via GAMSTOP; an exclusion applied via GAMSTOP will automatically apply to all Gambling Commission remote licensed operators. Likewise, consumers will not be able to select individual products to be excluded; the exclusion will apply to all gambling products offered.

Next steps With the design of the scheme nearing completion, the focus will

turn to the build and roll out of the technical solution. This is a key stage in the project and will see extensive testing of the solution along with a staged onboarding of all remote licensed operators in advance of the solution being made available to consumers. Once all operators, who have signed up to the scheme, are successfully integrated, GAMSTOP will be switched on for consumers to use and the new licence requirement will come into force. Alongside the technology vendor, another key external provider for GAMSTOP will be a contact centre. The process is underway to select a suitable contact centre solution, which will enable support to be readily available to consumers who encounter difficulties with GAMSTOP. The working timetable is for the scheme to be live for consumers by 2018, subject to no significant legal or technical barriers being encountered during the final phase of work. :: CGi References 1 http://www.gamblingcommission.gov.uk/PDF/consultations/LCCPsummary-of-key-changes-2015.pdf 2 http://www.gamblingcommission.gov.uk/PDF/Briefing-note-on-thenational-online-self-exclusion-scheme.pdf 3 wdc-creative.com

FIONA PALMER

Fiona Palmer has worked in the online gambling industry for the past 8 years and is currently leading the project on behalf of the Remote Gambling Association to set up GAMSTOP, the UK’s national online self-exclusion scheme. Prior to joining the RGA in March 2017 she was Head of Compliance and Social Responsibility at Sky Betting & Gaming. She is passionate about social responsibility and through her collaborative approach is a key member of a number of working groups in the industry.

CGiMAGAZINE.COM

24th / 25th October 2017 Johannesburg, South Africa

Content That Looks Beyond the Horizon The Gaming Africa agenda has been designed specifically with operators and regulators in mind, providing a line-up of expert speakers who will help you to uncover the opportunities that lie ahead... • Africa’s Growing Economy – what influence will this have on the gaming industry? • Payments: is Cash Still King? – Can we learn from the success of Kenya? • Does Being Responsible Pay? – How has this worked in other jurisdictions? • Anti-Money Laundering and Sports Integrity – discover key solutions to one of the largest inhibitors of progress. · Moving Forward with External Investment – What is the domestic view on foreign partnerships? • The Best Ways to Manage Public Relations – How can the gaming industry better communicate the social benefits of a thriving, sustainable market? • Regional Roundtables: East, West and South Africa – Share ideas, discuss challenges and opportunities with industry professionals. • Training for a Better Future – The Totally Gaming Academy master classes will cover online, land based, sports betting and affiliate sectors

For more information and to register for the inaugural Gaming Africa visit: www.gamingafrica.za.com

JERSEY ::

GOOD INTENTIONS AND OTHER REFLECTIONS ON THE ROAD: GAMBLING AS A FORM OF CHARITABLE FUND RAISING W

ithout wanting to sound like a corny joke one ﬁnds in cheap Christmas Crackers, consider this: When is a lottery not a lottery? And when is a lottery not really gambling? The answer it seems is highly dependent upon perspective. As a regulator, I am most often involved with the licensing and prudential supervision of commercial gambling companies. This brings its own complications, but in general terms, everyone knows the rules and what is expected of them – or ought to. Discussion can take place around reporting requirements and changes to game operation, but both parties, regulator and licensee, understand the rules and speak the same often dry and technical language. The same is not always true of social and charitable gambling.

Dr. Jason Lane Chief Executive Jersey Gambling Commission

Regulation of the third sector can be diﬃcult; it can also quickly become disproportionately complicated and time consuming, in part because you are dealing with well intensioned amateurs. That’s not meant to be in any way disparaging, it’s simply an expression of fact. The overwhelming number of people who freely give their time and energy to raise funds for a myriad of good causes generally don’t have a clue about what the gambling law means and how they should comply with it. And to be fair: why should they? Or, from a regulator’s point of view: how can they? I’ll come back to learning to communicuate later on. It’s important at this point to make clear that the gambling laws in Jersey are completely separate and distinct to those in the UK. Many charities in the UK can make use of External Lottery Managers (ELMs) to navigate the sometimes nebulous (to the uninitiated) rules and regulations around charitable gambling and while I have sometimes been more sceptical of their value in the past because of the charges that they can make, I now have a better CGiMAGAZINE.COM

:: JERSEY

appreciation of what they can oﬀer and the eﬃciencies that they can bring when done well. Of course charities can easily do it themselves – and in Jersey they have to as ELMs are not allowed – but if time is a commodity in demand and risk mitigation a factor of concern, I do now see their value. So that’s my confession over.

Regulatory Framework The regulation of charitable gambling in Jersey is administered through the Gambling (Charitable and Membership Gambling Services) (Jersey) Regulations (2012), a piece of secondary legislation sitting under the Gambling (Jersey) Law (2012). The Law provides the legislative authority for the Regulations and these Regulations set out the ‘do’s’ and ‘don’ts’ for the sector. Importantly, while the Law deals with commercial operations through a civil licensing regime, charitable gambling remains subject to criminal law. Does this appear a tad odd? The threat of severe penalties potentially applied after criminal conviction and to a charity? On first glance it may seem contradictory, but the criminal regime serves as a form of protection for the sector given the higher levels of evidential test required for conviction and because the process is governed by the judicial system and not the Commission. Thus while the Commission can impose civil penalties and other sanctions upon its commercial licensees, it cannot prosecute a criminal case itself, but rather prepares a file that is then considered by Her Majesty’s Attorney-General for Jersey, who has sole responsibility for deciding whether to prosecute or not. This doesn’t mean the Commission lacks influence over the conduct of charitable gambling. Of course there have been issues, occasions when the Commission has intervened to correct matters before they have gone significantly awry, but it does mean that the Commission is spared the otherwise invidious position of punishing well intentioned wrong-doing, while still having the power to prevent matters getting out of hand and, in very rare cases, issuing formal Directions preventing individuals from taking responsible positions for fundraising in the future. One difficutly in deciding how best to regulate third sector gambling was the judgement call about where to set the bar, above which regulatory oversight would be necessary. Most people would agree that the Commission’s public protection role is probably best served by concentrating on the commercial sector where large sums can be wagered, won and lost. And it’s also true that the majority of gambling fundraising is very low level. However, another important distinction between Jersey and the UK is that we do not place a cap on what charities can offer by way of a prize fund. For a number of years, one charity has held an annual lottery with a top prize of one million pounds and substantial other prizes. That is clearly of a level meriting inspection and supervision, given it surpasses what the government sponsored Channel Islands Lottery has traditionally offered. Also the odds of winning are somewhat better than average lotteries given a population of just over 100,000 people and only 6000 tickets issued. Ticket price also merits consideration and at a not unsubstantial £300 each, the Commission must balance its duty to assist good causes with its other statutory responsibilities, not least insofar as problem gambling is concerned. So one size cannot and does not fit all. Modernisation of Jersey’s gambling law offered the

CGiMAGAZINE.COM

JERSEY ::

Commission the ability to make informed professional choices based on experience and regulatory good practice. Prior to this, charitable gambling was meshed in an intensely bureaucratic system largely driven by revenue collection and an almost paranoid view that gambling should be closely supervised at all levels. Enter the new approach, one based on risk assessment and tiered into three levels. The first caters for one-off, low value events. These are essentially self-regulated so long as the prize fund is below £1500 and the charity, club or society undertakes no more than three events in a calendar year. The next level up captures charities wishing to offer gambling more regularly, or offer prizes up to £12,000 per event or up to £30,000 per calendar year. This requires a registration which is simply a record of what the club or society is planning to do and when and where they wish to do it. The third level introduces more stringent regulation and covers gambling where the prize fund is in excess of £12,000 per event or £30,000 in a calendar year, this requires a permit from the Commission. A permit is a licence by any other name, conditions are placed on the charity to a level where professional delivery of the service is expected and sanctions can and are put in place should anything go wrong. So, so far so good? Yes. Mostly. Except that life is never that simple. One of many good things that comes from a sense of community is that people often want to help others, particularly charities, and fund raising is a great example of that. Sometimes, however, enthusiasm knows no bounds and the law isn’t even offered a passenger seat in their fundraising vehical until the Commission flags it down. This unofficial fundraising is mostly low level in respect of income and prize money, but can represent significant risk of being conducted in a manner that is neither fair nor socially responsible: two of three Guiding Principles that the Commission is bound by statute to observe. This is where the application of criminal law becomes rather more helpful insofar as the three criminal tests are concerned, namely the evidential, proportionality and public interest tests. There have been a number of cases where evidentially, the gambling law may have been broken, but which thankfully the proportionality and public interest tests have been applied to prevent what most people would otherwise consider a harsh prosecution. So why does this happen? The regulations for charitable gambling are (relatively) straightforward: aren’t they? Partly it comes down to what I mentioned at the beginning of this article, namely perception. Many people seem to think that ‘gambling’ is limited to casino games, poker or sports betting. It’s something done by ‘other people’ and not something they often think about. The issue of lotteries is even more complicated, with many people thinking that they don’t really count as gambling. Even those who acknowledge the connection, often protest: ‘but we aren’t going to have a lottery, we just want to hold a raffle’. My office recognises perception as being one of larger risks combined with a mixture of other regulatory challenges including, but not necessarily limited to: • • • • • •

Ignorance of the Law and regulatory framework; Inexperience or lack of understanding of the product; Regulatory outreach, or more likely the lack of it; Lack of planning and poor record keeping Unco-operative mindset; and Use of children.

CGiMAGAZINE.COM

:: JERSEY

This latter issue – kids and gambling – is a fraught area to regulate. Jersey law does not prevent gambling by children unless it is for private (commerical) gain or through membership or private card clubs. The law allows the Commission to place conditions on commercial operators to ensure they do not offer their services to children , but this doesn’t extend to charities, clubs and societies. In one respect, that makes good sense. Parents should have the freedom to introduce their children to gambling and explain the pitfalls as well as the recreational enjoyment, and the Commission does not want to swoop spectre like into a domestic or social setting, renting the air with ‘Thou Shalt Not’ edicts. On the other hand, as well as it’s Guiding Principles, the Gambling Commission (Jersey) Law Article 9 mandates that: (1) The Commission must take the action it considers appropriate to – (a) protect children and other vulnerable persons from addiction to gambling and from other forms of harm associated with gambling. This requires a judgement call from Commission staff, working together with those involved in charitable fundraising to ensure appropriate access is given for children to participate, such as in school fete ‘guess the weight’ type events, but not allowing children to organise and distribute their own lotteries themselves. Making that distinction clear, however, is difficult and getting universal buyin probably impossible, even within a small jurisdiction like Jersey. I added outreach to the list of regulatory challenges, pretty much in the spirit of ‘physican heal thyself’. Communication is key to successful regulation, but pitching it at the right level is an art in itself. By way of example, I have stood in front of an audience explaining the do’s and don’ts of charitable fundraising, brandishing in my hand a sparkly new Policy to guide and help them in all their gambling-themed endeavours. Having concluded my perhaps slightly over long lecture, I quickly found myself fending questions on all the topics I had just covered. It was if I had never said a word! There’s a cartoon with the caption ‘What you say and what they hear’ and looking at my sparkly new Policy, its pages full of the same dry and technical language I mentioned earlier, it struck me we might be setting these people up to fail. And remember failure in this sense attracts criminal sanctions. This is not about levels of intelligence. I believe a regulator is duty bound to question itself and not set comprehension tests for a body of well meaning people who just want to run a lottery, or organise a bingo night to benefit a cause they are passionate about. And this was after we had redrafted the entire regulatory framework so that it would fall into what were meant to be three, easy to understand categories. So we return to perception again and the constant need to remember that what is simple and clear to you because of its cozy familiarity, can be utterly incomprehensible to someone else. Realising that and marking the new Policy a fail, I returned to the drawing board, but then the drawing board and the regulator are very close friends. So where does this leave us? We think we know that regulation of the commercial sector is still where we need to concentrate our focus. We recognise that gambling is an important route for fundraising in the third sector. We will try and find a balance so that the public understands what we are doing and thinks it legitimate and proprtionate and finally, answering my

CGiMAGAZINE.COM

opening riddle: we will agree that a lottery is a lottery if the regulator has the wit to explain that it is in plain terms. :: CGi References 1 For those unfamiliar with Jersey, the Island is located in the Bay of St Malo to the northwest of France and is the largest of the Channel Islands. Jersey has given its allegiance to the Crown of England since 1204 and in return has received successive Royal Charters confirming local customs and civil liberties. Of particular importance to the Island has been the confirmation of its own judicial system and freedom from process of English courts and other important privileges, including fiscal autonomy. To that end, Jersey is not part of the UK or subject (without consent) to UK laws so that in matters of domestic competence, such as gambling regulation, the UK does not represent Jersey. 2 Article 4 of the Gambling Commission (Jersey) Law 2010 states: The Commission must, in the performance of all of its functions, have regard to the principles that any gambling services provided – (a) should be conducted responsibly and with safeguards necessary to protect children and vulnerable people; (b) should be regulated in accordance with generally accepted international standards to prevent fraud and money laundering, and should not be permitted to be a source of crime; and (c) should be verifiably fair to consumers of those services. 3 The Gambling (Jersey) Law, Article 16(2) states that ‘it is a condition of every licence that the gambling must not be advertised in any manner that is directed at children or that contravenes any provision of a code of practice that restricts advertising of commercial gambling in relation to children’. But this only applies to commercial operators. Likewise 20(1)(b): the restrictions as to involvement of children as customers of the licensee, as employees of the licensee, or in any other way in the provision of the licensee’s gambling service.

DR. JASON LANE

Dr Lane is Chief Executive of the Jersey Gambling Commission since its inception in 2010 and was previously a senior civil servant. A past Chairman of the Gaming Regulators European Forum, he is also an active member of the International Association of Gaming Regulators and the International Masters of Gaming Law. As well as his executive role, Dr Lane is also Deputy Chairman of the Jersey Police Authority, a statutory body responsible for the eﬃciency and eﬀectiveness of the States of Jersey Police.

Totally T otally Gaming

SUMMIT

Totally Gaming Summit | 2017 31 October - 2 November Tallinn, Estonia

Ƥ www.TotallyGamingSummit.com

LIVE CASINO ::

A CONVINCING CASE FOR CONVERGENCE A

Helen Hedgeland UK Managing Director Evolution Gaming

ltogether the Dual Play concept makes a very convincing case for convergence — a win-win for operators and players. The whole point of convergence, after all, is that it results in something new and different; something that blends the best of previous traditions and/or technologies, and makes life easier or more enjoyable in some way, or preferably both! James Stern, Director of Business Development & Land-based Sales at Evolution Gaming, explains how the compelling, high-quality player experience delivered by Dual Play is convincing operators and players alike. The convergence of online and land-based casino play is very much in the news and on the agenda of land-based casinos across Europe and beyond. Indeed, just a few weeks ago the latest in a line of bespoke Evolution Dual Play Roulette tables went live on the gaming floor of Grand Casino, Bucharest. Several more are set to launch over the coming months. Installed around a Cammegh wheel on the main gaming floor of the casino, the bespoke Dual Play rig at Grand Casino provides a unique and compelling live game feed that enables players online to play alongside customers seated at the actual in-venue table. Grand Casino, on the ground floor of the Marriott Hotel in the historic Romanian capital, is part of a luxury resort that blends gambling, shopping, sports and spa clubs, gastronomy and more. For anyone looking for an exclusive playground full of high-class services, it’s a must-visit destination. But now players can get a taste of what it’s like to play at a real table there, just by selecting the ‘Live at Grand Casino’ Roulette game on their desktops, tablets and smartphones. Dual Play Roulette offers players the ability to play while CGiMAGAZINE.COM

physically present in the actual casino or to play from virtually anywhere in the world. It also brings together the various elements of the casino and the whole resort, as players can play at the actual physical table while seated there, then continue playing, should they wish to, on their own devices from one of the bars or restaurants on-site, or from their hotel rooms. None of this is completely new, however. The Grand Casino Dual Play Roulette table is simply the latest bespoke variant of a product ﬁrst launched by Evolution at Dragonara Casino in Malta in November 2015. Like all our Dual Play deployments, the Dual Play Roulette table at Dragonara Casino uses a similar camera and sound installation to that found at the Live Roulette tables at Evolution’s main live casino studios. Land-based live casino has been a key focus area for Evolution since 2013. Drawing on experience gained from both our central live studios and our on-premise live studios in Spain, Italy and Belgium, Dual Play Roulette deployments are the essence of landbased and online convergence. They draw online players right into the excitement of the real casino; they allow on-premise customers to stay connected to the live game action – even when they are in a casino’s restaurant or bar; and they open up highly scalable multiplayer revenue potential from a greatly extended audience. However, Dual Play is also a break with tradition, and one that some land-based casinos may be a little nervous about. That wasn’t the case at Dragonara, however. Franco Degabriele, Business Development Director of Dragonara Gaming Limited, stated at the time: “Dragonara is

CGiMAGAZINE.COM

synonymous to tradition with its rich history, but also very forward looking and innovative. Through this service we can now oﬀer our players an innovative and diﬀerent service that is unique in many ways. Dual Play is a great way for customers to join in the live game action whenever they like, and to play online with dealers they are familiar with from our casino. As well as a loyal local clientele we have a huge number of players who visit us while on holiday. Now they can continue to take their place at the Roulette table in their favourite casino, even after departing Malta and when they are thousands of miles away.” The Evolution live studio experience and know-how that had been so important to Dragonara was soon harnessed by other land-based venues looking to implement a high-quality, sharply focused convergence strategy. On the back of what had been achieved in Malta, Evolution Dual Play Roulette was subsequently selected by two of London’s best-known casinos: The Ritz Club and The Hippodrome Casino. On top of this, some very big brands indeed — brands that operate in both the land-based and online worlds — are set to follow with Evolution Dual Play Roulette installations in the coming months. A large part of the attraction for any land-based casino brand looking to maximum both its customer base and the appeal of its brand is that Dual Play Roulette can be deployed as a B2C solution, a B2B solution, or both. In a B2C deployment the Dual Play table is available exclusively as a dual on-premise/online table for the host casino’s own customers. In a B2B deployment, the host casino’s on-premise table can

LIVE CASINO ::

<< Like live casino generally, the convergence market has seen a great many new entrants. This gamut of suppliers includes both existing live casino providers and new suppliers... >> be syndicated as an online service and offered to an even wider global audience of players through the websites of other Evolution licensees. Predictably, land-based and online casino convergence is becoming a busy marketplace and there is plenty of choice out there for land-based operators. Like live casino generally, the convergence market has seen a great many new entrants. This gamut of suppliers includes both existing live casino providers and new suppliers. However, in our long experience, it is quality that ultimately convinces and wins over players, sustains the casino-player relationship, and underpins long-term loyalty. Just as we do with our core Live Casino product, we aim to differentiate ourselves by offering our customers a premium product — not an off-the-shelf, one-size-fits-all answer, but a bespoke, uniquely customised installation for each operator. Importantly, we work closely with the operator’s teams to understand what they are looking to create and, critically, to understand their brand and their player base. The aim always is to create a high-quality, unique player experience that is totally ‘on brand’ for the operator and totally relevant and convincing for their players. With Evolution Dual Play Roulette, the operator can choose the number of cameras, the camera angles and the camera and shot sequences. The overall rig design approach is flexible too. For example, at Dragonara there is a larger rig with overhead/over-table elements that are immediately obvious to casino visitors approaching the Dual Play Roulette table area. This is because Dragonara wanted to create a studio feel that would catch the eye and create a bit of a buzz with players. At The Ritz Club, the opposite is the case: a very discrete and unobtrusive rig design was preferred by the customer to suit the needs of their clientele. Whichever approach is chosen, in all instances the presence of cameras at the table — a clear enough signal that the table is streaming the games live — does little to distract or put off players. In fact, in many cases, the cameras and the hi-tech nature of the table set-up seems to attract players. Even so, licensees have full control, with everything customisable right down to how much or how little is shown in the close-up shots of the live game action. For example, at The Hippodrome Casino, initially the camera angles revealed only the hands of players as they placed their chips at the actual Dual Play table. However, based on feedback

to date and the attitude of The Hippodrome’s player base, these camera shots have now been raised to capture a little more of the fun and action at the table. Now, it’s not unusual for online players joining the game on their desktops, tablets or smartphones to witness the occasional ‘fist pump’ as a win at the in-venue table is celebrated. The Hippodrome Casino has been successful in creating a certain vibe away from the table, too. The live game feed is shown on large screens in the upstairs bar, allowing in-venue players to relax with a drink while continuing to place bets at the Dual Play Roulette table on a smartphone or tablet, or just keep an eye on the action or monitor winning number patterns. As our first Dual Play Roulette partner, Dragonara Casino in Malta has achieved great success not only with their own players but with the B2B potential of their Dual Play solution. Today, a significant number of Evolution’s network of licensees offer ‘Live from Dragonara’ as an additional table choice in their own live casinos. Players are instantly attracted to the fact that they can play at a real table in a real casino. That adds an additional level of authenticity and trust to the online gaming experience — and when players see the high quality of the game feed, the great UI, and the consistent player experience across multiple devices… yes, they are thoroughly convinced. I should mention also that some traditional land-based players also prefer playing at a Dual Play table when they are online. That’s because when the physical Dual Play table is busy in the land-based casino, the game is a little slower than our purely studio-based online Live Roulette games. Some traditional players prefer this more relaxed pace, with a little more time afforded to them for placing their complex betting patterns, and with less risk of bets closing before all their chips are placed. The fact is, a high-quality convergence solution such as Dual Play Roulette can work on so many levels for a land-based casino operator. Land-based casinos can use Dual Play Roulette, most obviously, to extend the service they offer existing in-venue players — both when those players are in the venue and away from it. They can use it to attract new players to their online offering — players who are familiar with the brand and relish the experience of playing at that brand’s tables, but who may not have visited the actual venue. And they can also use it as a B2B solution and source of new

CGiMAGAZINE.COM

:: LIVE CASINO

revenue by allowing other Evolution licensees to include the live Dual Play feed in their own line-up of Live Roulette tables. In the coming weeks and months, we expect to announce additional Dual Play deals in different jurisdictions, which will allow our licensees’ players to select from a number of land-based casinos in different territories and in different languages. Dual Play Roulette is very much a complementary product to our live studio solutions, allowing operators to provide wider choice for an increasingly diverse and demanding player base. It should also be stated again that land-based and online casino convergence solutions are not limited to Dual Play Roulette tables, though a Dual Play table is the ideal entry point to the convergence journey. So what other convergence solutions can a land-based casino consider deploying? A land-based private studio or VIP Salle Privée can be a great idea for a land-based casino with a strong focus on VIPs. The landbased casinos can open such salles on demand and stream to their patrons, wherever they may be, at whatever time, which is arguably the best example yet of an online casino service tailored to individual player needs. The whole offering mirrors the exclusive experience of a visit to a Salle Privée in an actual land-based casino. VIPs get the very best in casino interior design and service in an exclusive and private room; they have their own private point of entry and a dedicated team serving them; they have their own private chat facility, and the stakes as high as they want within the limits set by the casino and the jurisdiction. In all talk of convergence, though, we must never lose sight of what convergence actually means. Piecing together various technical and non-technical definitions that I found, I would

CGiMAGAZINE.COM

deﬁne it as: “The coming together of distinct and separate factors or phenomenon (which can include technologies or traditions or both), to create something diﬀerent or altogether new.” The history of converging technologies and traditions shows us that convergence has the potential to create something every bit as dominant as the original component parts — and potentially with greater mainstream appeal to boot. Following that logic, one could say that the convergence of land-based play and online play is creating a new kind of seamless play that will become the dominant factor in the land-based casino sector going forward. Of course, I’m just speculating. No one can predict the precise future of casino gaming, but land-based casinos must factor convergence into their own futures. Convergence is often a very natural and dynamic process that removes old barriers and gives people new choices and new ways of doing things. In our experience, casino table game players — both existing and new — are eager and enthusiastic adopters of convergence solutions, but with one proviso: they need to be thoroughly convinced by the quality of the gaming experience and service delivered to their screens. :: CGi HELEN HEDGELAND

Helen Hedgeland is Managing Director at Evolution UK, a role that sees her involved across the full gamut of live casino solution development and delivery for numerous leading global gaming brands and many specialist operators besides.

DATA SCIENCE ::

RECOMMENDATION SYSTEMS IN iGAMING: A HANDS-ON STRATEGY R

ecommendation systems are well known in the ecommerce industry, making the line “Customers who bought this item also bought” very famous. While names like Amazon, Booking.com and TripAdvisor jump to mind, recommendation systems are widely used in varied industries - movies (IMDB), music (iTunes/Google play) and even iGaming. Recommendations systems increase revenue through relevancy, improving the general customer experience, and cross/up sell.

Nimrod Ifrach Data Scientist Optimove

Collaborative fltering Recommendation systems is a wide and complex area of research, occupying brilliant minds across the world. One of the most common approaches, which we will outline here, is collaborative filtering. Collaborative filtering assumes that a customer will probably purchase (or subscribe, hear, play etc.) in a similar way to other customers like him/her. To use this approach, data must be collected about customers’ consumption behavior. On the following page is the most basic matrix of collaborative filtering. The matrix can contain data on all your customers, or on a smaller and more granular segment (i.e. Active users). It has two dimensions – customers (Rows), and Items (columns). The items can be any product or service you can recommend to your customers. The rating inside the matrix (between 1 to 5) represent the customers’ rankings for a specific item. The ranking can be derived from explicit data (rankings, reviews, likes etc.) and implicit data (which items the user has looked for, which items were bought, demographic attributes etc.).

CGiMAGAZINE.COM

:: DATA SCIENCE

(Empty cells denote unranked items)

After computing the matrix, we can use the existing information to conduct the following steps: 1. Identify similar users (“neighbors”). One of the common methods for calculating the similarity between users is the Pearson correlation. 2. Predict the rating for an item, based on similar users. Grouping similar users can be done using the KNN (K- Nearest Neighbors) algorithm. In our example, users A, B and C are similar in terms of ratings for items 2, 3 and 5, so we can call them neighbors. Users A and B gave an average ranking of 4.25 to item 1 and 1.5 to item 4. So, if we need to choose one item to recommend to user C, it will be item 1. There are two ways which collaborative ﬁltering can be used: •

•

User-User (row dimension): this method will answer the question which item should I recommend to user A? (The missing ranking will be derived by looking at the rows, like in the example above.)

Item-Item (columns dimension): this method will answer the question to which users should I recommend Item X? (The missing ranking will be derived by looking at the columns.)

simply because most iGaming companies don’t have this data, and the same goes for both casino and social casino. Obviously, iGaming requires a different approach. In iGaming, the two most important features that imply player preference are bet amount and number of bets. In addition, we can also consider the frequency for a specific game/event, or total session time (more relevant for social gaming). For example, in the past 6 months, a player played game A 300 times, game B 200 times and game C 20 times. If you want to be more sophisticated, you can combine two or more of these attributes. This information can help us understand which games the player liked more than others. To get reliable results, it’s crucial to normalize metrics for the different products. For instance, for bet amount $50 in sport should be treated differently from $50 in the casino, due to the different nature of the games and the different margins between the products.

Do It Yourself Congratulations, you’ve made it to the best part! In the next section, we will guide you with simple and easy way to implement a recommendation system for your customers.

Step 1 – Choose your sample Collaborative filtering suffers from 3 main problems – cold start (we have no information on new players), scalability (the user item matrix is enormous), and sparsity (many missing rankings). to address these issues, we will segment only active players who experienced several different games/events, and that make most of their bets in a specific product (e.g. casino, sport, Lottery etc.).

Step 2 – Calculate favorite game/event Using the attributes we mentioned earlier, the favorite game/event will be calculated for each player.

Step 3 – Compute co-occurrence matrix A co-occurrence matrix is very similar to the user-item matrix, but it has only one dimension. It looks like this:

Why is iGaming Diﬀerent? Before answering this question, let’s review a list of possible inputs for our recommendation system:

1. Demographic attributes single/married etc.

–

age,

gender,

country,

2. Purchase history – which items did the customer buy? Which items are in his Wishlist? Which items has the customer browsed?

3. User ranking – a speciﬁc rank for a product.

4. User reviews – “I highly recommend buying this product”.

5. Likes/Dislikes – adds on Facebook, songs in iTunes.

Most of these inputs cannot be used in the iGaming industry,

CGiMAGAZINE.COM

The matrix values reflect the number of customers who played two specific games. For example, 8,300 players played both gameid 1 and gameid 2. This table gives us the first intuition about which two games are associated. If you are familiar with association rules, you know that the percent of players who played each game has a high impact on the results. For example, what if a company gives all free bets only on gameid 1? Or what if a specific game is displayed in the center of the company’s

DATA SCIENCE ::

homepage, so almost every new player tries it? This type of cases can skew our results. Therefore, we will use the Jaccard Similarity to normalize the matrix. The process is very simple – each number in the matrix will be divided by the sum of players who played each game.

This is the normalized matrix:

The marked value was calculated as follows:

player’s favorite game is gameid 2, we will recommend gameid 5 since it holds the highest score – 0.22. Of course, this can be further developed by choosing the top 3 games we should recommend depending on tactical or strategic goals (pushing a stumbling game, cross selling to high margin games etc.) Step 5 – Additional dimensions This step is optional, and its main purpose is to show you that there are endless options in designing the system. Let’s say that we want to recommend gameid 5 to all players whose favorite game is gameid 2. What if some of those players already play gameid 5? To avoid redundant recommendations, we can create vectors for each user that show how many times he/she played each game. Based on this vector, we can create a second normalization by dividing the Jaccard similarity score by the number of times the player has played the recommended game. The more a player played the game, the lower the score the game gets. This way, games that the player hasn’t played before will rise to the top. There may be other parameters that you’d want to consider, such as seasonality in sports, game platform (a game might be very popular on mobile, but less so on the web) and side games in social casino.

Final Notes This is only the tip of the iceberg of recommendation systems. If you’d like to take a stab at implementing one for your iGaming business, the 5 steps speciﬁed here will allow you to do so in a fast and simple way that could get you some quick wins with your cross selling. Happy recommendations! :: CGi

It’s interesting to see that despite more players having played games 1 and 4, the highest score in the normalized matrix is for games 1 and 3. Below is a short MsSQL code for creating a co-occurrence matrix:

• •

Games table – transactional table that holds all gaming activity ActiveCasinoPlayers table – the population you want to build the system for

The output will be the number of players who played both games for each gameid combination (Number_of_Occurrences ﬁeld). Step 4 – Create recommendations Based on each player’s favorite game, you can now use the cooccurrence matrix to ﬁnd the best match. For example, if a

NIMROD IFRACH

Nimrod Ifrach, a data scientist at Optimove, has vast experience in working with data in the iGaming industry. He delights in turning statistical power into business value, always keeping the data at the center. Nimrod holds a BSc in Industrial Engineering and Management from the Tel Aviv University.

CGiMAGAZINE.COM

SPORTSBETTING ::

STAYING AHEAD IN THE TECHNOLOGY BATTLE i

Alessandro Fried Chariman BtoBet

Gaming is a business environment that is constantly changing and evolving as technologies improve and companies battle against each other to win a greater share of the pie. But how might the future online sportsbook look¬ from the customer perspective? And what should operators be looking to implement to stay ahead of the curve? For years, the gambling industry’s big suppliers had a power on the provision of both sportsbook and casino platforms. With few viable options on the market, licensees had limited opportunities when it came to differentiating their customerfacing offering. But a recent burgeoning of next generation providers, set a series of dangers and implications that operators can’t avoid to take into account to keep their business safe and long lasting. One of the main conditions for success for operators in the next 10 years will be their ability not only to keep track of players across a proliferation of devices and touchpoints – both online and in retail - but also to figure out how to effectively measure which of those are most effective at driving revenues. Let’s analyse 4 main key points to consider. 1. A new point of view of the customer - from 2D to 3D The range and depth of players’ data insight is set to proliferate over the next 10 years. There will be a greater range of digital services, platforms and devices than ever before capable of generating data insights from social media and messaging apps, location-based services, and online and mobile payment transactions. These multiple sources of data, combined with the everimproving technological capacity to reconcile data emanating from different devices, will enable an increasingly rich view of the

CGiMAGAZINE.COM

:: SPORTSBETTING

players, moving from today’s still largely two-dimensional view to one that is more fully formed and contextually relevant. As we say, we are moving from a two-dimensional world to a full 3D vision. What will be even more important for operators to understand will be how these multiple customer insights relate to the various touchpoints in the players’ journey, such as where they viewed a product including both the location and the type of device. It is already evident that the successful operators spend more time looking at the road ahead and less time looking at the rearview mirror. They will need to be agile and constantly learning, with the ability to recognise rapidly-changing trends and a willingness to adapt their businesses alongside them. This includes adopting promising new technologies and embracing the partnership opportunities and displaying organisational agility. Many bookmakers today approach learning as an exercise in analysing the past and making small, incremental changes. But this may no longer be enough. Instead, what will be needed is a forward-thinking view allied with a willingness to selectively test fresh and innovative concepts for engaging and interacting with both the suppliers and the player. 2. A diﬀerent approach for segmentation Traditional approaches to player segmentation already sits

CGiMAGAZINE.COM

uneasily with cross-platform players and in the next few years’ time to will almost certainly be no longer appropriate. Players will increasingly move between segments, and this fluidity means that the boundaries between segments will inevitably blur. The benefits of this evolution of segmentation will be obvious. Players are drawn to the heightened relevance and utility that more personalised offerings can deliver when the execution is spot on. Moreover, expectations in this area will only intensify. Segmentation models based on socio-demographic parameters and past search and betting patterns alone will prove to be ineffective. Instead, operators will need to take a far more sophisticated, creative approach to segmentation that is based on context rather than prescriptive one-size-fits-all models. But how far are we- as an industry – moving down this road? I’m not convinced the market today offers much by way of truly evolved software products. Up until a few years ago – when the proliferation of smartphones was more limited and a less-thanfully functioning mobile offering was more acceptable – this technology shortfall wasn’t so obvious Sports-betting and online gaming operators are now working within a far more competitive landscape generally, and licensees need to evolve at the same pace as the huge tech concerns in other sectors. In short, operators that don’t evolve will have no future in the space. Yet, the market is not offering many options in terms of

SPORTSBETTING ::

advanced technological software who can fulfil this growing need with regard to technology provision. To understand better the scenario, let’s analyse who are the platform providers today, what they offer and the problems facing an operator when it is comes to choosing the right platform to support their business. Many of the products offered today are generated by B2C operators that decide have opted to work in the B2B space in order to defray the high-investment costs and time-consuming effort involved in building and maintaining a tailored and bespoke platform.

3. A conflict on the go This is the theory. Yet, in practice, conflicts can soon arise over potential clients entrusting their user assets to a competitor. It is a fundamental issue, somewhat akin to sitting at a poker table where one of the players has access to all the other players’ hands. The player might not be stealing the pot – but he has a huge advantage. The operator-supplier will have a complete overview on the VIP players, on the statistics and on the marketing activities and the data. Moreover, the experience resides wholly in consumer-facing operations. No one within the organisation will necessarily have the needed knowledge of how to build scalable products for the needs of others and on how keep them updated in the same way as a specialised software provider can. Another cross-current comes from platform providers that have been attracted to the sector but which do not truly have the experience in product development. This could mean the foundation of the software won’t be built in a way that enables the system to evolve. In a very short time, it means that the technology runs the risk of becoming obsolete. To be a truly innovative and capable provider in the online gambling space you need a proper organisational structure with enabled R&D which focuses on providing updates and new versions of all the appropriate software. New releases should be anticipating the needs of the operators and ultimately that of the end users. This approach is common elsewhere in the tech universe – look at database servers and the degree to which they are anticipatory rather than reactive. Additionally, the manner in which platform providers acquire and manipulate data is a defining point of difference. Platforms must have the ability to interact seamlessly with all the new devices that will become available on the market, to handle ever more content and be able to collect in real-time data on the player activities through all the devices to improve the user experience.

4. The 360-degree view The innovation we are seeing today means that we are seeing the evolution of a complete experience for the player. And this process is organic and iterative, with each new player action providing even more data to be correctly analysed and monitored and eventually contributing to an improved gaming experience. Many large operators have come to understand the limits oﬀered by using in-house solutions. And the complexities of the technological future means the challenges are multiplying. Given this background, the only logical option is to outsource the technology. Partnerships will be sought with companies capable not only of providing the platform but also able to be a true

technical partner, able to ensure the core of their operations can reach the next level. An online gambling platform needs by definition to be open and able to integrate any possible content. Collaboration will be the name of the game in the future with operators seeking platform providers that will have the capability to aggregate all the available content while providing players with a seamless customer journey. Only provider with an open, independent and foresighted approach will be capable of managing this type of offering. And it is our contention that when the choice is framed in juts such a manner, the choices narrow down to a handful of potential options. Sometimes, travelling in different countries and taking part in lots of industry panels, I’m asked by operators “Are there nowadays new generation platform that are able to constantly update operators?” and I firmly believe that the concept of new generation can be equivocal. I’m convinced the market offers few really evolved software product. Few years ago the diffusion of smartphones was limited and low profile product were accepted, but now the market needs complex tools for the gaming. Real new generation platform are the ones able to offer the same level of service proposed by other sectors. Platform that are not able to evolve, have no future! Operators need increasingly data and information and can’t avoid to take into consideration that users are switching across different channels, smart watch, i-tv where they receive push notifications. In this sense, innovation is given by the possibility to provide a complete experience to the player, online, mobile and retail. On the other side, any action of the player becomes a data that- if correctly analised and monitored- can be transformed in a way to improve the gaming experience. To conclude, in the next 10 years, only platforms that can follow this direction can meet the needs of the operators and also of those licensees looking for outsourcing technology and platform. In this perspective, the platform must be an aggregator of content, must be flexible and allow operators to develop frontinterfaces, suitable for all type of devices. It must be able to integrate any kind of games and payments. Indeed, it must be able to be integrated with analysis instruments and must be opened to communicate with other products and environments. :: CGi

ALESSANDRO FRIED

Alessandro Fried is BtoBet’s Chairman after being CEO for 2 years. He is widely recognized as a visionary in the igaming sector and is frequently invited to speak at national and international igaming forums. He designed, developed and launched many successful products on the international market, and also obtained the ﬁrst European license in remote gaming from Malta Gaming Authority (MGA). He pursues the strategy in BtoBet of setting the new standards for the iGaming industry, refusing to settle for quick ﬁxes or half measures, striving to anticipate the future needs of our global audience, anticipating and meeting global industry needs.

CGiMAGAZINE.COM

14 - 15 NOVEMBEr, 2017 CONVENE, NEW YOrK CITY WWW.SPOrTSBETTINGCONFErENCE.COM

S P O

T S

B E T T I N G

U S A

A NEW PLAYING FIELD @SPOrTSBET_ USA

#SBUSA17

SPORTSBETTING ::

SPORTS VENTURING INTO THE UNKNOWN: A TALE OF DAILY FANTASY AND SAVING FACE IN AN UNFORGIVING INDUSTRY T

Bernard Marantelli Founder & CEO Colossus Bets

he summer of 2017 should have been the ‘summer of love’ for sports gaming startups and new entrants as it heralded the arrival of 22 months of continuous elite football - a FIFA World Cup ‘sandwiched’ between two EPL seasons of top-flight European football. And with World Cup-on-World Cup turnover set to grow at 50% to 100% depending on who you ask (vs. 2014), the future looked bright. Instead, the summer of 2017 seems to have turned into a reverse Cretaceous-Paleogene mass extinction, where the mammals (startups) die and the dinosaurs (incumbents) survive. Let’s have a quick run through some of the headlines... First, new entrant Sun Bets announced a £28m loss for their first full year. With revenue falling short of expectations, at a minimum, this amounts to a significant speed bump. Then, after a costly and unsuccessful season, US DFS betting heavyweight Fanduel announced their swift exit from the UK market. Despite a dignified exit notice to their customers, which left the door open for a potential return, their move probably marks the beginning of the end for DFS in Europe, if there was indeed ever a beginning. Many startups announced closing for good. Most of them you have never heard of but a few, like industry darlings Element Wave and BetUP, achieved enviable B2B partnerships over the last 1-2 years, their eventual failures serving sadly as a reminder that getting distribution in the form of partners is only half the battle. And still, there are many others that linger on life support, unable to gain any B2C or B2B traction but setting their funders back by a further £1-2m to get through the next 12-18 months, before inevitably closing. So what went wrong? Or, if you are ending up on the right side of this, what went right?

CGiMAGAZINE.COM

:: SPORTSBETTING

A perilous journey New sports gaming ventures in the UK are faced with a long list of hurdles so there is definitely plenty to go wrong. To start with the obvious, regulatory and AML requirements are a complex, ever-shifting beast that puts a severe onus on any company’s resources. Almost certainly no startup can fully stay on top of them so from the get-go there is something to keep you up at night. Then you have the resistance from incumbent operators, who naturally want to protect their hard-earned but precarious dominance, mostly achieved through expensive, race-to-thebottom marketing tactics (of questionable ROI). Then, there are the big new entrants like BetStars, Sun Bets, Playtech, Gamesys or even the more mature Betway and a raft of media and casino companies attempting to enter this space and cover every vertical. These companies have their own battles to fight to gain market share against the already established players but they still have a significant advantage over startups: big-bang marketing budgets even a well-funded startup cannot compete with. A forward-looking strategy would have these new entrants focus on product innovation and indeed be the keenest clients of innovative, agile startups but instead, they tend to treat their media clout and cross-sell capacity as their core USP. As a result,

CGiMAGAZINE.COM

a big part of the B2B market is largely off the startup target list. Beyond the usual regulatory and competitive pressures, 2015 and 2016 were also years of significant M&A activity. Betfair merged with Paddy Power, Ladbrokes with Coral and a host of others merged or got drawn into protracted merger discussions that did not bear fruit but hamstrung the business from integrating any third party provider. These mega mergers effectively took the operators involved off the table as B2B targets not only for the 6-18 month process of the merger but also for the next 12-24 months while they try to integrate their teams and technology. And for the operators that remain undistracted from such activity, startups are often disappointed to find that the new technology they offer is out of sync with their clients’ legacy systems and slow moving roadmaps, which prolong the business development cycle, sometimes until it is too late. Last but not least, the incentives of the decision makers are often misaligned with the high risk/high reward expectation that is inherent in partnering with a startup and taking on a new proposition to the market. Income security reigns supreme in this realm and this mentality will not be helped by recent high profile failures like BetUp. Those that decided to integrate it will not enjoy their next review and executives in other firms will use the example as

SPORTSBETTING ::

ample excuse to remain inactive. That is assuming they ever even contemplated giving a startup product the time of day. Now admittedly, the hurdles listed above are largely outside of a startup’s control. But let’s not conclude they are blameless for their ordeal. What I see as the biggest failing of startups in our space is attempting to solve problems that do not really exist. Almost invariably, all startups I come across these days include in their pitch decks the words ‘innovation’, ‘social’, ‘esport’ and ‘millennials’, the intended implication being that they hold the holy grails of modern product and marketing and that should be enough to lure traditional sportsbook operators (who startups claim don't understand these areas). Their innovation is usually a new game type of unknown appeal, which the startup claims will solve the millennial targeting issue, without much evidence in favour of their argument (or to the contrary). From DFS to esports and instant betting, everyone is laying their claim on the next generation of players and perhaps because it is the one thing we cannot disprove, they (we) all keep chanting the mantra.

A tale of Daily Fantasy Considering the case of DFS betting in Europe, the entrants, USA giants or European startups, are facing challenges similar to any new venture as outlined above but also unique to DFS. The main flaw of the game lies in its complexity, which causes the ecosystem of players to be imbalanced. The little fish get eaten alive early and therefore exit faster than in other forms of sports betting. Some argue incorrectly that simplified section processes (such as snake drafts and no salary cap) remove this imbalance, whereas in reality they can exacerbate it. No company with the right amount of firepower has shown willingness to take on the DFS challenge in Europe, and they can now feel vindicated at the sight of Fanduel running for the exit. And when Fanduel don’t fancy the market, who will? Let’s also remember that DraftKings, the other US heavyweight with European aspirations, largely closed their UK offices and operations last year, although their UK website still remains open for business. So who steps up to the plate next? Personally, I doubt that any executive at one of the big, established operators will invest the £10-20M required to give DFS a serious go in Europe. Because all such executives have been brought up and educated (for the most part) in ‘real’ betting, but also because they are simply not incentivised to take the risk, whether justified or not (income security will again win the day).

Saving face If we accept that making a DFS B2C play is problematic, B2B looks even more challenging. I perhaps know better than anyone, after spending four years trying to sell my product to operators, that it is plain hard. Many startups fail to ever get a contract and if you manage to get the contract, you are confronted with the reality of roadmaps, changing management and strategic focus, M&A, holidays, weddings… an endless list of possibilities to delay or derail your integration. The Bodugi case comes to mind with a William Hill contract for more than 12 months that never went live. I have several such skeletons in my own cupboard - in fact, ﬁve of the seven contracts I signed in 2014 never went live. But imagine you do go live, pop the champagne and now you are at your operator partner’s mercy to push your product. Why would

the operator want to push existing profitable clients to you? Again, think of BetUP, live on two serious operators for a season and then closing overnight. The pickings are slim even for firms that make it this far, and there is every possibility your partner will just use your product as an acquisition tool and then push your ‘recruits’ to their casino and sportsbook. Of course, B2B partnerships continue to form and some may even work. Dribble recently announced that they will become another social ‘feeder’ game on Sky. Sky are rapidly making a name for themselves as the home of games that ‘soft introduce’ audiences to betting - with a reported 1.5m weekly actives and 5m unique annuals on Sky Super6. Dribble may be one mammal destined to survive. So when do you stand a chance? My advice is to aim to be an expert at something. Build a product that has credence, that solves a problem or advances an existing product significantly. Don’t build a novelty that has no known demand. Then focus on acquisition and retention and make sure your product delivers on both counts. Talking about the vision behind your product may be more exciting than talking metrics, especially when you don't have metrics (yet), but if you can demonstrate your product is good for acquisition and retention, operators will eventually use it. Or you just might succeed in your B2C channel. We are seeing B2B acceptance rising with two of our products at the moment, first FreePlay and then Syndicates. But the process has been slow and expensive to wait out. Most start-ups simply don't have the cash to be patient. The ‘social’ betting resonance of Syndicates has exceeded our expectations, delivering especially competitive CPA and LTV results. Conversely, I am sure I went on record many times from 2010 to 2015 stating that social betting would largely fail. And it did. So what am I doing introducing a ‘social’ product in the minefield of startup success? Well, I do not view Syndicates as a social product per se. I just view it as another way to bet that is also very socially acceptable. Critically, there is an inherent incentive to share what you create and the ‘stories’ that come from your Syndicates, like cash-out offers and wins. The player wins by sharing and so do we as the product owner. So on the whole, I still believe that social betting products do not work, but I also believe that syndicate betting has opened up unique opportunities to rethink traditional acquisition routes, redefine the affiliate model and fudge the boundaries between product and marketing. The bottom line is that if you are looking for an efficient path to success, think product = marketing, give your players a product they want to share and talk about, and focus relentlessly on the boring metrics. And still be prepared that everything will be twice as slow and four times as expensive as your business case predicted. :: CGi

BERNARD MARANTELLI

With a background in background in ﬁnancial trading and professional gambling, Bernard is the Founder and CEO of Colossus Bets, award-winning provider of the world’s biggest sports jackpots and pioneer of Cash Out and ‘crowdfunded’ Syndicates.

CGiMAGAZINE.COM

DAILY FANTASY SPORTS ::

POKER AND DFS: FAST MOVER ADVANTAGE R

Jure Rejec Oulala Network

emember the online poker boom that occurred over a decade ago? Despite the declining market now being dominated by a single player, other industries’ early adopters still enjoy their small but fair share of

the market. The ever-changing nature of the (i)gaming industry requires quick action when a new product arrives, so the ﬁrst movers are often the winners. In 1998, Planet Poker emerged as the pioneer in online poker, but could not keep it up due to the rapidly growing business, so other poker operators quickly grabbed the opportunity. This suggests that being quick is actually even more important than simply being ﬁrst. Bear in mind that many poker rooms, which are still popular today, popped up before the actual boom in 2003 when Chris Moneymaker, who won his entry fee in an $86 online tournament, shockingly beat all contestants at the 2003 World Series of Poker and took home that year’s $2.5 million grand prize. Bwin Poker, Unibet, 888 Poker, TigerGaming Poker and iPoker Network (Titan Poker) were all established in 1999, while Party Poker and PokerStars joined the club in 2001. However, after the initial exponential growth, the global online poker industry, now vastly dominated by PokerStars (it controls around 70% of the market), has been on a steady decline for quite a few years now. Recent data shows that the gross gaming yield (GGY) declined by over $1bn between 2010 and 2014 and will drop to $3.22bn by the end of 2019. Interestingly enough, the next ''big thing'' in online gaming appeared before Black Friday on April 15th 2011. FanDuel, established nearly two years earlier in 2009, initially did not see much success with its new business concept, Daily Fantasy Sports (DFS). The growth actually began with the arrival of a strong CGiMAGAZINE.COM

:: DAILY FANTASY SPORTS

competitor, DraftKings, in 2012, and both companies soon found their place among the fastest growing companies in America. The advent of DFS caused yet another blow for the online poker industry as many poker players began to switch to playing DFS, which was due largely to the similar style of play (lobbies/leagues), and the prevailing element of skill and general popularity of sports. Despite the problems both DFS behemoths have been facing since 2015 (legal issues in different federal states, a failed merger), they continue to attract investors and, most importantly, enjoy continuous growth. While both companies control over 90% of the DFS market in North America, they have also expanded overseas. This seems like a logical strategy, a necessary step for the rise of DFS on a global scale, but the real question is whether DFS can threaten iGaming activities in other countries and continents, for instance in Europe. Some people claim that DFS became so popular in the US thanks to massive advertisement efforts and due to online poker losing its momentum. We can probably agree with that. They also like to point out that it attracted large numbers of new clients so fast simply because sports betting is illegal in most federal states. It is a harsh statement which does not take into consideration the fact that DFS is structurally different from any other type of traditional gambling activity and it has been the first to respond to the needs of the new generation. Also, according to Eilers Research survey from 2015, more than 90% of US clients say they would continue their DFS activity even if sports betting was made legal and accessible. What many people don't realise is that DFS is on solid ground to become successful globally because it feeds the needs of the millennial generation: it is a real skill game, it is a structurally social game (unlike other games such as online poker and casino), a game that is not played against the house as in the case of sports betting (DFS is a market place), and it allows you to be customercentred and generate loyalty. In a digital world where everything is becoming social, DFS is definitely a natural next step. Thus, can DFS become huge in Europe and cannibalise the sports betting industry? It certainly can in the long run, however in the next few years we should not perceive it as a substitution product but rather as a great opportunity. Because the house does not take players' money, they remain loyal, meaning that they come back regularly and for a long period of time (9.57 years on DFS according to the FSTA). DFS is not just a great retention tool, it is a way to attract customers that operators cannot reach

CGiMAGAZINE.COM

with their existing offers. In recent developments, it appears that iGaming operators in general are beginning to understand the benefits of offering DFS on their sites. This can be seen in Unibet’s launch of a new Daily Fantasy Sports platform (currently the operator is in Beta-Testing stage with the help of selected players). Further research shows that additional operators are also testing the DFS waters. Winamax and Vivarobet have already launched their DFS games while Paf has agreed to a partnership to enter the DFS market with Malta-licensed platform provider Scout Gaming Group. Even Paddy Power Betfair announced its entry into the DFS market in the US, with the acquisition of an early-stage operator, DRAFT. There are more big players in the game coming to terms with the idea that DFS might be the future as William Hill and Betclick are making plans to launch their own versions of DFS. Following closely behind is SkyBet with their CEO recently revealing that they are looking into opportunities to experiment with DFS, so that in the case that it ever becomes a growth area, they could quickly bring their knowledge and player base from the free games into DFS. As discussed recently at both East Coast Gaming Congress in Atlantic City and EL/WLA Sports Betting Seminar in Stockholm in May, casinos in the US as well as lotteries in Europe are also curious to see if DFS can be added to the mix because there is a common belief that millennials are disinterested in casino and lottery gambling. At Oulala, we correctly foresaw the evolution of our sector four years ago when we launched our – at the time – free-to-play daily fantasy football game, which now serves as a showcase to all our potential partners. We have had a clear vision of how DFS should evolve: as a properly regulated gaming product, separated from other gambling activities. The authorities in Malta were the first to foretell the impact of DFS’s potential in Europe, and the MGA was, in fact, the first regulator to acknowledge our needs. We are incredibly proud to be participating in the development of a licensing framework that regulates skill-based games, fantasy sports included. It was a highly significant step in the right direction, and our hope is that other European regulators will follow suit. At Oulala, the very first licensed B2B DFS provider, we are currently implementing a significant number of deals – some will go live at the beginning of the new football season – allowing Oulala to be the first DFS network on football. Any operators willing to benefit from this new opportunity can opt for our Turnkey, iFrame or API solutions. DFS is the next big thing arriving in the market and iGaming operators need to have access to this new market quickly because, as always, when a promising newcomer appears – like online poker – the fastest movers are often the winners. :: CGi JURE REJEC

Jure Rejec has been a sound advocate of the Daily Fantasy Sports sector for a few years now. Focused on B2B content marketing, he is an all-rounder for OulalaNetwork.com, the company that oﬀers an award-winning fantasy football platform for API/ iFrame integration as well as a complete turnkey solution.

THE

M OS T

E XC I T I N G

AFFIL IATE

EVEN T

O F

2 0 1 7

BERLIN AFFILIATE

CONFERENCE 1 - 4 NOVEMBER 2017, MESSE BERLIN

! es t a i l ffi a l l Free for a www.BerlinAffiliateConference.com

SOCIAL RESPONSIBILITY ::

THE PSYCHOSOCIAL IMPACT OF DAILY FANTASY SPORTS GAMES T

Dr. Mark Griﬃths Professor of Behavioural Addiction International Gaming Research Unit Nottingham Trent University

he triangular convergence of digital technologies, sport and the gambling industry has multiplied the possible combinations of products that, having originated in one field, have evolved into something different (Lopez-Gonzalez & Griffiths, 2017). For instance, fantasy leagues and videogames existed in the pre-internet era, but it was not until the internet’s arrival that their convergence with gambling materialized. All things considered, the integration of sports themed products becomes easier as their digitalization process continues, blurring the lines between formerly distinctive markets. Fantasy sports games have been popular for many years and involves individuals assuming the role of a professional sports team manager (typically football in the UK) and assembling a virtual team of sportsmen to compete against other players within a private or public league. For decades, the game was played out across the whole season with the winners being those that had accumulated the most points (with the points gained being based on the real-life statistics of individual sportsmen using a predetermined scoring system). However, fantasy sports have changed dramatically over the last few years. Fantasy leagues have grown into a multi-billiondollar industry in the US, arguably because of their controversial legal status as a skill game, contrary to the chance-based games of online sports betting, illegal in most of the jurisdictions (LopezGonzalez & Griffiths, 2017). Although the game can still be played over a whole season, the playing of daily fantasy sports (DFS) has become increasing popular (particularly in countries such as the USA, Canada, and Australia) and can operate over much shorter time periods. In DFS, players can pay to play and this has led to the blurring of lines of whether the activity is a game or whether it is gambling. As Pickering, Blaszczynski, Hartmann and Keen CGiMAGAZINE.COM

:: SOCIAL RESPONSIBILITY

<< According to gures in the same paper, in the USA, the fantasy sports (FS) market is currently estimated to be between $3 and $4 billion. In 2015, approximately 57 million Americans played FS. >> (2016) in the journal Current Addiction Reports: “Daily fantasy sports (DFS) is the most recent and controversial of FS games…It is an accelerated version of FS conducted over much shorter time periods: generally a single game (per day) or weekly round of competition. Users pay entry fees ranging from US 25 cents to US $5000 per league, which is deposited into a prize pool typically paid out to the highest ranked users in the contest. A portion of the entry fees also goes to the operator as commission. Accordingly, DFS, as such, is most associated with wagering. Currently, the US DFS market is dominated by ‘FanDuel’ and ‘DraftKings’ (combined with about 95% of the market)”. According to figures in the same paper, in the USA, the fantasy sports (FS) market is currently estimated to be between $3 and $4 billion. In 2015, approximately 57 million Americans played FS. Research suggests that the prevalence rates are higher in North America than elsewhere with 19% of Canadian adults and 16% of American adults engaging in FS compared to 10% of British adults and 6% of Australian adults (Pickering et al., 2016). However, these figures relate to FS rather than DFS and many FS players do not pay money to participate in the game and simply play for fun. There has been much debate (particularly by US legislators) as to whether playing DFS for money is classed as a legitimate form of gambling. If gambling is defined as “an agreement between two or more parties to deliberately stake something of value (typically money) with intent to profit on the outcome of an event that is determined wholly, or partially by chance” (the definition used by Pickering et al [2016]), then DFS could well be a form of gambling as they argue: “DFS can be construed as representing a form of gambling: (a) DFS includes an agreement between an individual and others, (b) money is staked on the relative performances of athletes across a certain number of sporting events with the outcome determined by both chance and skill, and (c) chance is involved given that multiple unknown factors can influence outcomes. In this regard, similarities are found in horse and sports wagering where some skill in selecting horse/sports outcomes is present, but unpredictable variables influence results (i.e., chance)…Literature from the legal field asserts that gambling must contain three elements: (a) consideration (staking something of value in order to participate), (b) chance (luck is a substantial factor in determining results), and (c) prizes (cash, merchandise, services, or points) are redeemable...While the first and third elements are clearly present

CGiMAGAZINE.COM

in DFS, the second element, chance, is the source of current disagreement”. The US legislation on gambling rests on whether an activity is more skill than chance determined. If DFS is predominantly a game of skill it is not deemed to be a form of gambling. The DFS operators claim that DFS games are not gambling because of the “substantial” amount of skill involved in the selection and management of FS teams. But is this any different for the professional gambler who bets on horse racing given the many factors that the person gambling has to take into account (the form of the horse, the skill of the jockey, the weather conditions, the state of the track, the number of other horses involved in the race, etc.)? Similarly, poker and blackjack are both games that players can win big if they are skilful. Furthermore, as Thomas and colleagues (2015) argued in an Australian report for the Victorian Responsible Gambling Foundation, the enhanced participatory role that fantasy games introduce could facilitate the ‘illusion of control’ as they perform actions, making bettors overestimate the importance of skills and knowledge for the outcome of the competitions. The illusion of control was defined by Langer (1975) as being "an expectancy of a personal success inappropriately higher than the objective probability would warrant" (p.316). This was tested for experimentally in a series of studies that supported her original hypothesis (i.e. under some circumstances people will produce skill orientations towards chance events). Langer reported that individuals bet more when cutting cards against a 'nervous' competitor than against a 'confident' one, and that individuals would sell previously bought lottery tickets for a higher price if they had picked it themselves as opposed to having the ticked 'assigned' by someone else. Other experiments showed that certain factors such as the nature of the competition, the familiarity of the task, and the degree of personal involvement influence the belief that skill is a controlling force. In essence, Langer's basic assumption was that in some chance settings, those conditions that involve factors of choice, familiarity, involvement and/or competition, may stimulate the illusion of control to produce skill orientations. All these conditions are present in DFS games. Control and the illusion of control may also depend upon the motivation to play fantasy sports games in the first place. A study by Farquhar and Meeds (2007) published in the Journal of

SOCIAL RESPONSIBILITY ::

Computer-Mediated Communication, reported two basic types of FS players. The first type was highly involved, enjoyed the statistics of FS, viewed FS playing as skillful, and enjoyed outsmarting FS playing losers. The second type was much less involved, viewed FS playing as a game of chance, were motivated by the thrill and arousal of winning, and the bragging rights that followed. However, this study was carried out on FS players rather than DFS players and motivations by the latter group may be different. Interestingly, research by Drayer, Dwyer and Shapiro (2013) published in the European Sport Management Quarterly suggests that those who engage in playing DFS games do not typically engage in other forms of gambling. Earlier research by Dwyer and Kim (2011) published in the Journal of Sport Management, reported that compared to more traditional forms of gambling, the elements of fun, excitement, competition play a bigger role than winning money in the playing of DFS games. However, a study carried out Martin and Nelson (2014) in Addictive Behaviors reported that college students who were FS players (free and fee-based) were five times more likely to incur gambling problems than non-FS users, and students who played FS for money had significantly higher rates of gambling problems than those who played in free leagues. A more recent 2016 study by Marchica and Derevensky published in the International Journal of Mental Health and Addiction examined data from national surveys of collegiate athletes and reported a steady rise in FS participation among college students between 2004 and 2012. They reported that approximately half of the male and a quarter of the female college athletes who qualified as at-risk or problem gamblers also reported wagering on FS. The rise of DFS playing has mirrored the rise of the standardization and quantification of sports action (i.e., the generation of ‘big data’). Like sports betting, a prerequisite for DFS playing is the conversion of sport performance into data. Data and big data industries in sport have blossomed over the last decade, and data driven technologies have taken centre stage in the transmission of sports content (Lopez-Gonzalez & Griffiths, 2017). Data companies (such as the Perform Group) have signed long-terms deals with sport competitions worldwide to extract, analyse and deliver data content. These data are bought by sports betting and FS operators to produce the bettable elements in the market. Personally, I believe that playing DFS games for money is definitely a form of gambling, and even if it isn’t legally classed as a form of gambling, the games contain structural elements (including high event frequencies, low entry fee per game, lots of games, etc.) that can facilitate excessive use and expose vulnerable players to harm. DFS operators also allow team lineups from a previous sporting event to populate other events which increases the speed of play, another factor that can facilitate habitual use (Harris & Griffiths, 2017). However, the number of studies to date examining the psychosocial impact of DFS games are few and it will be some while before the potential risks of DFS games compared to more traditional types of gambling are known and elucidated. :: CGi References Drayer, J., Dwyer, B., & Shapiro, S. L. (2013). Examining the impact of league entry fees on online fantasy sport participation and league

consumption. European Sport Management Quarterly, 13(3), 339-335. Dwyer, B., & Kim, Y. (2011). For love or money: Developing and validating a motivational scale for fantasy football participation. Journal of Sport Management, 25(1), 70-83. Farquhar, L. K., & Meeds, R. (2007). Types of fantasy sports users and their motivations. Journal of Computer-Mediated Communication, 12(4), 12081228. Harris, A. & Griﬃths, M.D. (2017). The impact of speed of play in gambling on psychological and behavioural factors: A critical review. Journal of Gambling Studies. Epub ahead of print. doi: 10.1007/s10899-017-97017. Langer, E. J. (1975). The illusion of control. Journal of Personality and Social Psychology, 32, 311-328. Lopez-Gonzalez, H. & Griﬃths, M.D. (2017). Understanding the convergence of online sports betting markets. International Review for the Sociology of Sport. Epub ahead of print. doi: 10.1177/1012690216680602. Marchica, L., & Derevensky, J. (2016). Fantasy sports: A growing concern among college student-athletes. International Journal of Mental Health and Addiction, 14, 635-645. Martin, R. J., & Nelson, S. (2014). Fantasy sports, real money: Exploration of the relationship between fantasy sports participation and gamblingrelated problems. Addictive Behaviors, 39(10), 1377-138. Pickering, D., Blaszczynski, A., Hartmann, M., & Keen, B. (2016). Fantasy sports: Skill, gambling, or are these irrelevant issues? Current Addiction Reports, 3(3), 307-313. Thomas, S., Bestman, A., Pitt, H., Deans, E., Randle, M., Stoneham, M., & Daube, M. (2015). The marketing of wagering on social media: An analysis of promotional content on YouTube, Twitter and Facebook. Victoria, Australia: Victorian Responsible Gambling Foundation.

DR. MARK GRIFFITHS

Dr. Mark Griﬃths is Distinguished Professor of Behavioural Addiction at Nottingham Trent University, and Director of the International Gaming Research Unit. He is internationally known for his work into gambling and gaming addictions. He has published over 650 refereed research papers, ﬁve books, 150+ book chapters and over 1500 other articles. He has won 18 national/international awards for his work including the US National Council on Problem Gambling Lifetime Research Award (2013).

CGiMAGAZINE.COM

:: ADVERTISERS’ INDEX // FORTHCOMING EVENTS

Advertisers’ Index

Forthcoming Events

SEPTEMBER 2017

Alfastreet alfastreet.si

Balkan Gaming & Entertainment Expo balkangamingexpo.com

Berlin Aﬃliate Conference

igbaﬃliate.com/events/berlin-aﬃliate-conference

Colossus Bets colossusbets.com

OBC EiG

eigexpo.com

IFC

IBC

Gaming Africa

gamingafrica.za.com

Greentube

greentube.com

Harris Hagan harrishagan.com

ICE Totally Gaming icetotallygaming.com

NYX Gaming

nyxgaminggroup.com

Optimove

optimove.com

SAGSE Latin America monograﬁe.com/sagselatam

SiGMA

maltaigamingsummit.com

Sports Betting USA Conference sportsbettingusaconference.com

Totally Gaming Summit totallygamingsummit.com

Yggdrasil Gaming yggdrasilgaming.com

CGiMAGAZINE.COM

:: WrB London | 12 September London, United Kingdom

:: Betting On Sports Conference | 12-15 September London, United Kingdom

:: Cyprus Gaming Show | 20-21 September Nicosia, Cyprus

:: Malta iGaming Seminar (MiGS) | 26-28 September Malta

OCTOBER 2017

:: G2E | 3-5 October Las Vegas, USA

:: Daily Fantasy Sports Expo | 9 October London, United Kingdom

:: Gaming Africa | 24-25 October Johannesburg, South Africa

:: EiG | 30 October-1 November Berlin, Germany

:: Totally Gaming Summit| 31 October-2 November Tallinn, Estonia

NOVEMBER 2017

:: Financial Partrners Expo | 1-4 November Berlin, Germany

:: Berlin Aﬃliate Conference (BAC) | 2-3 November Berlin, Germany

:: SAGSE LATAM | 7-9 November Buenos Airies, Argentina

:: BiG Africa Supershow | 7-8 November Johannesburg, South Africa

:: Sports Betting USA | 14-15 November New York, USA

:: Eastern European Gaming Summit | 21-22 November Soﬁa, Bulgaria

:: Balkan Entertainment & Gaming Expo | 22-23 November Soﬁa, Bulgaria

:: SiGMA | 22-25 November Malta

30 October - 1 November 2017, Arena Berlin eigexpo.com I @EiG_gaming I #EiG17

Excellence Excellence in iGaming