Casino & Gaming International: Issue 32

2018 ISSUE 32

PUBLISHER’S NOTE ::

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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 Sarah Harrison, Clive Hawkswood, Melanie Ellis Darin Yug, Jennie Blumenthal, Amy Riches Dr. Jason Lane, Paul Marcantonio, Valéry Bollier Kate Chambers, Dr. Mark Griffiths, Maris Bonello

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ith another year upon us and an industry that continues to move

at lightening speed, CGi is delighted to be joined for our first

edition of 2018 by another host of industry leaders, all looking

to offer their expertise and analysis on the latest hot topics.

And we kick off the publication with Sarah Harrison (Gambling Commission)

who, before she leaves her post at the end of February, gives us an update on

what the Gambling Commission are doing to make the industry fairer and safer for the forseeable future.

Clive Hawkswood (Remote Gambling Association) also gives his thoughts on the latest regulatory issues affecting customers and Melanie Ellis (Harris Hagan)

looks at the final warnings the Gambling Commission have recently issued to 17 Remote Casino Operators.

Darin Yug and Jennie Blumenthal (PwC) provide us with a detailed analysis of

the customer ecosystem, whilst Amy Riches (Evolution Gaming) highlights the latest Live Casino innovations.

Dr. Jason Lane (Jersey Gambling Commission) gives us an up to date overview

on Jersey as a jurisdiction whilst Paul Marcantonio (EcommPay) offers his

predictions for the year ahead.

Valéry Bollier offers his thoughts on how the Video Gaming industry is already

looking in our direction and we chat to Kate Chambers (Clarion Gaming) about

the continuing progression of ICE and what we can expect at this years show in London.

And finally, Dr. Mark Griffiths and Maris Bonello (Nottingham Trent University) share with us their latest Social Responsibility report.

ISSN 2398-4252

© 2018 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.

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Jamie Kean, Publisher

The next edition (Issue 33) of CGi will be published on 1st May 2018.

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CONTENTS ::

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FEATURES 7

Working together to make gambling fairer and safer

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keePing the trUst of the CUstomer and being aWare of an eVer-Changing landsCaPe

sarah harrison, gambling Commission

Clive hawkswood, remote gambling association

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final Warning for remote Casino oPerators

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eVeryone is a CXo: Creating a Unifying CUstomer eXPerienCe in the gaming indUstry

melanie ellis, harris hagan

darin yug & Jennie blumenthal

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Proof that yoU Can reinVent the Wheel in liVe Casino amy riches, evolution gaming

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FEATURES 33

soCial resPonsibility, JUrisdiCtional rePUtation and deVeloPing bUsiness: a reCiPe for – What? dr. Jason lane, Jersey gambling Commission

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the indUstry trends PrediCted to haVe a signifiCant imPaCt on igaming in 2018 Paul marcantonio, eCommPay

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game oVer for the igaming seCtor?

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a global ‘ParadiCe’ for a global indUstry

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soCial resPonsibility, Player ProteCtion, and harm minimisation: hoW are online gambling oPerators doing?

Valéry bollier, oulalagames

interview with kate Chambers, Clarion gaming

dr. mark griffiths & maris bonello, nottingham trent University

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WORkING TOGETHER TO mAkE GAmBLING fAIRER ANd SAfER F

or the last two years Sarah Harrison has been the Chief Executive of the Gambling Commission, regulating all gambling operators providing products to consumers in Britain. Later this month (February) she will be leaving the regulator to take up a senior role with the Department for Business, Energy and Industrial Strategy. Before leaving, Sarah has taken time out to speak to Casino & Gaming International about a new strategy which will shape the Commission’s actions over the next three years.

Sarah Harrison Chief executive gambling Commission

The gambling market in Britain continues to grow. Our figures show that between April 2016 and March 2017 the gross gambling yield (GGY) for the industry was £13.8bn which represents a 2% increase on the previous year.

This will be good news to all 100,000 people working within the industry – each and every one of us wants to work in a sector with a bright future.

But here’s the rub, our research suggests that public confidence in gambling is declining.

Some 78% of people believe that there are too many opportunities to gamble, 69% of people feel that gambling is dangerous for family life and only 34% believe that gambling is fair and can be trusted, down from 49% in 2008. In addition to this, there are significant public concerns about the volume, nature and scheduling of gambling advertising and the impact this could have on future generations.

What’s more, these concerns are reflected in parliament and media coverage. You don’t have to look very far to see headlines portraying the gambling industry in a poor light.

It doesn’t take a genius to deduce that such GGY growth – particularly in the online sector which was up 10% to £4.7bn – is not sustainable if the public and customers begin to lose faith.

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<< More needs to be done, and at a faster pace, by operators to improve ways to know their customers, to ensure fair and safe play, and to keep gambling free from crime and money laundering. >> We want this market to be the best in the world – one that provides consumers with enjoyment, and that is fair and safe- and is seen to be so by the wider public.

And this is why we have recently published our ambitious strategy for the next three years… much of which will have significant impact on the casino and gaming industry. The strategy has been informed by our assessment of risks, our understanding of the current public policy environment and by views expressed by industry operators including at board level. It aims to paint a picture of some of the things you might expect to see in a well-functioning market which puts consumers at its heart. The strategy sets strategic priorities and we will develop business plans (and budgets) to support delivery of the strategy over the next three years.

Much of this strategy is not new in the sense that it brings together the themes and priorities that the Commission has been advancing over the last couple of years, in particular the clearer focus on consumers. Because of that, and because it has been developed by the Commission’s governing board, it is well grounded and sets the direction and tone for the regulator for the future.

Protecting the interests of consumers Information currently available to help consumers understand the products and services they use, apply their rights and how to access help can be difficult to find, and generic in nature. We are finding that technology has not been applied to tailor information, processes and systems to an individual’s circumstances and needs. As a result there is an imbalance between businesses and consumers. Too often, the consumer bears a disproportionate share of the risk.

Over the next three years the team at the Gambling Commission will make sure that operators provide easy access to reliable information, tools and services which consumers can use to inform and control their gambling. This includes intervening early when problem gambling behaviour is spotted and signposting consumers to help with gambling-related problems.

For example, this may include information for families and others who might be well placed to spot signs of problem gambling. We will work with consumers and operators to ensure interventions and safeguards are well designed and targeted.

We will promote greater transparency by putting independent and trusted information into the public domain.

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Consumer choice is heavily influenced by price and brand and it can be difficult for consumers to work out what else matters. This might include information such as details of any proportion of the price which is paid to good causes, the risks posed by particular products, treatment of customer funds and accounts, and other features that show operators’ approach to serving customers.

We will review and strengthen rules to tackle unfair and misleading practices – this will include working with other consumer protection regulators, and penalising companies who provide misleading information to consumers or fail to treat them fairly. Our recent work with the Competition and Markets Authority on failings by operators in relation to terms and conditions is a good example of this.

We will make sure that consumers have access to effective dispute resolution and redress services, which are independent, swift, trusted, free of charge, transparent and fair. Over the life of this strategy we want to see more streamlined and simplified arrangements for dispute resolution and redress arrangements.

Prevent harm to consumers and the public Gambling-related harm is when gambling causes damage to not only individuals, but also their families, the communities they live in or society more generally. It is associated with a range of mental health and social problems (including crime). This includes the costs associated with its impact on public health services, on communities, on employment and debt, and on justice and court services. Understanding the full impact of gambling will help the industry, the Commission and other key stakeholders to properly manage and minimise those impacts.

Over the course of the next three years we will regulate and take precautionary action where necessary to reduce gamblingrelated harm. Our focus is a balanced one. Not just on gambling controls to help customers manage their gambling, but also on the nature of the products themselves, the provider, and the place or environment in which the gambling is taking place.

We understand that operators must compete with one another, indeed competition is important for customers where it can drive choice and innovation. But we also expect cooperation across the industry to mitigate and minimise harm. We want a focus on ‘what works’ and we know there is no ‘silver bullet’ solution. So we want to see a culture of trialling and evaluating interventions – where operators draw on the innovation and creativity that drives growth and profit, and channel this to protect and empower consumers.

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We will work with partners to shape a future national strategy for safer gambling. This must identify the scale of industry funding required to invest in preventative measures, in effective education, and in the evolution of treatment services which are accessible in the areas of greatest need and based on best practice models of treatment delivery and evaluation.

We will put in place a more effective approach to target funding, supervise progress, and evaluate and report on the impact of a national strategy for safer gambling. Many initiatives and programmes are already underway. However, if there is to be step change over the next three years, we see the case for increased funding and improved supervision of delivery across the operators and agencies concerned with limiting and treating gambling-related harm.

Raise standards in the gambling market More needs to be done, and at a faster pace, by operators to improve ways to know their customers, to ensure fair and safe play, and to keep gambling free from crime and money laundering.

In January 2018 we wrote to all online casino operators to raise concerns about the sector’s approach to anti-money laundering and social responsibility. This followed a thematic review of the sector to consider how well operators are meeting their current obligations. Due to the serious nature of our findings, we have already begun investigations into 17 online operators, and are considering whether five of these require a licence review.

Over the next three years we will require operators to design protections ‘up front’ to the products and services they offer, considering how data analytics, technology and other measures can be used to detect and prevent crime (including money laundering) and harmful gambling. We will also require operators to build on existing ‘backstop’ protections, such as self-exclusion, in ways that work for well for consumers as well as for industry.

In addition, we will look carefully at the evidence brought to us by operators and consider whether we should make changes in the interests of consumers if regulatory requirements prove to stand in the way of piloting or developing new innovative approaches. Innovation is important, and while welcoming it, we will apply the precautionary principle to new products, or other innovations, when there is good reason to believe they might cause harm disproportionate to any benefits they might bring.

The burden of proof will sit with the operator to demonstrate otherwise.

We will look to intervene to enhance the protections to consumers given by our Licence conditions and codes of practice.

For example, we are currently reviewing the online gambling sector to take account of how the market has evolved since Point of Consumption in 2014 and whether current regulations and protections are fit for purpose. Where necessary we will amend our requirements to raise the bar in consumers’ interests.

We know we have a role to play in helping the industry comply.

We will support the industry to lead the way, collaborate and share what works, as well as what has proven to be less effective for consumers, via processes like the annual assurance statement reporting. This will involve finding ways to better share lessons learned and supporting the industry in a drive to share best practice and accelerate progress.

We will develop and publish risk assessments, analysis and research, such as the assessment of money laundering and terrorist financing risk. We will look to operators to draw on these to shape their own risk assessments and take pre-emptive action.

We will hold to account those who do not attempt to understand the risks of gambling or fail to put in place effective mitigations.

We will use the full range of our enforcement powers, and develop our use of sanctions, to ensure these are well targeted and provide credible deterrence.

We will continue to support and facilitate collaboration across operators and other agencies concerned with raising standards in relation to sports betting integrity, and work to foster national and international standards where it is clearly in the interests of consumers to do so.

If operators fail to respond to our challenge to raise standards and persistently or repeatedly fail consumers, they will face the sharp end of regulation. Recent examples of this include our £7.8m penalty package against 888 and the £2.3m penalty package against Gala Interactive. We are making it very clear that over the life of this strategy we use tougher and broader sanctions. This is important, not just for wider public confidence in regulation, but also for the market to give assurance that there is no competitive advantage to be gained from not raising standards.

We are here to help Over the next three years we want to continue to make gambling fairer and safer for consumers, and the wider public. The pace of change across the industry so far has been too slow, and we are approaching a tipping point- things cannot continue as they have.

The time to act is now and we want to provide more support, help and advice to operators to get it right.

Our call to action extends to partners and others who have an interest in this market. A call not only to challenge from the side lines but to stand ready to work with those in the industry who genuinely want to make a difference.

Just like any other industry we want to see gambling operators shape their businesses to fit with consumer demands not only on price, choice and excellent service but also their expectations for fair treatment, values and protection. :: CGi

SARAH HARRISON

Sarah became Chief Executive of the Gambling Commission on 1 October 2015.

Prior to joining the Commission, Sarah had worked at Ofgem since 2000 with her last position as a Senior Partner leading the Sustainable Development Division and before that as Managing Director of Corporate Affairs and Communications Director.

Before joining Ofgem, Sarah was the first Chief Executive of ICSTIS, the UK industry regulator for premium rate telephone services. Her earlier career was in public relations consultancy.

Sarah will be leaving the Commission at the end of February 2018 to take up a senior role with the Department for Business, Energy and Industrial Strategy.

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kEEPING THE TRUST Of THE CUSTOmER ANd BEING AWARE Of AN EVER-CHANGING LANdSCAPE E

very year seems to be a challenge for the online gambling sector and 2018 will be no different.

Overall trends continue to be upwards and positive.

Even in the UK, which is generally regarded as the most mature of markets, the latest Gambling Commission statistics show double digit growth in GGY. Online gambling is the largest segment of the regulated sector and the Commission is quite reasonable predicting that it will soon account for 50% of the market. However, what goes hand in glove with that is an increased profile with politicians and media. Where we are weak or can do better will increasingly come under the spotlight.

Clive Hawkswood Chief executive remote gambling association

So, in the firm belief that the same issues will arise to a greater or lesser degree in every regulated jurisdiction at some stage, it must be better for us to look proactively at where we might be open to criticism and try to do something about it. Sometimes it pays to be our own hardest critics, which is some challenge given how many vocal critics we already have. It is not necessarily a case of washing our dirty linen in public, but rather cleaning our linen before we wear it in public.

In the past, issues such as money laundering or safeguarding the integrity of sport might have been near the top of the list.

However, they barely figure anymore and that is largely a reflection of the work that has gone into addressing the risks involved.

Instead they have been replaced for very understandable reasons by a raft of concerns about how well we treat and protect consumers.

It is no understatement to say that our long term future rests on getting this right. Tougher laws and regulation will follow if we do not. Those are the more obvious threats, but beneath that is the more fundamental danger of losing the trust and confidence of our customer base.

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<< Of all the issues that could determine the extent of future regulation of the online gambling sector, it is behavioural analytics that is probably the predominant one. >> So what are the areas we’ve been looking at?

In no order of priority and frequently where there is an overlap between them, it includes potentially unfair terms and practices; the use of behavioural analytics; player protections, such as enhanced and joined up self-exclusion; marketing practices; and the adequate funding of research, education and treatment associated with gambling-related harm.

Of course, identifying and accepting the problems is in many ways the easy part. Agreeing proportionate and effective responses to what are hugely complex issues is no easy task, but we have no option other than to try.

Unfair terms and practices It must be right that any unfair terms and practices should be remedied and the recent CMA enquiries have looked especially at those relating to promotional offers. Great clarity will be forthcoming from the CMA and the Gambling Commission early in 2018 but there is already an expectation that companies should be reviewing all of their T&Cs. Although unfair bonus play-through requirements have attracted a lot of attention there are numerous other areas of concern that have been, and will be, looked at. The key will be to get the best possible guidance out of the Gambling Commission when it reviews the relevant provisions of its Licence Conditions and Codes of Practice.

Behavioural analytics Of all the issues that could determine the extent of future regulation of the online gambling sector, it is behavioural analytics that is probably the predominant one.

The use of behavioural analytics to identify signs of problematic online gambling is still at a relatively early stage in its development. However, real progress is now being made.

Approaches do vary widely across the industry, but this is reflective of the lack of hard research on which to base models. As that research improves and as operators are able to evaluate and share learnings from any existing systems they have, greater consistency will be achieved.

This applies both to the methodology for identifying problematic gambling and, crucially, to the interactions with customers once they have been identified. It is self-evident that unless effective interactions take place which lead to either a return to safer patterns of gambling or to the cessation of gambling then there is little or no benefit to be had from having processes which identify potentially harmful play.

The GambleAware (now BeGambleAware) research undertaken by PwC into markers of harm has been very helpful and

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it is now working on an associated piece of research which will focus more on evaluations and interactions. The RGA is supportive of, and co-operating with, this project and it would disappointing if at its end there was not a much greater consensus about what the most effective interactions are and how interactions can best be evaluated.

In the meantime the RGA is already working on draft industry good practice guidelines which will cover analysis and interactions.

It is based on the PwC research and existing experience from within the industry. The aim is to have it published as soon as possible in the first half of 2018. Thereafter it will be reviewed and updated periodically to reflect any new learning in this emerging field and, of course, any related changes that are required following amendments to the Gambling Commission’s LCCP.

GAMSTOP – national self-exclusion Self-exclusion is a recognised tool to help customers who wish to stop gambling. It cannot ever be in isolation a solution to the question of how to prevent problem gambling, but undoubtedly it is of use to many tens of thousands of customers. The biggest flaw in the current provisions, certainly in the UK, is that there is no national self-exclusion system of the type found in places like Denmark, Spain and New Jersey.

Although no system is fool-proof, GAMSTOP will bear comparison with any state or regulator-run self-exclusion system in the world and will undoubtedly make self-exclusion easier and more effective. It is unusual for a private sector body to set up and run such a scheme, but in doing so the RGA has sought to establish something which will bear comparison with any state or regulator run system in the world.

Marketing By their nature advertising and marketing are designed to be in the public eye. The problem we face at the moment is that a lot of people simply think there is too much if it. Regulations are gradually being tightened and there are particular pressure points such as the one around the very subjective area of advertising that might be deemed to be of particular attraction to under18s.

Advertising in a competitive market can be one of the main differentiators between companies and the ability to advertise should be one of the quid pro quo benefits are being regulated and taxed. Unfortunately, fairness is in short supply when it comes to politics and newspaper coverage and we ignore the longstanding opposition in some quarters at our peril.

Various initiatives should help and one worth mentioning here is the proposed joint project from BeGambleAware, the RGA, the Senet Group and the major broadcasters such as Sky and ITV to

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bring forward a two year multi-media raising awareness campaign.

Under the guidance of BeGambleAware this is an example of two responsible industries working together to produce a campaign that will alert consumers to the risks that can come with a gambling. To some it might sound like Turkeys voting for Christmas, but there is no reason that responsible businesses cannot be successful businesses as well and, in the current climate, there is a strong school of thought that across all industries the two must go hand in hand.

Funding of research education and treatment This is a subject worthy of an article in its own right, but safe to say in the UK things have reached a tipping point. For the RGA, we have already announced that we would like the government to introduce a statutory levy now rather than retaining the current system or considering alternatives. It is not a position that the RGA has taken lightly, however, we have listened to the calls from the Gambling Commission and others to put customers first and believe this is the only way to ensure the levels of long term and sustainable funding that are required to support those affected by gambling-related harm.

Yes, it will lead to greater funding than under the current system but a levy would also spread the cost across the entire industry in a way that is equitable between sectors and size of operators. However, most importantly it would ensure the long term and adequate funding of research, education and training. A levy is not a blank cheque and the annual targets would be objectively justified and subject to Parliamentary oversight, but for an industry that generated over £13bn in GGY it is frankly embarrassing that the voluntary system is scrabbling every year to get close to raising £10m.

If the wider industry is serious about the responsibility it has to the users of its products then support for this initiative is one way obvious way to demonstrate that. As an industry we should

take pride in the good work that has only been achievable over the years because of the voluntary funding arrangements, but the truth is that we get no credit for that and the present system is no longer fit for purpose.

Is that all?

Hopefully, this has given more than a flavour of the challenges we face in 2018 and beyond, but it would be naïve to think there are no other issues simmering away below the surface. Anyone wanting to dig a bit deeper could do worse than listen to what the CMA has said already and what else it might say before the Spring.

Do not be surprised to see the regulation of affiliates raise its head again and for some old favourites like dormant accounts, especially charges on dormant accounts, attract more attention. :: CGi

CLIVE HAWKSWOOD

Clive Hawkswood has been Chief Executive of the Remote Gambling Association (RGA) since its establishment in August 2005. Before that he was the General Secretary of ARGO. Clive was formerly head of the Betting & Racing Branch at the British Department for Culture, Media & Sport (DCMS). Prior to that, he was at the Home Office, spending time in both the Gambling Section and the Horseracing Policy Team. Earlier in his career he spent several years working in the bookmaking industry.

He is also a longstanding board member of the Responsible Gambling Trust, the British charity that raises funds for problem gambling related research, education, and treatment. He is the author of the Industry Code for Socially Responsible Advertising and sits on the cross-sector groups: Industry Group for Responsible Gambling (IGRG) and Gambling Anti-money Laundering Group (GAMLG).

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LEGAL ::

fINAL WARNING fOR REmOTE CASINO OPERATORS O

n Friday 5 January, Gambling Commission licensed remote casinos received a late Christmas message from their regulator. The letter set out the results of an assessment exercise the Commission has been carrying out into operators’ compliance with AML and customer interaction requirements. It reveals that, during the course of its assessment, the Commission discovered 17 operators whom it believed warranted formal investigation, due to apparent failings in this area, 5 of whom may become subject to a licence review. The identities of the 17 and 5 have yet to be made public.

melanie Ellis senior associate harris hagan

The widespread nature of the AML failings has caused the Commission to have concerns about the effectiveness of policies and procedures throughout the remote casino sector. This letter gives all operators a chance to correct their own practices before they too face regulatory action and also serves to put them “on notice” as to the issues that must be addressed. The implication is that if failings in this area are discovered in the future, the licensee in question would not be in a position to plead ignorance and/or ask for time to become compliant.

Background The Commission’s focus on AML failings is nothing new: 13 of the 17 public statements published by the Commission since 2013 related to this issue, all involving sources of customers’ funds.

This goes to the very heart of gambling regulation and ties into social responsibility; these public statements reveal that it is often the case that if someone is spending the proceeds of crime with a gambling operator, the background is that they have been stealing (often from their employer) to fund a gambling addiction.

The serious results when things go wrong suggest that the

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Commission is right to be concerned about operators following appropriate AML procedures. However, this should be put into context. Whilst one person stealing from their employer to fund a gambling addiction is obviously one too many, the Government concluded in its 2015 National Risk Assessment that the overall risk level for the casino sector was “low”, compared to “medium” for estate agents and “high” for legal service providers . The report did state, however, that “if the recent efforts by the sector to improve standards were to lapse, or if businesses were to begin offering new products or services that increase the inherent vulnerability within that sector, then the overall risk could rise” .

There is no doubt that operators have been taking significant steps to improve their processes over the last few years, but the Commission has found that many operators are still missing the mark.

What do operators need to do?

If not already part of their policies and procedures, remote casino operators must:

1. Conduct and document an AML risk assessment (or review the existing one) and implement and new policies / procedures deemed necessary; 2. Conduct customer due diligence (CDD) and enhanced due diligence (EDD) when appropriate; 3. Provide employees with sufficient training on AML laws, procedures and controls; 4. Keep proper records of suspicious activity reports (SARs) and the analysis of transactions which triggered the reports; 5. Ensure procedures are in place to identify potential problem gambling (or review those that are in place to ensure triggers are appropriate); 6. Interact with customers where their gambling pattern and

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spend indicates potential problem gambling and keep evidence of interactions.

It is worth noting that these are not new requirements; remote casino operators should already be doing each of these things under the LCCP and Money Laundering Regulations. Compliance with some of these points should be reasonably straightforward and it is perhaps surprising that, for example, the Commission has identified operators who were unable to produce an adequate risk assessment document on request. On the other hand, there is a lack of clarity in relation to exactly what is required under some points.

In particular, putting in place the correct CDD / EDD procedures can be challenging, not least because the Money Laundering Regulations and Commission guidance do not specify the exact circumstances under which each would be required, nor the level and nature of the information which must be gathered.

In its letter, the Commission points out that CDD must be conducted when operators “establish a business relationship with a customer, suspect money laundering or doubt the veracity or adequacy of documents or information previously obtained”. EDD is required “where a customer presents a higher risk of money laundering”.

This leaves operators needing to ask themselves questions such as when and if they have established a business relationship with their customer, what is “adequate” information to mitigate the identified risks and what constitutes a “higher” risk of money laundering. Even the legislation itself does not provide definitive answers; for example in assessing whether there is a high risk of money laundering operators must take into account that the casino is remote so they do not meet customers face to face , but does not specify that this necessarily does or does not make transactions high risk and therefore subject to EDD. Customer

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<< Nobody wants to admit out loud that commercial factors must come into play, but it is the higher value customers we are talking about. Asking for additional information and documents and/or asking if the customer may have a gambling problem is at best intrusive and at worst insulting enough to cause the customer to gamble elsewhere. >> interaction can also be a tricky area, with no small degree of subjectivity and sensitivity being required to determine whether an interaction is required and what it should entail.

The industry has long lamented that the Commission is reluctant to give specific guidance on these points, but is quick to criticise operators when their procedures have failed to identify a customer who it turns out should have been subjected to a higher level of scrutiny or interaction. But the Commission is probably right to fear a “race to the bottom” if it specifies exactly what is the minimum needed to meet the requirements, and the lack of specifics cannot be an excuse to do nothing (or very little).

Recommended steps Of course I would say this, but if you as an operator are unclear on what is required under points 1 to 6 above, the first step is to seek expert advice, from a lawyer and/or accountant. Even if the Commission subsequently disagrees with that advice, the fact that you have sought it will go a long way to demonstrating that you have taken your AML and social responsibility obligations seriously.

Secondly, it is vital that you document what you are doing and why. Having a written AML policy, risk assessment and training plan again shows that you have given proper thought to these issues. Documenting decisions that you make, all due diligence you carry out and SARs that are submitted (along with reasoning in each case) again shows, even if the Commission disagrees with your conclusions, that you are at least attempting to do the right thing.

Conclusions Nobody wants to admit out loud that commercial factors must come into play, but it is the higher value customers we are talking about. Asking for additional information and documents and/or

asking if the customer may have a gambling problem is at best intrusive and at worst insulting enough to cause the customer to gamble elsewhere. There needs to be a very good justification for taking steps which could lead to the loss of a valuable customer, so the feared race to the bottom is inevitable. Perhaps it is time for the remote casino industry to come together and agree some specific minimum steps that will be taken in specific circumstances (in particular in terms of customer due diligence and customer interaction) so that customers know they will face the same questions with every operator.

The Commission’s letter reflects the general tightening up of standards by the regulator over the past few years and the increase in regulatory action and penalties. The letter must be seen as a final warning, which makes it imperative that operators find some balance between remaining competitive but also ensuring they are able to demonstrate their compliance with the LCCP and AML regulations. :: 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.

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EVERYONE IS A CXO: CREATING A UNIfYING CUSTOmER EXPERIENCE IN THE GAmING INdUSTRY

darin yug

C

darin Yug & Jennie Blumenthal PwC

ustomer experience is everything these days - an extension of your product, a reflection of your brand, the difference between a social media win or nightmare. Yet delivering on a consistent experience is difficult. Where and when does the “experience” begin and end? How do you deliver a cohesive experience across such seemingly disparate customer touchpoints? Businesses today from across all industries are struggling with these questions while striving to exceed the constantly evolving expectations of their customers.

In order to deliver a unique and memorable customer experience, it is important for organizations to manage their experience touchpoints comprehensively across the whole customer experience ecosystem.

Delivering positive, memorable, and differentiated experiences for today’s customer requires companies to succeed along three pillars: get digital right, be data rich and data literate, and deploy the right operating model to lead and foster change.

Defining the “Customer Experience Ecosystem” The “Customer Experience Ecosystem” comprises all touchpoints a customer has with a brand. For integrated resort and gaming operators, this includes before a trip begins with planning activities, during the trip across the integrated resort amenities, after the trip with any follow up interaction, and any social or internet gaming experiences between visits. Thinking of the customer experience as an ecosystem opens up a more dynamic range of possibilities for informed, consistent and wellcoordinated delivery of experience.

Expectations of Today’s Customer The rapid acceleration of technology has reset the bar for

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<< In the near future, the average customer will have grown up steeped in technology. They demand an integrated digital customer experience that is accessible on mobile devices, on-demand, personalized, and tied to social media. >> customer expectations, and will continue to do so into the future. Kurzweil’s Law holds true- the rate of technology change is always increasing, and sustained customer loyalty hinges on the ability of integrated resort operators to leverage technological innovations and create a unique customer experience that is aligned with their brand.

Customer experiences that were viewed as innovative and differentiated in the recent past have become the baseline. For example, long gone are the days where retailers can survive without mobile and ecommerce platforms. Similarly, taxi operators have been forced to adopt on-demand hailing applications to react to disruptive rideshare companies.

Hospitality is not immune to this trend either, as the room and home sharing economy and short term rental companies have eroded the market share of traditional players by differentiating on customer experience.

In the near future, the average customer will have grown up steeped in technology. They demand an integrated digital customer experience that is accessible on mobile devices, ondemand, personalized, and tied to social media. In addition, they expect two-way digital communication, where the integrated resort becomes a travel partner rather than a destination.

Customers want to browse dining options from the comfort of their hotel room or on the go and seamlessly book dinner reservations with one click on their mobile device. They expect to see gaming products on the floor that have a similar look and feel to the social gaming apps that they played before their stay.

They want to receive digital promotions that are relevant to them and easy to redeem on property at any time. And all of these discrete events should feel like waypoints on a journey, from start to finish.

Integration of different touchpoints into a cohesive and memorable experience does not come without challenges given the diverse services and experiences a gaming and integrated resort offer. The following pillars are building blocks to success.

Pillar 1: Get Digital Right What is digital? How should an integrated resort operator think about digital transformation to support customer experience?

From our point of view, a digital company is an organization that

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embraces constant innovation, has flat or integrated decision making, and weaves technology into all phases of the business.1 A digital company determines their deployment of new technology by focusing on a specific human or business need, and aligns their investments to specific use cases with quantified benefits.

So how do you get digital right? First, integrated resort operators should determine which customer touchpoints to innovate, and how that impacts the end-to-end customer experience. In addition, operators should consider which innovations are appropriate for all customer segments and how to incorporate them into their CRM platform. For example, do some segments want a digital first self-service mentality, while others crave the high touch face-to-face interaction? Next, think hard about where you should build or buy digital capabilities that will align to the strengths of your business. Don’t “do digital” for the sake of being digital- buy or build the capabilities that make the most sense for the experience you are seeking to enable. Finally, you will need to match your talent strategy to this new ambition to ensure everyone is brought along with the change. Employees should have baseline knowledge of technology and design thinking (which may require training) and be empowered by a customer focused, digital and insightsdriven culture. Companies that use dedicated cross-functional teams, agile approaches, and have a strong understanding of the human experience, are typically more successful than their peers.

Pillar 2: Be Data Rich and Data Literate As operators have recognized, the era of valuing customers by only gaming activity ended years ago. In fact, non-gaming products accounted for 65% of revenue at Las Vegas Strip properties in 2016, up from 54% in 2000 and 42% in 1990.2 Aggregating the data from the various customer touchpoints can be daunting, however advancements in technologies make it possible to not only aggregate, but perform advanced analytics focused on customer profiles and automation.

Most industries don’t leverage the vast amounts of data collected about their customers. But they are beginning to.

AdVISORY ::

Customers leave digital footprints while they are online, and online advertisers are finally beginning to capitalize – and customers are arguably seeing more relevant advertisements thus translating to improved sales. Customers are also leaving an imprint of their preferences based on locations visited, their “likes” on social media, and user reviews on product and service sites.

The gaming industry has a unique ability to create a truly 360 degree view of customers inside and outside their ecosystem. Inside their ecosystem, whether through the use of online or mobile, hotel systems, retail POS, gaming loyalty programs, facial recognition, IoT or beaconing technologies – many companies now have both the opportunity and challenge of gathering, storing and leveraging data collected from every touchpoint – during visit planning, on-site footprint, and historical preferences.

Just as airline and hospitality companies have focused on helping their customers research, plan and book their visit – the gaming industry can do more to assist with trip planning and booking their experiences (dining, shows, clubs, etc.). Today it is suggestive, but more can be done to influence the outcome if we better understood our customer. Leveraging data from outside their ecosystem is increasingly possible today too. Data is increasingly available - either acquired from a vendor or gathered organically – to understand a patron’s behaviours, patterns, and preferences outside your ecosystem. This data is extremely powerful when customizing an experience. For example, if a patron regularly dines at vegetarian restaurants and never buys coffee, don’t promote a new steakhouse or offer coffee-related comps! What can gaming resorts achieve by not only meeting the customers’ expectations, but anticipating them?

Pillar 3: Deploy the Right Operating Model In order to meet the needs of the ever-changing customer, gaming companies need to deliver a more comprehensive, consistent and seamless experience – from online to onproperty to off-property. This can prove challenging with aging technologies and organizational silos that exist within the megaresort companies.

Customers expect their service providers to offer simplicity, transparency and control; whether searching or buying online, shopping at a store, visiting their bank, dining at a restaurant or staying at a hotel. To meet this demand and facilitate this seamless experience, several industries have adopted the role of the Customer Experience Officer or “CXO.” If well executed, companies can create and ensure delivery of a consistent, unified approach to the customer across the many channels and touchpoints. This role and concept is emerging in the airline and hospitality industries as well – with some brands elevating a CXO or Chief Customer Officer, and others integrating the function across silos through a “CX Forum” governing body.

Either model facilitates discussions and decisions across the operational teams to promote seamless interactions with customers across channels. To get it right companies must set a CRM or customer experience strategy, and then clarify the roles and decision rights of not only the CXO and customer facing roles, but also extend the importance of customer centricity throughout the organization. This includes on property and back

office functions, such as Sales, Marketing, Finance, IT, and Operations - across channels of digital, phone, and face to face.

Everyone is a CXO!

Conclusion and Call to action In today’s environment, everyone in your customer ecosystem has a responsibility to deliver the customer experience. Putting these 3 pillars in place will set the right foundation and ensure everyone is a CXO. 1. Leverage digital to enhance the experience, by equipping your employees and customers with the knowledge and tools they need to guarantee an outstanding experience.

2. Design a data strategy to inform and enhance the customer experience through the collection and use of data across the ecosystem; creating a 360 view of your customer.

3. Rebalance your operating model to match the customer experience you aim to deliver. Understand your ecosystem, and your customers changing expectations and how to manage them. Ensure you have a strategy and ownership for ensuring the customer experience is consistent across the enterprise from customer-facing to back office. :: CGi

References 1. https://www.strategy-business.com/article/Winning-with-DigitalConfidence 2. http://gaming.unlv.edu/reports/NV_departments_historic.pdf

DARIN YUG & JENNIE BLUMENTHAL

Darin Yug is an advisory partner with PriceWaterhouseCoopers, LLP (PwC) and the firm’s US Gaming Sector Advisory Lead with over 25 years of industry and management and digital consulting experience for consumer industry clients including gaming, hospitality, airlines, retail (grocery, luxury, apparel & specialty). Darin specializes in advising senior executives on developing and implementing strategies to improve operations and enable growth through process, people, and digital transformation across customer facing and back-office operations including marketing, operations, supply chain, finance, IT and HR. Jennie Blumenthal is an Advisory Partner leading the Customer practice for Hospitality consulting in PwC’s Travel & Transportation group. Jennie brings 20 years of experience working with executives on business-led technology initiatives, specializing in Sales, Marketing and Digital transformations. She has helped Sales and Marketing executives of the 3 leading global hospitality and travel brands develop a Sales strategy and Customer segmentation approach, redesign the Organization model to improve Sales coverage and reach untapped potential, and designed several new sales processes and CRM / Salesforce deployments for up to 2500 person Sales teams across 4 major regions.

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PROOf THAT YOU CAN REINVENT THE WHEEL IN LIVE CASINO I

nnovation in Live Casino is alive and well. Far from resting on its laurels, one of the strongest sectors in the gaming world is showing the remarkable capability to continually reinvent itself and attract all types of players.

Amy Riches head of marketing evolution gaming

Just how far can product developers and innovators take Live Casino? Quite some distance, it would seem.

Of course, sceptics could be forgiven for thinking that there is little more that can be done with the basic Live Casino line-up of Roulette, Blackjack, Baccarat and a handful of top Poker variants. After all, one online Live Roulette is just like another online Live Roulette, isn’t it?

This perception — that Live Casino has simply become a commodity — has been fostered to a certain extent by a wave of new entrants to the Live Casino providers market in the last few years. In short, we’ve seen a lot of new names but this increasingly crowded marketplace has only been a spur to Evolution’s creative thinkers, encouraging them to venture further and on to even more fertile ground.

Innovation has been a constant at Evolution ever since the company was founded in 2006. Indeed, Product Innovation is enshrined as one of the six pillars that underpin and define the company’s Live Casino offering, alongside Operational Excellence, Customer Optimisation, Maximised Mobile, Land-based Casinos, and Regulated Markets.

All of these six pillars we see as inter-dependent fundamentals for a world-leading Live Casino offering.

At Evolution we are constantly looking to differentiate our licensees’ Live Casinos in every way possible by being forever alive to every opportunity.

In the 12 years since the day in 2006 when Evolution first

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embarked on its journey to revolutionise the nascent Live Casino market, the company has developed and launched a stream of landmark solutions and award-winning products.

Constant investment in R&D and an in-built desire to push boundaries has resulted in an innovative, ever-expanding product line and a live games portfolio that never stands still.

New game variants are regularly introduced, while existing games are constantly evolved and enriched with new, easy-to-use features and engaging Jackpots or side bets.

One of the best examples of innovation in Live Casino is our Dream Catcher money wheel game.

Introduced at last year’s ICE, Dream Catcher quickly went on to achieve strong commercial success as well as being voted Digital Product of the year at the Global Gaming Awards at G2E Las Vegas last October.

With Dream Catcher we really broke the mould of what was expected. Nobody could see this development coming, which makes its fantastic success even more pleasing.

The sheer popularity of Dream Catcher with players has been phenomenal, with the game breaking every player count record at Evolution Gaming in terms of unique players per day.

At the same time, Dream Catcher converts the highest number of new players out of all our 400-plus tables. Added to which, almost a quarter of Dream Catcher players go on to play other Evolution Live Casino games.

Most importantly, this is innovation that works commercially, not simply innovation for the sake of being new and different.

Most new games fit squarely into well-understood categories: slots, tables, virtual sports, for example. As a result, most innovations also fit this traditional mould.

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In contrast, Dream Catcher introduced a whole new category to Live Casino that can best be described as a 24/7 game show where you can play along at home or when on the move.

The idea behind Dream Catcher was to start creating more interactive games for the next generation of online players, who may not find traditional table games interesting enough, or who are looking for an alternative to slots.

Driven by the desire to create an irresistible online attraction that would expand the Live Casino space and cross-sell Live Casino into other player verticals, our product development team set to work.

Everyone is familiar with the basic concept of the spinning wheel, and the idea that if the pointer lands on the section you want, then you win.

This simple, easily understood foundation was one that we felt could be built on.

Even so, we knew that a simple money wheel had been tried and failed online already. In its simple form it was largely seen as a game with a high house edge and no ability to win big jackpots.

So while the foundation was solid and well understood, it needed a lot of work to transform the age-old money wheel concept into something that would work in today’s online world, have broadbased appeal, and that players would want to play, not just for the first time but again and again.

Dream Catcher consists of a giant wheel with 54 segments labelled 1, 2, 5, 10, 20, and 40, each paying those same odds: 1:1, 2:1 and so on through to 40:1.

To bring extra excitement and suspense into the game, the 2x and 7x multipliers were added. Then we thought, why not let players stack multipliers so they can get, say, three 7x multiplier

LIVE CASINO ::

hits in a row followed by a 40 and therefore win 13,720 (7x7x7x40) times their initial bet.

This became a clear signal to players that this game was something new and different and very exciting; players knew almost immediately what those multipliers do and that this game was worth playing.

Furthermore, Dream Catcher was the first Live Casino game to come with Autoplay functionality, which lets players repeat their selected bet for a chosen number of game rounds, so that they can enjoy playing hands-free, and while multi-tasking.

Interestingly, the Autoplay innovation, has since been introduced to our Live Roulette games, again with great success.

The Dream Catcher game was also created inside what is easily the most complex and advanced studio area Evolution Gaming has ever built.

The wheel and game events are synchronised to a variety of sounds and music which in turn is synced with a massive curved LED wall that changes colours and ‘dances’ according to game events.

This is all captured using an HD multi-camera studio set-up.

This enables players to enjoy a fully immersive live gaming experience in which the mounting excitement is relayed to their screens using a series of dynamic camera angles and close-ups, as well as simulating a slots-style experience that has never before been seen in Live Casino.

No detail was overlooked and it really shows in the quality of the game across all devices — in both portrait and landscape view on smartphone, tablet and desktop.

Of course, we took our own gamble when we decided to create a game that did not fit into traditional casino game

categories, because it runs the risk of having no obvious and natural player base to begin with.

What happened in practice is that the game attracted players from all other game types. Perhaps the most surprising subset of players that came flocking to Dream Catcher was Poker players, who, we have seen, regularly have one of their windows dedicated to Dream Catcher, hoping for those massive wins that come when the multipliers hit.

The game show hosts (dealers) play a critical role in giving the game a flavour that is totally different to any sort of traditional gambling game. They are given a lot of freedom and encouragement to engage with players, who in turn have proven to be quite chatty on Dream Catcher. Something of a community has formed around different hosts who each bring their own style to the game.

Only time will tell if the Dream Catcher approach is the start of a revolution that ushers in a whole new era of games, but the signs so far indicate that players are very responsive indeed to this style of game.

Of course, there will always be a place for games that have been thoroughly proven in the land-based sector. That’s why our extensive live games portfolio also includes an ever-growing number of exclusive games developed with our content partners Scientific Games and Games Marketing.

Our partnership with Scientific Games, meanwhile, has spawned online exclusive live dealer versions of Ultimate Texas Hold’em and Three Card Poker. This partnership has recently been extended in scope, so we will have more exclusive titles in the pipeline very soon.

Working with Games Marketing we have developed exclusive CGiMAGAZINE.COM

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online live dealer versions of Caribbean Stud Poker and Double Ball Roulette. We have also integrated their Perfect Pairs and 21+3 side bets.

Enriching and differentiating our content still further are world-first Progressive Jackpots that have been integrated within Live Caribbean Stud Poker, Live Casino Hold’em and, most recently, in our brand-new Live Texas Hold’em Bonus Poker.

Similarly, in the land-based space our Dual Play convergence solutions are a key differentiator. By offering a fully bespoke multicamera Dual Play solution we enable land-based casinos to bring together land-based and online players at the same table in a truly unique way.

Selected by numerous world-leading casinos including The Ritz London, The Hippodrome London, Genting and Grosvenor, Dual Play Roulette has quickly become the de facto standard for leading land-based casinos looking to offer their players a unique playing experience.

And this month (February 2018) we will extend our Dual Play range with the introduction of Dual Play Baccarat, with the first table going live at Grosvenor’s Victoria Casino in London.

Players ‘on-premise’ in the actual casino will be able to play at the physical table and also at the same table on their smartphones or tablets when in the bar, in The Vic’s restaurant, ‘The Dining Room’, on their journey home or, indeed, from any internetconnected location.

At the same time, all other Grosvenor registered players will be able to play at the Dual Play Baccarat table on their connected devices. Remote play at the table will be via both the Grosvenor Casinos website and the Grosvenor Live Casino app.

Additionally, ‘Dual Play Baccarat live from The Vic’ will be available to other selected Evolution licensees as a 24/7 B2B service.

After close to a dozen years of Evolution success built on this innovative approach, our teams’ enthusiasm for pushing the boundaries of Live Casino shows no signs of abating.

Evidence of this will be only too apparent at this year’s ICE, where a number of big surprises are set to be revealed on the Evolution stand.

This follows what has arguably been Evolution’s busiest ever 12 months of innovation and solution development.

Leading a line-up of multiple new products for the first quarter of 2018 is a revolutionary new game that will light up Live Casino for any operator looking for fresh, innovative ways to attract and engage online players. The exact nature of this revolutionary new game will remain under wraps until the first day of ICE, but suffice to say we are confident that this latest development will have an electrifying impact on Live Casino.

Another surprise that won’t be unveiled until the doors open at ICE 2018 on 6 February is an all-new product range. This new range is quite a departure for Evolution and has been developed to appeal to the broadest audience of players and so open up new opportunity for operators.

On the subject of player types, it’s vitally important for operators to offer innovative solutions that have appeal across the complete spectrum of players. We have always offered operators a rich choice of live games for the mass market, for VIPs and high rollers, and for devotees of games such as Baccarat and Poker.

2018 will see new and innovative solutions introduced by

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Evolution for all of these player types.

At this year’s ICE we will also premiere our new high-end VIP solution — a solution we believe is the world’s best online live Salon Privé.

Created at our primary central studio in Riga, our all-new Salon Privé is an elegant VIP environment that offers high maximum bets and the highest levels of player control at private, single-player Blackjack and Roulette tables.

Poker lovers are well catered for, too. Another new title making its debut at ICE is Evolution’s Texas Hold’em Bonus Poker, created in partnership with Games Marketing. This latest of our Poker variants is a unique online live version of Hold’em that adds optional, easy-to-play bonuses. The bonuses include an everincreasing ‘First Five’ Progressive Jackpot with an initial seed from Evolution of EUR 50,000 for the top-level Jackpot fund. As with the other Progressive Jackpot games mentioned earlier, there’s no cap on this top Jackpot prize, which keeps growing with each Jackpot side bet that is placed.

Finally, in this latest tranche of new games, we have another new title that we know will appeal to Baccarat enthusiasts. Our new No Commission Baccarat game offers exactly that — no commission to pay on a Banker win with the exception of a Banker 6, which is covered by a new Super 6 insurance side bet.

At Evolution our teams across all disciplines have worked tirelessly to build the company’s reputation for being the king of live content for gaming operators.

All players are different in their needs, and those needs can vary greatly from country to country and by demographics such as age group, gaming experience and exposure to and familiarity with digital media.

That’s why our portfolio offers the richest mix of casino classics, new and innovative products, and online exclusives.

Innovation naturally feeds into all of these games, even those that at first glance seem to be faithful online versions of well-loved land-based casino table games. It’s present in simple things, such as the way that decision-making and game speed are increased by enhancements in the user interface, for example.

Furthermore, we have our bespoke Dual Play solutions, which are now firmly established as the convergence solution of choice for leading land-based operators around the world.

Dual Play is also a stand-out product in terms of innovation, particularly in the way that the whole bespoke installation, including the number of cameras and the number, style and sequence of camera shots, can be customised to each operator’s needs and brand.

In conclusion, innovation is alive and well in Live Casino, and both land-based and online operators have a hugely exciting array of options at their disposal with which to attract and serve new and existing customers. :: CGi

AMY RICHES

Amy Riches is Head of Marketing at Evolution Gaming, a role that sees her involved across corporate and product marketing for Evolution’s world-leading Live Casino services.

JERSEY ::

SOCIAL RESPONSIBILITY, JURISdICTIONAL REPUTATION ANd dEVELOPING BUSINESS: A RECIPE fOR – WHAT? H

dr. Jason Lane Chief executive Jersey gambling Commission

ow do you drum up business as a jurisdiction when the industry in question brings historical baggage, causes some to reflect on their own sense of ethics and morality and where success brings criticism from a wide range of sources seeking to paint the jurisdiction as a bad neighbour, economic parasite and a den of criminality?

The answer I suppose is ‘carefully’. As it happens, I’m not talking about gambling. I actually mean finance, or, more specifically, wealth management and trust administration in particular. In this area Jersey has excelled and counts as one of the premier offshore finance centres in the world. The story of how Jersey has done this is widely known and easy to research, but it demonstrates that with determination to prevent crime, acting with ethics and transparency to deliver against international standards, and with government and industry working together, an extremely robust and successful industry can be established.

Located in the Bay of St Malo to the northwest of France and the largest of the Channel Islands, Jersey, since 1204, has given its allegiance to the Crown of England 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.

Are we facing a Dilemma?

And so to gambling. It’s common to read articles saying what CGiMAGAZINE.COM

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business needs or considers is best when choosing a location from which to operate and there are plenty of jurisdictions that market themselves quite legitimitely as ideal bases for this or that sector.

What this article tries to do, however, is give industry a flavour of some of the issues government and its associated agencies consider when evaluating what an individual business or a sector will bring to an economy. The gambling industry operates at a number of levels and seeks to service markets in a way that is compliant with legislation and, let us make no bones about it, provides a return to its shareholders and ultimate beneficiaries.

Nothing wrong with that of course, so long as it does so within a legal framework of local and international standards. However, should a jurisdiction seek to develop the sector as a basis for generating economic growth, job creation and revenue? This sounds like a fairly straightforward question to answer given the obvious benefits and a number of jurisdictions have done so successfully; some because of an absence of any local alternative, while others have developed the sector as a balance against overriding dependence upon other economic activity. The majority, however, have a gambling industry because their size and population create it rather than as a deliberate act of policy, and yet even in these larger jurisdictions, gambling receives a level of oversight and scrutiny that is at odds with other service industries and sectors.

Without dwelling on historical issues that most are well aware of, the main reason the gambling industry finds itself unwelcome in a jurisdiction is because of the harm, perceived and actual, that it can bring with it. Gambling is in no way unique in having the potential to create harm, but what seems to set it apart from other products has been a tendency (at least within Europe) to combine a relatively high measure of taxation with additional protections to minimise harm such as regulating the types of product allowed to be offered and having a sector specific regulatory body to provide prudential supervision. Gambling has also traditionally been something confined to domestic markets and not subject to freedom of movement, in part because of differing public policy objectives, but also because of a desire to keep domestic revenues (many of which are used to fund good causes through national lottery products) secure and undiluted.

This is a perspective that would be hard to envisage in other sectors where (unhealthy) foods, alcohols and tobacco are traded and consumed across national borders.

So what has changed to move the industry from one that was tolerated at best to now being part of the mainstream leisure sector? The answer is complex, including evolving social attitudes, a trend over the past twenty or so years towards economic liberalisation and, most importantly, the development of technology that has increasingly allowed players to access services they wish to, irrespective of national borders.

A recipe for success?

So how does a jurisdiction ensure that it provides the right balance of economic and social freedom while ensuring that gambling related harm is acknowledged and addressed? The answer is much like a theatrical performance, where each actor has to play their own part and understand their own role but crucially, also understands and can work in co-ordination with the role of others. From a jurisdictional perspective this involves government and its business development bodies, the regulator

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and also the health, education and third-sector providers who assist individuals and families experiencing difficulties caused by excessive gambling.

As noted previously, Jersey has a well developed economy, largely based on finance and has an international reputation in the field that is the envy of many of its competitors. In developing its public policy for the sector, the government has, quite rightly, sought to protect that reputation and in so doing, ensure that its core business strength is not adversely affected. Jersey has, as a consequence, undergone a quiet revolution in the field of gambling over the past ten years. Modern effective legislation has been put in place and slowly and with little fanfare, the sector has started to expand to now include remote gambling, with the Island currently hosting eight companies operating in the B2C and B2B space. This development has rightly been the focus of scrutiny by public policy advisers and the legislature, the latter enacting the statute creating the legal boundaries, with the former ensuring that the emerging industry sits firmly within a structure that conforms with international good practice and vitally, is not seen as detrimental to other established forms of business. In keeping with good governance, therefore, the Jersey administration has periodically consulted with business to ensure that growth in the gambling sector is not viewed adversely and the Economic Development Minister noted in November 2015 that this was “part of the ongoing evaluation of business initiatives and risk awareness that Jersey carries out…[and which] has resulted in the continuation of a permissive regime for

JERSEY ::

tackle given a relative paucity of specific data within Jersey and the difficulties of taking experience in other jurisdictions and seeking to apply it locally. The Gambling Commission (Jersey) Law gave the Commission a duty to ensure that ‘gambling should always be conducted responsibly and with safeguards necessary to protect children and vulnerable people’, with the actual provision of assistance is generally through the public health infrastructure, the voluntary sector and self-help groups.

Although the Commission has offered direct counselling via the services provided by ‘Gambling Therapy ’ no Islander has to date utilised the service and anecdotal evidence offered by health professionals points to gambling addiction being seen occasionally, primerily amongst clients presenting with other mental health afflictions. Funding for these type of ventures is guaranteed by gambling licensees who pay into a Social Responsibility Fund administered by the Commission and which underwrites the costs of providing information to the public and specific training, the most recent example of which was delivered in December 2017 on Motivational Interviewing and the Stages of Change for a cross-section of professionals within Health, Criminal Justice and the Third Sector. So progress is being made, but the industry would improve its position amongst its detractors if it did more to show that it is sincere about helping those who, for whatever reason, fall foul of their products.

eGaming in Jersey.”

In tandem with the legal and advisary services of government, most jurisdictions also have a business development arm and the Island is no exception , working as it does alongside the sector industry body . What makes Jersey unique, however, is the high level of regulation that business in general is required to adhere to and which ensures that casino business in particular can take reassurance that it is operating within a framework as comprehensive as possible. Given its relative small size and population , Jersey has regulated business growth for over 50 years and all businesses irrespective of sector require either their own business licence or to be operated through a managed trust company structure. All corporate gambling operators require a licence under a regime administered and supervised by the Jersey Gambling Commission, while operators of casinos in particular also report to the Jersey Financial Services Commission in respect of supervision of anti-money laundering (AML) under the Island’s AML/CFT regime . This comprehensive regulatory oversight feeds into the Island’s National Risk Assessment and the broadening of AML provisions to encompass all forms of gambling as required by the 4th AML Directive. Co-ordination of policy, co-operation and sharing of intelligence is achieved through participation in the Financial Crime Strategy Group .

So business development and regulatory oversight are well established, but this in and of itself is not enough. Crucially, social responsibility policies have not only to be present, but also effective and joined up. This has been the most difficult issue to

Conclusion It may come as a surprise to some to discover that Jersey does not fall over itself to welcome just any business seeking to establish itself in the jurisdiction. The standards are high, the benefits to the jurisdiction have to be demonstrated and considering the layers of regulation enforced it is not a suitable base for companies that do not value transparency and dialogue with the regulator. That having been said, for those companies that have made the transition, they are able to benefit from a jurisdictional base that is second to none. In considering applications for domicile, be it from companies or individuals, government will look to its core economic strengths to ensure they are not threatened; it will demand a business plan that sets out risk appetite and demonstrates how the Island’s international reputation will be protected and, in the case of the gambling industry, it will want tangible evidence of harm prevention and active involvement in strategies designed to reduce and relieve damage that can otherwise be caused. In such cases, where the needs of social responsibility, international reputation and business development are aligned, it is very much a recipe for success. :: CGi 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 Chairman of the Jersey Police Authority, a statutory body responsible for the efficiency and effectiveness of the States of Jersey Police.

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THE INdUSTRY TRENdS PREdICTEd TO HAVE A SIGNIfICANT ImPACT ON iGAmING IN 2018 T

Paul marcantonio head of Uk & Western europe eCommPay

he previous decade has seen a mass migration from land-based to online casinos, largely due to the emergence and increased penetration of new technologies, such as smart devices, through which players engage iGaming services. Annual revenues from iGaming reached €37.7 billion in 2016, and are expected to soar up to €50 billion by 2020 . The online gaming industry continues to grow steadily, with total global gross win estimated to increase by 13.2% towards the end of the current decade.1 As new market players prepared to challenge the status quo appear, introducing innovative products, technologies, and services to reach a wider audience, the established industry market grows increasingly competitive. To gain an advantage against competitors, operators focus on optimising their payment processes, striving to not only increase conversion rates, but to improve the retention of existing customers.

For operators looking to remain relevant, as well as to retain or even improve their market position, international payment service provider and bank card acquirer ECOMMPAY cannot overemphasise the importance of keeping up with both industry and payment trends.

Payments act as the direct link between merchant and consumer. Consequently, a payments strategy can make or break an aspiring business. In recent years, payment trends have focused on streamlining the payment process, improving customer experience, introducing new technological features, maximising security, keeping up with wider industry developments, and responding to incoming regulation.

Facilitating seamless transactions across multiple digital channels Across e-Commerce, from iGaming to the retail industry, the term “omnichannel” has become a buzzword. In recent years, more and

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<< Historically, keeping up with industry developments has proven to be in the best interests of operators. Responding effectively to changes and rapidly implementing new technologies attracts consumers, especially from the younger generations, who are attracted to novelty and innovation. >>

more studies have been undertaken to demonstrate the importance of facilitating a faster, more convenient user experience across multiple digital channels.

The rise of mobile greatly contributed to this trend, responding to consumer desire and demand for instant gratification. In 2010, mobile transactions as a percentage of iGaming gross win was at 11.1%. By 2016, this was up to 33.5%, with mobile transactions expected to comprise half of all iGaming payments activity in the next five years. As more players switch to using mobile devices, the iGaming content they consume must be adapted to these new parameters.

Historically, keeping up with industry developments has proven to be in the best interests of operators. Responding effectively to changes and rapidly implementing new technologies attracts consumers, especially from the younger generations, who are attracted to novelty and innovation. However, addressing consumer needs can cause operational friction as payment instruments struggle to contend with the unforeseen obstacles presented by new channels.

This friction often arises as a consequence of attempting to reconcile conversion and security. To streamline the payment process for ease and convenience, thereby boosting conversion rates, iGaming operators are often prepared to simplify established security measures. Despite the threat of fraudulent activity, many merchants feel that the benefits outweigh the risks.

Achieving synergy between the two seemingly counterintuitive processes – increasing conversion while maintaining stringent security protocols – is possible. Experienced payment service providers can advise iGaming operators, building tailored security strategies to safeguard merchant revenues while ensuring effective risk management.

By partnering with payment service providers and collaboratively establishing comprehensive payment strategies, operators can not only integrate sophisticated products to simplify the payment process both for themselves as well as the end-user, but also determine their individual fraud filters and engage dynamic 3D Secure.

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Introducing 3D Secure 2.0 In November 2014, VISA and Mastercard jointly announced that their focus would shift from the original 3D Secure to an updated protocol, 3D Secure 2.0. The latter enables operators and issuers to exchange data securely for the purposes of conducting effective risk scoring. The authentication process for the consumer, meanwhile, remains simple and straightforward.

Risk assessment occurs prior to the authentication process.

Recognising significant changes in consumer behaviour, e.g. new device, new bank card, etc., 3DS 2.0 will challenge, or require (re)authentication only from those users whose transaction variables compound to exceed acceptable risk levels.

The products, features, and technologies popular among iGaming operators will sustain their capabilities. For example, immediate payments through a single click, commonly referred to as one-click payments, will remain fast, efficient, and convenient.

3DS 2.0 will enhance the feature’s security, preserving its conversion boosting effect without risking increased fraud. Accounting for the omnichannel trend, 3DS 2.0 also offers native compatibility with mobile devices via SDK. The main benefit of the protocol for the two parties engaged in the transaction process is that neither carries liability for issues with payment security. In case of problems, the bank card issuer assumes responsibility for all transactions approved as secure.

Navigating the incoming regulation set to come into force in 2018 In 2018, two important European Union (EU) regulatory initiatives are set to come into force, forever altering the face of European eCommerce and the payments landscape. The Revised Payment Services Directive (PSD2) launched on January 13, 2018, though the grace period extends until April. The General Data Protection Regulation (GDPR), meanwhile, will become enforceable on May 25, 2018.

The two directives appear to be at odds with one another in how they tackle the question of personal consumer data. While PSD2 encourages the use of this sensitive information to engineer new, innovative technologies, GDPR protects consumer rights by

PAYmENT SOLUTIONS ::

attempting to keep confidential user data in the hands of individual consumers.

It’s important to consider how the two initiatives came into being. PSD2 was drafted to ensure cross-European payment services were safer, as well as to level the playing field between banks and non-banking institutions. GDPR replaces the Data Protection Directive, adopted in 1995, and seeks to address the new challenges arising from the rapid technological advancement in recent years.

Whereas PSD2 promotes technological innovation, encouraging data dissemination in hopes of facilitating the development of new, consumer-centric products, GDPR, in contrast, is explicit in its opposition to any personal consumer data being made available.

A potential solution to the incongruence between the two incoming regulations is to use card payments as an additional layer of player verification. The implementation of GDPR is unlikely to affect the relationship between payment service providers and their iGaming clients. However, operators must ensure that they comply with the new regulation fully, as penalties for transgression will be severe.

Fully licensed iGaming operators already comply with the existing data protection laws, so the transition to becoming GDPR compliant should not pose much difficulty. It is compliance to the pro-consumer provisions, such as “the right to be forgotten”, to which merchants should dedicate their efforts.

In regards to consumer payment data, it largely remains the

responsibility of the iGaming operators themselves. However, in instances when payment service providers offer consumer-centric technologies, such as the one-click payment feature or tokenisation for recurring payments, PCI DSS compliant providers may retain certain cardholder details.

By engaging payment technologies exclusively for verification purposes, payment service providers could comply with PSD2 while addressing the challenges posed by GDPR. ECOMMPAY is closely monitoring the regulatory changes of 2018. Two additional major pieces of legislation will determine the future of business within the United Kingdom: Open Banking (the development of an open banking platform via an API for nine of the country’s largest current account providers) and the influence of Brexit (whether or not the UK will stay in or leave the single market).

Though it’s hard to predict the outcome of either at this point in time, it’s important for both operators and their payment partners to prepare contingency plans.

Exploring payment technologies The quest to gain a competitive advantage leads to industry innovation. Market players continue to introduce new capabilities and to improve existing functionalities. As one of the fastest growing sectors of e-Commerce, iGaming contends with a number of payment challenges, which are amplified by the fact that payment operations are conducted in two directions: during deposits, when

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consumers top-up their player accounts, and during payouts, wherein players collect their winnings.

The importance of payouts cannot be overstated, and the success of any iGaming merchant depends heavily on their ability to facilitate fast, easy, transparent, and secure payout operations.

To do so, operators must partner with capable payment service providers, who have the necessary capabilities to ensure not only a quick, timely payout service, but to account for user preferences, thereby engendering consumer trust and loyalty.

Another hot topic at the moment is the rise of cryptocurrencies and their application in iGaming. When the Internet was a new phenomenon and online gaming was only just picking up speed, many experts forecasted that online casinos will displace their landbased counterparts entirely. However, this theory has not stood the test of time.

Though gaming online is appealing to the consumers short on time, going to a physical location to experience a casino environment first-hand is different. Though the prevalence of online services has affected attendance figures to land-based casinos, physical establishments continue to flourish. It is in the latter, where digital technologies, such as cryptocurrencies, may have found their iGaming niche.

Created in 2009, cryptocurrencies are a fairly recent trend, amplified over the past couple of months by Bitcoin’s dramatic rise in price. Though some cryptocurrencies are faster, more convenient, and more secure than the traditional methods of payment, others, such as Bitcoin, can take up to several days to be processed.

However, as the topic is capturing the attention and imagination of consumers, gaming operators, both digital and land-based, can take advantage of the trend to build a bridge between the payment possibilities available in both online and offline environments.

While currently experiencing extreme volatility, if cryptocurrencies enter the mainstream and undergo regulatory measures, they can begin to be introduced as a payment method for gaming customers. iGaming operators in the regions in which cryptocurrencies are accepted have begun to connect alternative payment methods to accept cryptocurrency payments online. Their land-based counterparts, meanwhile, can integrate technologies to accept those same payments online, but pertaining to an offline transaction.

By offering cryptocurrency payments, operators merge the online and offline gaming environments. As an example, the same e-Wallet containing cryptocurrency deposits could be used both while engaging in online gaming, as well as through mobile technologies within a betting shop or casino.

Pursuing new opportunities As new possibilities emerge, preferences change. The generation known as millennials, aged between 18 to 35, are a market force to be reckoned with. Though it varies by country, millennials make up roughly a quarter of the entire population. Due to sheer number, millennials are incredibly influential, and capturing the millennial mindshare is an immensely lucrative prospect.

For iGaming operators, this requires creating content to capture the imagination of these digital natives. Products and services must be adapted to appeal to younger consumers, taking into account their unique preferences. Most millennials were raised on technology, from playing video games to surfing the web.

Consequently, their expectations differ from older generations. Slot

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machines and money wheels are unlikely to interest younger consumers. Instead, iGaming operators must remain relevant by responding to the latest trends. One of the most widespread trends, which arose fairly recently, is e-Sports.

Initially, e-Sports began as an avenue for video game enthusiasts to showcase their skills to a global audience. In the last few years, however, e-Sports have grown into a multibillion-dollar business. Immediately, opportunistic entrepreneurs began analysing the emerging industry’s business potential. Monetisation through placing bets proved popular. After all, winning money while engaging in a hobby is appealing.

According to a recent study, the estimated value of the competitive video gaming market share will be USD 1.5 billion by 2020.2 As e-Sports offers two methods of engaging in speculation, through both monetary sums and virtual property (e.g. weapon skins in Counter Strike: GO), the combined market value could even surpass predictions.

As e-Sports grows in popularity, questions of regulation and the legal standing of market stakeholders arise. At present, they tend to be unregulated and unaffiliated with any of the owners of virtual items. However, it is likely that established businesses will take an active interest in e-Sports this year, with large online bookmakers entering the market. It is essential to stress, therefore, that any activities pertaining to e-Sports betting must be regulated by the same regulatory bodies and to the same standards as traditional sports betting.

Conclusion The global iGaming and payments industries continue evolving, adapting, and developing in parallel with one another. To remain relevant and competitive in a mature marketplace, iGaming operators must be flexible, responding quickly to incoming regulatory or technological changes, as well as becoming more demanding of their suppliers. Contending with the changing demands of their audience, merchants turn to proven payment partners to establish effective payment strategies, thereby retaining existing customers and attracting new players. By ensuring a streamlined, omnichannel customer journey; implementing sophisticated payment technologies; navigating incoming regulations; and exploring new business opportunities, iGaming merchants demonstrate business acumen, safeguarding the future of their operations. :: CGi References 1 http://www.igamingbusiness.com/news/igaming-dashboard-november2017 2 http://uk.businessinsider.com/esports-popularity-revenue-forecast-chart2017-3?r=US&IR=T PAUL MARCANTONIO

Paul Marcantonio is Head of UK & Western Europe at ECOMMPAY, establishing the payment service provider as a trusted partner to e-Commerce merchants throughout the region. He has over 17 years of experience working within interactive technology and online commerce, driving success for various well-known brands across the diverse landscapes of digital payments and fintech.

VIdEO GAmING ::

GAmE OVER fOR THE iGAmING SECTOR? T

he Video gaming sector is on the verge of majorly unsettling the iGaming sector and very few operators seem to be willing to pay attention to this disturbing reality. A late diagnostic is always painful, however our sector needs to react accordingly to the gravity of this huge threat.

Valéry Bollier Ceo & Co-founder oulalagames

1) How the video gaming sector is locking the current 18 – 35 age range market.

For the last couple of years the iGaming sector has been struggling to attract new young customers. With these young generations rapidly representing half of our market, the struggle is becoming a critical issue.

Most experts claim that it has always been the case throughout history and that younger generations will come to iGaming the way that people come to the opera: as they age. They may be partially correct, however they are clearly missing the new elephant in the room.

For years, the video gaming industry was unable to ''chase on our land'' because they had initially targeted the child and teenage market. However, because the video gaming industry did such an excellent job, customers never actually stopped playing their games and the average age of gamers is now 35 years in 2017 (30 in 2013). It may come as a surprise, however our young and reluctant prospective clients are already their customers.

The video gaming industry perfectly understands the expectations of the 18-35 age range market and the end of 2017 had already seen the decisive first step of the video gaming sector in our direction with the launch of a loot box system. Similar to a number of other games, Star Wars Battlefront II invites players to pay real money in order to unlock a virtual "loot box" with no knowledge of the kind of reward there is inside.

The publisher, Electronic Arts (EA), indicated that the

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<< Knowing that Rockstar, one of the market leaders in the video gaming industry, is looking in our direction, there is no doubt that the sector's next step will be to offer the only thing that they are currently not providing: a real money based kind of experience. The quality of these games will be of such a high level compared to ours that we will immediately be looked at as a has-been industry. >> "mechanics of Star Wars Battlefront II are not gambling," however the Belgian Gaming Commission is conducting investigations into how exactly players are rewarded through access to these "loot boxes."

There has almost never been a time where the gaming industry has been so discordant and in such an uproar over an issue as the debate over loot boxes, making for one of the most significant stories for the industry in 2017. With billions of dollars at stake, the issue is sensitive and precarious particularly since legislators and regulators across the globe have begun to speak up.

Chris Lee, the Hawaiian state representative, recently held a press conference where he branded loot boxes as ''predatory gaming,'' and is currently working towards a legislation that bans minors from purchasing them. He later added in a Reddit post that ''such loot boxes and micro transactions are explicitly designed to prey upon and exploit human psychology in the same way that casino games are designed.'' A regulator in the Australian state of Victoria also agrees that ''what occurs with 'loot boxes' does constitute gambling'' and that the gaming regulatory body was "engaging with interstate and international counterparts" on policy changes.

For those who are still missing the big picture, the introduction of loot boxes is the first clear attempt by the video gaming industry to directly compete with the iGaming sector.

By introducing elements of luck in their skill games, they begin to offer the best of both worlds. By doing so, they are erasing any competitive advantage that our sector could possibly offer. They are making sure that, even as they age, the customers will stick with them because they are catering to all their present and likely their future expectations.

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2) How the video gaming sector will take over of the + 35 market If most iGaming companies appear to somewhat accept the fact that the 18-35 age range market is an unreachable target, it is mostly because they are confident that they will continue to milk the +35 market cow for more years to come.

Yet, once again, the near future will prove them wrong and that this sense of security is a dangerous illusion.

Recently, Rockstar announced that GTA VI will offer an online real money poker and casino game. With GTA V being the fastest selling entertainment product in human history, this should be seen as a critical warning for the future of our industry.

If GTA VI were to disrupt the casino and the poker industry, there is no doubt that it would not be only their current 85 million customers that would start playing poker and casino in their game, but also the countless customers of ours that they would begin to attract.

If any doubt still remains, we may compare a simple number for reference: GTA V cost $280M while an average casino platform likely cost around $5M to create.

It would be absolutely unrealistic to believe that we stand a chance with our current offer. We are at least 20 years late and until we start investing a substantial amount of money towards developing our game, we will be stuck at a point that is miles away from what our customers expect from us.

Knowing that Rockstar, one of the market leaders in the video gaming industry, is looking in our direction, there is no doubt that the sector's next step will be to offer the only thing that they are currently not providing: a real money based kind of experience.

The quality of these games will be of such a high level compared to ours that we will immediately be looked at as a has-been industry.

VIdEO GAmING ::

3) The American mirage This year, the American delegation, alongside the Maltese and the Italian ones, will be the biggest delegation at ICE. Many within our sector see the evolution of the legislation in the States as another gold rush. However, the reality may prove to be very different. If the US market opens, the video gaming industry is in the perfect position to be the only winner.

According to the Entertainment Software association (ESA) 155 million Americans regularly play video games and 42% of Americans play for at least three hours per week. This is what we can easily call a captive audience! "Video games are ingrained in our culture," said ESA president and CEO Michael Gallagher.

Against a competitor that holds a massive amount of customers, power, budget, and talent, how exactly are we planning to win this war?

4) Is it too late?

It is becoming critical but our sector can still overcome this colossal challenge. If we do not want to end up like Kodak (the worldwide camera leader that died in 10 years because they refused to face the consequences of the digital revolution), our reactions needs to equal the danger:

1) Massive reinvestment in our current offer to lock our existing customers Fighting with a plastic fork when facing a fiercely armed army is not the best idea. We need to invest the same amount (50 to 300$M) in each game if we want to have a chance to win the battle.

Of course, only the industry’s big name groups will be able to react accordingly to the challenge. Their responsibility is therefore huge, particularly the networks since they are the ones structuring the offer. They need to pave the way of the sector. Knowing that it takes around three to five years to launch a top game, one could say that they urgently need to make a move.

2) Understand the needs of the younger customers and adapt our offer… to attract them Over the last four years, Oulala has trained its focus entirely on understanding the exact needs of the newer generations. In order to truly gauge their expectations, we launched our game as a free version for two years to gather data. Our portals of communication included email, forum, live chat, polls and studies. It stands to reason that if a start up such as ourselves can afford to tightly budget our way through two years with the goal of understanding customers, then bigger companies could certainly also afford to allocate a reasonable budget for the same motive.

This is what we have learned from our customers: A) They are looking for skill games.

After a childhood and teen years well spent playing fantastic skill games on their consoles, chances are one would be completely hooked on skill games. Logically, upon adulthood, one begins to cultivate the longing to play for real money. With an ever growing stake making the game increasingly exciting, one may be hard pressed to find a reason anyone would suddenly retreat to luck games instead.

The latter is an issue that sector strategists often tend to ignore. Instead, they seem to leap to the assumption that what

worked for the older generations will also work for the newer ones, thus overlooking the fact that the former were raised before the 1982 launch of the first Atari console. This would go down as a fatal error in any CTO's book.

B) They are looking for social games.

Everyone appears to be on the same page regarding this observation. Nonetheless, it is crucial that one understand that what we may want to give them is actually nothing close to what they are hoping for. We may be willing to offer social luck games because building them is easier, however they are looking for real social games, that is, a game that offers bragging rights following a victory. This is the kind of satisfaction that a game of luck cannot offer. It is for this reason that social games started out on skill games and should continue to do as such.

C) They seek optimal graphic design and gameplay.

Following 15 years of having played games costing between $50 million and $300 million to build, the level of expectation reaches a new threshold with regards to graphic design and gameplay.

5) Action plan The sector needs to accept the market reality and start offering products that fit its needs. Luckily for our industry, many young B2B companies have already begun to offer social, skill-based products that are customized for them. Daily Fantasy Sport is, of course, one of these new games, and this is why Oulala.com was launched four years ago as a fully customizable solution with API, Iframe and Turnkey to offer the most innovative DFS game in the market to iGaming operators.

Moreover, I still maintain that a number of major iGaming groups as well as a few big land based casino groups have the financial resources to fight this war and obtain the dominant position in this upcoming market. However, to win a war, you must first realize that there is one at all! :: CGi

VALÉRY BOLLIER

Valéry Bollier has nine years of experience in the media and online marketing as well as 13 years of experience within the iGaming industry. He is the shareholder and former CMO of ZEturf (20% of the French online horse racing market) and Co-founder/CEO of Oulala, the first B2B Fantasy football game based on European football. In 2016, Oulala was given the best Daily Fantasy Football Game award.

Bollier is also a private investor and a regular speaker at industry conferences and seminars, as well as a contributor to various B2B publications. He was awarded in 2016 as ''Tech ambassador of Malta'' as well as the ''iGaming Idol'' (in the category ''Data & Business Intelligence''). In 2017 he was elected the ''ICE prophet''.

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A GLOBAL ‘PARAdICE’ fOR A GLOBAL INdUSTRY K

ate Chambers, Managing Director at Clarion Gaming, looks ahead to the forthcoming ICE London and explains why comparisons with Davos are flattering.

Jamie Kean: ICE was another record breaking event in 2017.

Where do you go from that lofty position?

kate Chambers managing director Clarion gaming

Kate Chambers: Well what you don’t do is sit back, take your foot off the pedal and wallow in a sea of self-congratulations. Of course, it’s gratifying to have met the vast majority of our objectives, for ICE to have grown for the sixth consecutive year and to have delivered on behalf of our stakeholders. It’s a cliché, but in my business you are only as good as your last show and that truism means that the focus has to be on how we address those areas which didn’t go to plan, to maximise on those that did and to add to the ICE London experience. It sounds a very simplistic approach, but our job is to continually improve and enhance the experience, which starts when people register to attend online and ends when they arrive back home.

Enhancements can be macro, in terms of new features or sections, but they can also be smaller or incremental improvements. The key thing is to never stand still.

JK: What macro changes can visitors expect to experience at year’s event?

KC: The most tangible are the addition of new sections for Payments and the Consumer Protection Zone, both of which are firsts for ICE London.

The ICE Payment Solutions Section, comprising 4,000sqm of space, will provide a focal point for international visitors wanting

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to meet and engage with the key innovators and thought leaders in the sector. The purpose of ICE is to showcase and reflect the dominant trends in gaming and payments is a case in point. We were approached by a number of leading players wanting to utilise ICE as a platform to reflect these innovations and to create a meeting point for all those international visitors with an interest in the latest technologies and advances. I am delighted that we have been able to respond to the needs of the industry in this way and I am confident the resource that we are putting behind the ICE Payment Solutions Section will be well received by visitors.

We will also be promoting the social responsibility message with the launch of the Consumer Protection Zone. The Zone will provide a focus for the social responsibility message and feature key organisations that are promoting social responsibility, as well as being a platform for presentations. The Zone is the latest in a series of social responsibility initiatives undertaken by Clarion Gaming, which includes the annual World Regulatory Briefing on Responsible Gambling Innovation, held in London in the Autumn, and the Responsible Gaming Academy training, run by the Totally Gaming Academy.

Wherever Clarion operates, social responsibility is one of the most important topics and that’s across both emergent and mature gaming markets. Although we are not part of the

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operating community, I believe strongly that we also have a responsibility to serve as a forum for discussion and knowledge exchange.

We will be creating an agenda with demos and presentations from regulators, providers and operators. We also hope to bring government officials, policy-makers and regulators to the Zone as part of the World Regulatory Assembly (WrA) and International Legislators’ Day programme. The industry has made important headway in helping to make gambling an entertainment experience, as opposed to a negative or destructive one, and there have been some really significant technology-driven advances in the fields of responsible gambling using data analytics. It’s totally appropriate that these are showcased at ICE London.

JK: I can see you have a record 43,500sqm of net space at this years event – what does this growth mean to the industry?

KC: We have been very careful to grow ICE at a manageable pace and avoid the boom bust scenario you might associate with an overheating economy. While ICE 2018 is nearly twice the size of the 2012 edition, which was the last held at Earls Court, a lot of that growth has been facilitated by the move to ExCeL London

EVENT SPOTLIGHT ::

and our ability to meet the needs of exhibitors. Our strategy, wherever we operate in the world, is to work with the industry to create events and opportunities that help meet business objectives. The expansion of ICE has been driven by demand and reflects the dynamics of the international market, which views London as the once-in-the-year opportunity to engage with a really significant and influential community of buyers and influencers, which in 2017 travelled to ICE from 151 jurisdictions.

This is great news for gaming organisations who we know want a flagship event that showcases the world’s leading innovators from every gaming vertical. Gaming is a global industry and ICE is its global event.

JK: You have announced the launch of ICE Africa: can you explain your thinking?

KC: Our strategy has always been to partner with the industry and that’s exactly what we have done in Africa. After a successful experience on the continent, where we tested the water with our Gaming Africa event, we took the strategic decision to fast track our presence, transitioning the 2018 event into the first ICE Africa, which will comprise an exhibition and co-located ICE VOX style conference dedicated to the development of the domestic industry. Whilst the scale of ICE Africa will not be the same as ICE London, we will be bringing the same level of commitment, thinking, creativity and professionalism that has made ICE London the world’s favourite and most international gaming expo. ICE Africa will be an event where the industry can meet, network, see the very latest gaming innovations, share best practice and progress in a strategic and sustainable manner. The ICE Africa team is already in place and working with our stakeholders in order to deliver on our pledge to create a world class business event for the continent. Every business decision such as this comes with its own risks, but we have to be prepared to be bold and to act decisively. The industry is behind us and I’m confident that, providing we remain true to our brand vision and principles, ICE Africa will be a success.

JK: Someone described ICE as the Davos of gaming – do you recognise that description?

KC: I think it’s a very flattering description. Davos brings together the most influential economic and political leaders in the world.

ICE London does a similar thing in so far as we host international gaming regulators, industry thought leaders, the CEOs of every major international gaming organisation, elected politicians and the vast majority of trade associations drawn from every continent. When an event develops momentum, these type of credentials start to come to the fore. If observers choose to refer to ICE London as the Davos of gaming, I’m certainly not going to object!

a way that stakeholders can feel proud of. Stakeholders already use ICE to showcase the credentials of the industry to a broad audience and we will always work to accommodate any initiatives they want to progress.

JK: You launched your Ampersand Think Tank initiative at G2E Las Vegas. Why there and, more importantly, what is Ampersand?

KC: We actually undertook a soft launch at our WrB Responsible Gambling Innovation event held in London in September. G2E gave us the opportunity to introduce it to an influential gaming audience and to generate some interest and traction ahead of ICE London. The aim is to make Ampersand the biggest think tank in gaming, comprising a representative cross-section of industry verticals, jurisdictions, job functions and channels. I envisage Ampersand working on a number of levels. It will enable us to validate ideas and concepts prior to launch, it will introduce a process and structure for customers to provide their feedback – both positive and negative – and it will enable the industry to make suggestions on how we can work more effectively to help in the development of sustainable gaming economies, particularly in emergent markets. We are always keen to explore new formats favoured by the industry and to receive suggestions for great new speakers and Ampersand will provide swift and direct access to the decision making process. It delivers a valuable opportunity to help shape event content. Industry professionals who agree to participate in Ampersand will receive a number of benefits in recognition of their time, including entry to The Lounge at ICE London, as well as access to intelligence reports and surveys produced by the team at Clarion Gaming.

JK: How do you think Clarion Gaming is viewed within the broader Clarion family?

KC: Clarion Gaming is an important part of the Clarion Events business comprising exhibitions, conferences, technical training as well digital and print information. Our events attract more than 50,000 customers annually in locations spanning every continent and, with ICE London, we have created the world’s most influential and international meeting place for the entire industry.

The Clarion Gaming team has earned the respect of the other divisions within Clarion all of whom will take the opportunity to spend some time with us at ExCeL London in February. :: CGi

JK: If ICE is the shop window for gaming, do you think it could have a bigger role in helping to shape the opinion of regulators and legislators?

KC: That’s not really for me to say. My job, and that of my team, is to deliver a 360 degree take on the international gaming industry and to present it in an ultra-professional manner and in

KATE CHAMBERS

Kate Chambers is Managing Director of Clarion Gaming

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SOCIAL RESPONSIBILITY, PLAYER PROTECTION, ANd HARm mINImISATION: HOW ARE ONLINE GAmBLING OPERATORS dOING? T

he number of people gambling online has steadily increased over the last 15 years. Concern has been raised about online gambling especially with regards to specific issues that are associated with this activity including availability, accessibility, anonymity, dissociation and disinhibition (Griffiths, 2003; McCormack & Griffiths, 2013). Online gambling has also been perceived as a safer and more acceptable gambling by specific groups of people such as female gamblers as the online environment is gender-neutral (Griffiths, 2001; Corney & Davis, 2010). Other positive aspects include the fact that the virtual environment can provide short-term comfort, fun and/or excitement and a haven for distraction (Kuss & Griffiths, 2012; Reith, 2007).

dr. mark Griffiths & maris Bonello nottingham trent University

Research has also demonstrated that problem gamblers are more likely to gamble online (Kuss & Griffiths, 2012). However, because of the way that online companies can collect data on their clientele via behavioural tracking, internet gambling may in turn offer possibilities for utilizing responsible gambling (RG) tools (e.g., temporary self-exclusions, personalized behavioural feedback, limit setting tools, pop-up reminders, etc.) that might be difficult in a land-based setting unless player cards are used to track the totality of a gambler’s behaviour (Wood & Griffiths, 2014).

The regulation of gambling has always been concerned with its social risks with a primary role of consumer protection (Vileneuve, 2010). Consumer protection is also something that concerns online gambling operators in a commercial manner to protect the company’s brand (Carran, 2013). This has resulted in a topic of great interest in how to engage corporate social responsibility in controversial activities such as online

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<< The main concern in our ď&#x20AC; ndings was what happened after we informed customer services that we may have a gambling problem. Despite having disclosed this information, 26% of the gambling operators still sent promotional and marketing communication. >> gambling (Cai, et al., 2012). In order to provide safe environments for gamblers (both online and offline), policies need be based on a tripartite model that includes the government, the gambling operators, and those advocating individual harm minimisation (Blaszczynski, et al., 2011).

Responsible gambling refers to a duty of care including consumer education, playing within limits, information to allow informed choice that includes resources for help, information about games, and information to combat misconceptions and gambling fallacies (Blaszczynski, et al., 2011).

Research examining the RG practices used by gambling operators has been relatively sparse. One of the first studies

by Smeaton and Griffiths (2004) examined the RG practices of 30 UK-owned online gambling websites. The results (based on data collected in 2003) showed that there was a lack of RG initiatives at the time. Arguably, online gambling needs more consideration, because in this field of study, geographical boundaries become non-existent and technology may facilitate competition between the gambling providers and regulators (Vileneuve, 2010), although this might put off some gamblers because the gambling provider is not locally licensed. This lack of geographical boundary and the lack of a strong regulation of online gambling has led to third-party organisations attempting to identify what consumer protection practices are available and what RG practices should be ensured (Gainsbury, et al., 2013).

More recently, Wiebe and Philander (2012) reviewed RG practices of internet gambling sites. The results were collected via a literature review, an evaluation of 50 online gambling sites, and player interviews. They found that monetary limitsetting tools are generally positively viewed because they encourage gamblers to reflect on the amount of time they spend gambling. However, usage is often low because operators are falling short of properly promoting the tools.

They found deposit limits to be most common on online gambling sites.

Due to the relative lack of research on the topic, we recently carried out a study (i.e., Bonello & Griffiths, 2017) examining the RG practices concerning 50 of the worldâ&#x20AC;&#x2122;s

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biggest online gambling operators. Each online gambling operatorâ&#x20AC;&#x2122;s website was examined in further detail by checking for a wide range of RG practices including whether the operator provided (i) dedicated RG page, (ii) warning(s) that gambling can be harmful, (iii) reference or referral to a problem gambling help organisation and/or self-help groups, (iv) a self-assessment test for problem gambling, (v) information about the RG tools offered by the operator, (vi) links to gambling filtering software such as GamBlock and/or Betfilter, (vii) initial age checks during the account registration phase, and (viii) availability RG tools (e.g., limit setting facilities, cooling off periods, self-exclusion periods, etc.)

Of the 50 online gambling operators, all had a statement on their commitment to RG and all had a warning that gambling could be harmful. Most operators referenced an organisation where players could get help for a gambling problem (84%), and approximately two-thirds of the gambling operators displayed a self-assessment test for problem gambling (64%). Many of the operators displayed information about the RG tools that they offered on their website (84%).

A large majority of the operators displayed commercial promotion on the RG page (88%). Approximately two-thirds of the gambling operators mentioned or provided links to gambling filtering software to block access from online gambling websites (60%).

When gamblers registered for an account with an online gambling operator, approximately two-thirds of them had prominently displayed that the gambling service provided is for individuals who are 18 years of age or above (68%). In no instance were registrants required to provide any identity documents that they were 18 years of age or over (i.e., no age verification checks were carried out by any of the 50 gambling operators).

Most operators had RG tools such as at least one type of limit-setting (such as deposit limits, spending money limits, spending time limits, and loss limits: 90%), a cooling-off period (such as daily, weekly, or monthly breaks: 72%), and voluntary self-exclusion (exclusion from the site for six months or more: 86%). In some cases, self-exclusion was not immediate. For instance, 12 operators mentioned that in order to self-exclude,

SOCIAL RESPONSIBILITY ::

the gambler had to contact customer services and/or fill in a form to send via email (24%). In some cases, the information about the RG tools was not encouraging RG practice. For example, in one instance, the following sentence was present when accessing the self-exclusion option: “Customers who block their account will no longer be able to deposit funds into their account or take advantage of our offers.”

We also assessed how RG-oriented the online gambling operators were by contacting customer service representatives. More specifically, all 50 online gambling operators were asked if they had any information on how we could control our gambling. Customer services were also informed that we felt our gambling was becoming an addiction and that we could not control our gambling. These issues were explored via live chat or via email correspondence (if there was no live chat facility).

Almost three-quarters of the operators’ customer services offered the option of live chat (70%), with the remaining operators being contacted via email (30%). With regards to controlling gambling, 30 out of 35 operators on the live chat facility (86%) suggested or provided links to limit setting information. When they were informed that we may be addicted to gambling, 17 operators of the 35 operators (49%) suggested an RG measure including checking information on RG, voluntary self-exclusion, and doing a problem gambling self-assessment test. Eight of the 35 gambling operators (23%) performed a specific action (e.g., closing of the account). Ten operators of the 35 engaged in bad practice (29%). In three cases, the information given was irrelevant for someone who was going through a problem. In six cases, the remark was completely ignored and the online interaction was ceased by the gambling operator. In one case, a bonus was offered to us to continue gambling. After the live online chat interaction, seven operators contacted us with more information about RG tools via email, while six of the operators closed the account.

For the other 15 operators where emails were sent informing them of a possible gambling problem, six of them closed the account, five gave generic information about RG tools, and four operators did not provide a reply – just an acknowledgement of the email sent. The number of gambling operators that allowed access to the account after the information about having a possible gambling addiction was given to the customer service representative was also recorded. Over half of the operators still allowed account access to the gambling account (56%) whereas the remainder did not (44%).

Overall, our findings demonstrated that RG information is consistent across most of the online gambling operators examined. An area that appeared to be consistent with most of the gambling operators was the information available in the designated RG page. This page contained information about the operator’s commitment to RG, a warning that gambling can be harmful, and a reference to a problem gambling help organisation. The self-assessment test for problem gambling was present in nearly two-thirds of the operators’ RG page (64%). However, among 88% of the gambling operators examined, there was some type of commercial advertisement (typically promoting some type of bonus) on the RG page.

Another area that seemingly needs improvement is age verification of the registered players. The only evidence that the gambling operators took age restriction seriously was in providing a message upon registration that players needed to be aged over 18 years to gamble. In our study it was difficult to determine whether an age verification check had been carried out by the operator because age verification can take a variety of forms without the knowledge of the consumer, such as cross-referencing the customer details with official data sources.

The main concern in our findings was what happened after we informed customer services that we may have a gambling problem. Despite having disclosed this information, 26% of the gambling operators still sent promotional and marketing communication. Although the percentage was modest, the impact of sending marketing communication to a consumer who specifically tells the gambling operator that they have a gambling problem may have an increased negative impact on the individual.

One RG tool that appears to be popular amongst gamblers is the temporary self-exclusion option, where consumers can choose to temporarily remove access to their online gambling account. In research by Griffiths, et al. (2009), 46% of their participants (in over 2500 online gamblers) reported that the 7-day self-exclusion was a useful RG tool. This was followed by the 1-month self-exclusion, and the daily self-exclusion option. Among the 50 online operators evaluated in the present study, 72% of the operators had an option for a selfexclusion that was less than six months, and 86% offered six-month self-exclusion. Online self-exclusion has its advantages when compared to land-based self-exclusion as it only requires a few clicks with low access barriers (Hayer & Meyer, 2011), and when provided online. More importance should be given in order to make sure that all online operators provide such an important and popular RG tool.

Although our study was beneficial in examining which RG initiatives are being offered across different online operators, it had a number of limitations. The main shortcomings were that only a limited number of online gambling websites were examined (n=50) and that RG-oriented communication was based on only one customer service interaction. While some online gambling operators appear to be socially responsible, there are a number of areas where further improvement is needed (e.g., age verification, customer service feedback, direct marketing to players).

Based on our findings as well as those of others, we would argue that RG practices are critical in order to ensure consumer protection. Thus, a strategic framework is needed to establish responsible gambling oriented policies based on empirical studies that in turn will reduce any possible sociopolitical influences (Blaszczynski, et al., 2004). This is also in the interest of the gaming operators because a lack in trust and credibility will in turn create a commercial disadvantage in the long-term (Wood & Griffiths, 2008).

References Blaszczynski, A., Collins, P., Fong, D., Ladouceur, R., Nower, L., Shaffer, H. J., & Venisse, J. L. (2011). Responsible gambling: General principles and minimal requirements. Journal of Gambling Studies, 27(4), 565-573.

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Blaszczynski, A., Ladouceur, R., & Shaffer, H. J. (2004). A science-based framework for responsible gambling: The Reno model. Journal of Gambling Studies, 20(3), 301-317.

Bonello, M. & Griffiths, M. D. (2017). Analysing consumer protection for gamblers across different online gambling operators: A descriptive study.

Gaming Law Review and Economics, 21, 278-285.

Cai, Y., Jo, H., & Pan, C. (2012). Doing well while doing bad? CSR in controversial industry sectors. Journal of Business Ethics, 108(4), 467480.

Carran, M. (2013). Minors and gambling regulation. European Journal of Risk Regulation, 4(4), 509-520 Corney, R., & Davis, J. (2010). The attractions and risks of Internet gambling for women: A qualitative study. Journal of Gambling Issues, 121-139.

Vileneuve, J. P. (2010). Gambling regulation and risk. European Journal of Risk Regulation, 1(4), 415-418.

Wiebe, J., & Philander, K. (2012). Monetary limit tools for internet gamblers. A review of their availability, implementation and effectiveness online. Ontario: Ontario Problem Gambling Research.

Wood, R. T. A. & Griffiths. M. D. (2008). Why Swedish people play online poker and factors that can increase or decrease trust in poker websites: A qualitative investigation. Journal of Gambling Issues, 21, 80-97.

Wood, R. T. A., Shorter, G. W., & Griffiths, M. D. (2014). Rating the suitability of responsible gambling features for specific game types: A resource for optimizing responsible gambling strategy. International Journal of Mental Health and Addiction, 12(1), 94-112.

Gainsbury, S., Parke, J., & Suhonen, N. (2013). Consumer attitudes towards Internet gambling: Perceptions of responsible gambling policies, consumer protection, and regulation of online gambling sites. Computers in Human Behavior, 29(1), 235-245.

Griffiths, M. D. (2003). Internet gambling: Issues, concerns and recommendations. CyberPsychology and Behavior, 6, 557-568.

Griffiths, M. D. (2001). Internet gambling: Preliminary results of the first UK prevalence study, Journal of Gambling Issues, 5. Retrieved January 10, 2018 from: http://jgi.camh.net/index.php/jgi/article/view/3590/3550 Griffiths, M. D., Wood, R. T., & Parke, J. (2009). Social responsibility tools in online gambling: A survey of attitudes and behavior among internet gamblers. CyberPsychology and Behavior, 12(4), 413-421.

Hayer, T., & Meyer, G. (2011). Internet self-exclusion: Characteristics of self-excluded gamblers and preliminary evidence for its effectiveness.

International Journal of Mental Health and Addiction, 9(3), 296-307.

Kuss, D. J. & Griffiths, M. D. (2012). Internet gambling behavior. In Z. Yan (Ed.), Encyclopedia of Cyber Behavior (pp.735-753). Pennsylvania: IGI Global.

McCormack, A., & Griffiths, M. D. (2013). A scoping study of the structural and situational characteristics of internet gambling. International Journal of Cyber Behavior, Psychology and Learning, 3(1), 29-49.

Reith, G. (2007). Gambling and the contradictions of consumption: A genealogy of the “pathological” subject. American Behavioral Scientist, 51(1), 33-55.

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).

Smeaton, M., & Griffiths, M. (2004). Internet gambling and social responsibility: An exploratory study. CyberPsychology and Behavior, 7(1), 49-57.

Maris Bonello is an integrity analytics manager at Kindred Group Plc in Gzira, Malta, and a doctoral research student of Professor Griffiths at Nottingham Trent University (UK).

Monaghan, S. M. & Blaszczynski, A. (2009). Electronic gaming machine warning messages: information versus self-evaluation. Journal of Psychology: Interdisciplinary and Applied, 144 (1), 83-96

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