Casino & Gaming International: Issue 34 by Casino & Gaming International

2018 ISSUE 34

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2018

PUBLISHER’S NOTE ::

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

ith a busy FIFA World Cup summer behind us and an event heavy

Autumn ahead of us, we are delighted to be joined in this edition

by some of our regular contributors, along with some new faces

who we welcome to CGi for the ﬁrst time.

Julian Harris and Melanie Ellis (Harris Hagan) start proceedings by discussing

the latest compliance and licensing issues the industry is facing, Simon Airey

and Joshua Domb (Paul Hastings) join us for the ﬁrst time and examine the UK

Governments stance on problem gambling and how they are trying to address it

whilst Michael Harris and Katrina Jones (LexisNexis® Risk Solutions) take a look

Circulation Manager Natasha Harvey nharvey@cgimagazine.com

at why operators should be paying attention to high rollers’ source of wealth.

Commercial Director Daniel Lewis dlewis@cgimagazine.com

Paul Brennecker (Security Risk Management) returns to discuss the implications

Account Manager Nathan Charles ncharles@cgimagazine.com

Editorial Contributors Julian Harris, Melanie Ellis, Simon Airey, Joshua Domb, Michael Harris, Katrina Jones, Paul Brennecker, David McDowell, David Ruggeri, Anthony Ure, Korbi Carrison, Allie Barth, Mark Griffiths, Elizabeth Killick

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the General Data Protection Regulation may have on the gambling industry and

explains how it is not simply a compliance exercise but an industry-wide altered

mind-set that is the key to eﬀective data security.

David McDowell (FSB) oﬀers his expertise on the US Sports Betting market and

how he sees it playing out, whilst David Ruggeri (BtoBet Sports) takes a look at

player experience and the importance of the user interface.

Anthony Ure (Isle of Man Department for Enterprise) gives us his eGaming

forecast for the remainder of 2018, we talk to Korbi Carrison & Allie Barth

(Global Gaming Expo (G2E) / American Gaming Association) about the upcoming

G2E show in Vegas and ﬁnally, Dr. Mark Griﬃths and Elizabeth Killick

(Nottingham Trent University) give us a brief overview of the psychology of

in-play sports betting.

Jamie Kean, Publisher The next edition (Issue 35) of CGi will be published on 1st November 2018.

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FeAtures ::

FEATURES 7

Preserving the balance between liberty and regulation

betting on More regulation

high rollers and higher stakes: why oPerators Must Pay attention to custoMer sources of wealth

Julian harris & Melanie ellis, harris hagan

simon airey & Joshua domb, Paul hastings

Michael harris & katrina Jones, lexisnexisÂŽ risk solutions

gdPr and data security in the gaMbling industry

how euroPean technology and new business Models will shaPe the us sPorts betting Market

Paul brennecker, security risk Management (srM)

david Mcdowell, fsb technology

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FEATURES ::

FEATURES 29

SPORTSBETTING: THE WAY FORWARD FOR A UNIQUE PLAYER EXPERIENCE Davide Ruggeri, BtoBet Sports

EGAMING: TRENDS AND PREDICTIONS FOR THE REST OF 2018

G2E: LOOKING AHEAD AND BUILDING ON PREVIOUS SUCCESSES

Anthony Ure, Isle of Man Department for Enterprise

Interview with Korbi Carrison & Allie Barth, Global Gaming Expo (G2E)

THE PSYCHOLOGY OF IN-PLAY SPORTS BETTING: A BRIEF OVERVIEW Mark D. Griï¬&#x192;ths & Elizabeth A. Killick, Nottingham Trent University

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PreserviNG the bAlANce betweeN libertY ANd reGulAtioN O

Julian Harris

n 28 June the Gambling Commission published a report into the enforcement action it has taken over the past year: “Raising standards for consumers, Enforcement report 2017-18”. In this report the Commission highlights the lessons it wants the industry to learn from its investigations, and provides helpful and timely guidance to gambling businesses on anti-money laundering, customer interaction, self-exclusion, unfair terms and practices and marketing and advertising. These are all areas in which some gambling businesses have been slow to understand that regulatory action does not just happen to others.

Julian harris & Melanie ellis harris hagan

So far, so good. However, in the Commission’s announcement of the publication of the report, its recently appointed chief Executive, Neil McArthur, also said this: “We also want gambling businesses to collaborate and to invest the same amount of resources into data, technology and research into building better protections for consumers, as they do to creating new products, or advertising and marketing campaigns.” It may be that he simply meant “a proportionate amount”. The number of staff and the amount of money spent by the whole of the gambling industry, which is what is contemplated in this statement is vast, running into hundreds of millions per year. It defies all logic to suggest that any industry would or could spend the same amount on consumer protection. Indeed, other potentially harmful industries such as the tobacco industry and alcohol industry, whilst – like gambling- they pay vast amounts of tax much of which no doubt goes indirectly to the NHS, are not called upon to spend their own profits on research and prevention of the harms caused by their products. Interestingly, in 2013 the BMJ decided it will no longer publish CGiMAGAZINE.COM

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<< The costs of compliance and licensing in Great Britain is already high. Companies can only absorb so much cost before it becomes imperative to pass on additional cost to the consumer. >> research conducted by the tobacco industry due to the risk of biased results. Whilst there is no reason to believe that research into problem gambling funded by the gambling industry would be inaccurate, equally it is worth considering whether “data, technology and research into building better protections for consumers” would be more suitably funded and carried out by an independent body. If the industry were to devote the same amount of resources to consumer protection, aside from asking where this money would come from in the first place, one has to ask what would the consequence be? The costs of compliance and licensing in Great Britain is already high. Companies can only absorb so much cost before it becomes imperative to pass on additional cost to the consumer. And consumers will generally look for the best bargains. We have only to look to other industries to see the truth of that statement: in grocery, the rise of Aldi and Lidl at the expense of Marks & Spencer and Waitrose; in travel the desperate shift downmarket by many national airlines to compete with low-cost carriers; or the loss of well known names from the high street to the mighty Amazon. The same applies in gambling. There are plenty of supplier choices for consumers, many of which do not enjoy the benefits, or the associated costs, of holding a licence from the Gambling Commission: illegal bookies, gambling dens, poker “clubs”, and of course many thousands of online gambling websites in unregulated, or at least inadequate regulated, jurisdictions. It is worth remembering that in the early days of online gambling, many gambling operators with household names thought that they had an immediate advantage in this nascent business. They quickly discovered their mistake. The only factors consumers were interested in were (a) whether they would get paid if they won, and (b) who offered the best value for money: the name was irrelevant. In the same way, consumers are unlikely to choose their supplier because one company has a better consumer protection policy than the other. Last year in CGI, we questioned the influences on the Commission. In an earlier edition we questioned why the Commission had never apparently, so far as we know, advised the Government to address some of the unfair anomalies that unduly prejudice pre-Gambling Act 2005 casinos. The point here is that the Commission, at least sometimes, gives the impression that it has unrealistic expectations, suggesting a misunderstanding of the commercial world. Meanwhile, the Commission’s Business Plan for 2018-2019 cites as one of its five key priorities “protecting the interests of

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consumers” and another as “raising standards in the gambling market”. These go a lot further than the licensing objectives. It is one thing to ensure that the provision of gambling is fair and safe; quite another to set up as the consumers’ champion, which necessarily involves taking sides. Notably, unlike some other gambling regulators, the Commission is not responsible for investigating and adjudicating on customer disputes and its remit does not extend to taking up individual consumer complaints against gambling businesses. Moreover, raising standards implies that they are insuﬃciently high. This is a subjective point, and again is a judgement call. The regulator does not say to what level standards should be raised and probably never will, but the implication in this phrase is that the industry’s standards are always insuﬃciently high to meet the standard required.

Illegal Gambling It is worthy of note that in its Business Plan the Commission says nothing at all about unlicensed gambling, better expressed as illegal gambling. In its Enforcement Report, after dedicating twenty pages to discussing enforcement action against licensed operators in the areas of AML, social responsibility, unfair practices and marketing, we find one paragraph plus one case study about action taken against those operating in Great Britain without holding the appropriate licence. That case, against the operators of the Futgalaxy website, involved the significant aggravating factor that a complaint was received from the parents of a fourteen year old child who had gambled on the website. It is not apparent from the Enforcement Report what action (other than the Futgalaxy case) has been taken against operators of unlicensed sites targeting adults in Great Britain, other than a reference to “typically sending cease and desist letters”. The document sets out figures which show that enforcement action against unlicensed operators is increasing – action was taken against 40 operators in 2015, 57 in 2016 and 61 in 2017. Unfortunately, there are no further details on the action taken, nor is it clear how many of these were the aforementioned cease and desist letters, on how many occasions the letters were effective at closing down illegal operations and whether in any cases further action was taken. Arguably, ensuring that all those carrying out licensable activities are appropriately licensed should be the first priority of any regulator and it is surprising that these figures are tucked away at the very end of the report. This is not just a matter of fairness to licensed operators; for a system of regulation to work, operators must have a good incentive to become regulated, which effectively means they need to be prevented from accessing the

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market without becoming regulated, or subject to severe penalty if they do access it. Further, as the standards and costs of regulation become higher, the incentive to access the market illegally also increases. The increasing figures for action against unlicensed operators may reflect the increasing burden of regulation – for more operators perhaps it is becoming less attractive to be regulated and more attractive to operate outside the law. The regulator needs to get the balance right. If the standards and costs of regulation are too high, more operators will seek to access the market illegally and they will have a competitive edge. We are concerned that the scales may now have tipped too far in one direction. With seven figure penalties for making mistakes and the expectation that operators will invest as much into protecting consumers as into building products and marketing, for some the potential costs will price them out of the licensed market. What is more, the lower cost base for unlicensed operators will enable them to offer far more attractive odds and incentives than their licensed competitors. The Commission has wide powers of prosecution. The industry pays a high price for the privilege of being licensed and deserves protection from unfair competition. The consumer deserves to have his or her interests protected and it is in this last regard that the Commission’s efforts need to be concentrated if it truly wishes to protect the consumer. So when Bill Moyes, the Chairman of the Commission, states that the final priority for the current year is “to improve the way we regulate”, we would suggest some more focus on those that flout, not just the word of the Commission, but the letter of the law as well.

The Regulator’s Role No-one would seek to excuse licensees who fail in important areas like age veriﬁcation, AML checks, who, for example, seek to mislead consumers with erroneous terms and conditions or who fail to return their money when requested. But the regulator needs to remember that its role is precisely that; to regulate gambling in accordance with its statutory duty. Regulators should necessarily be impartial, fair and reasonable. The regulator’s role is not to promote itself as a consumer watchdog, or as a selfpromoting interest group. The Commission has powers that involve it making semi-judicial decisions about the industry and the people who work in it: in that regard they must be as Caesar’s wife – beyond reproach. “Under the headline “Gambling Commission makes online gambling fairer and safer”, in March 2018 the Commission announced the publication of its review of online gambling (http://www.gamblingcommission.gov.uk/news-action-andstatistics/news/2018/Gambling-Commission-makes-online-gambl ing-safer.aspx). Neil McArthur, the recently appointed Chief Executive, announced proposals “to protect children better, reduce the risks to vulnerable consumers and build on the measures we already impose on operators to know their customers and intervene at an earlier stage before consumers experience harm.” The Commission has very wide regulatory powers, and a duty to promote the licensing objectives; these include the duty to ensure that gambling is conducted fairly and safely and to protect children and the vulnerable. In pursuit of these laudable aims the Commission can do anything it likes, after due consultation. Its

“motto” – making gambling fairer and safer – could in theory be used as a justification for almost any measure, however costly, difficult, impracticable or disproportionate. The Commission’s findings were based once again on surveys conducted, inter alia, by Ipsos-Mori, who have so spectacularly failed to assess voting intentions in the last two general elections and in the EU referendum: this is the subject covered in our previous article “Worrying influences on the Gambling Commission” publishes in the Q3 edition in 2017. What these surveys actually demonstrate is that the incidence of dysfunctional gambling remains at the roughly the same level as before online gambling was invented: a level which is one of the lowest in the world. In pursuit of the intention expressed by the Chief Executive, the measures proposed by the Commission include: • Banning operators from providing free-to-play demo games until a customer’s age has been determined; and • Limits on customers’ spending until affordability checks have been conducted. In addition, the Commission is going to consider further measures to enable consumers to manage their gambling, review product characteristics to see if certain features pose greater harm and whether credit cards will continue to be permitted. The upshot is that the provision of gambling will be further restricted. On the face of it, this sounds sensible. However, one has to ask where this might lead in the longer term. The Commission’s constant trumpeting of its desire to make gambling ever fairer and safer could lead eventually to gambling being so bogged down in an ever thickening mud of restrictions and onerous procedures that it will be impossible to operate commercially, and in any event too burdensome, invasive and boring for the consumer to enjoy. Take the issue of concern about children and young people. They can play category D machines at any age and they can participate in the National Lottery from the age of 16. But the Commission is concerned that, despite the fact that free-to-play games are not gambling – they are free and there is no prize – they “may” encourage young people to gamble. The Commission’s concern even extends to “gambling-style” games offered by non-gambling operators, who are not therefore subject to regulation. Nevertheless, the Commission believe that these operators should provide greater protection. As for adults, even they are not to be trusted to make their own decisions. Who is to judge how much of their (legitimately earned) funds adults should or should not spend on gambling products? Such an idea demonstrates an unacceptably paternalistic approach to what ought to be private lifestyle choices, not to say an unacceptable invasion of privacy. It seems to be a growing trend, reminiscent of late Victorian puritan prurience to seek to direct every aspect of our lives for our own good. It is a retrograde development. Back in 1978 the Royal Commission on Gambling captured the idea that gambling is somehow a feature of the morally worthless: “The objection that punters are wasting their time is a moral or possibly an aesthetic judgement. As it happens, none of us is attracted by the idea of spending an afternoon in a betting office. But the people who frequent betting offices have chosen to enjoy themselves in their own way and we think that in a free society it would be wrong to prevent them from doing so merely because

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good product, but that product must offer good value to customers. If licensed gambling operators are expected to spend as much on researching and building consumer protection measures as they do on advertising, they will unfortunately be faced with a stark choice if they want to remain in business. They could reduce advertising spend, with the result that their customers go to more heavily advertised sites. Or they could offer worse odds in order to make a higher profit margin per stake, again with the result that their customers go elsewhere. Neither of these options will keep them in business for long. The third option is to resist as far as possible the Commission’s demands, to the extent that doing so does not risk regulatory action: the race to the bottom. The Commission has been focusing on turning operators away from the race to the bottom with its “raising standards” message and increased penalties against licensees who fail to comply with their licence conditions. But if the Commission is to continue to raise standards, the cost of operating at the “bottom” will become such that customers will eventually be driven to unlicensed operators. The Commission must create an environment where it is possible to operate to high standards and be profitable. Enforcement action against illegal operators will become an increasing part of that as expectations increase and we hope to see recognition of this by the Commission in its next Business Plan. However striking a fair balance between protecting vulnerable customers and allowing gambling businesses to flourish should, in our view, be the priority. :: cGi

others think that they would be better employed in digging the garden, reading to their children or playing healthy outdoor sports.” The encroachment of the “nanny state” into so many areas of life is now impacting gambling. The impression is that the Commission somehow disapproves of the activity and this is leading to moral judgements being made about, for example, what each of us can afford to spend; presumably this would depend upon our family circumstances. This highlights the dangers of the intention of seeking constantly and indefinitely to make gambling fairer and safer for all, without ever stating what the end goal is. If the Commission believes that all problem gambling and harm arising from gambling can be eradicated, then however admirable an aim, it is doomed to failure. It equates with those who want constantly to reduce the speed limit for road traffic. They cite statistics proving that lowering the limit will reduce injury and death, the logical conclusion of which is of course a total ban on all traffic. Of course, this is not to say that the industry or the regulator should be complacent in seeking to reduce such levels. However, the means of doing so need to be balanced and proportionate. Commercial Imperatives In Great Britain, gambling operators are commercial enterprises and in some cases are listed companies. Whatever noble intentions their executive team may have, their first priority must be to be profitable if they are to survive. In today’s competitive marketplace, to be profitable, a company must not only deliver a

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JULIAN HARRIS & MELANIE ELLIS

Recognised as a leading expert in national and international gambling and licensing law, Julian Harris is highly regarded by both operators and regulators throughout the world. Harris Hagan is the first and only UK law firm specialising exclusively in legal services to the gambling and leisure industries. With over 30 years experience of gambling law Julian has advised some of the world's largest gaming industry corporations and has been described by Chambers Guide as “the best gaming lawyer in London”. Harris Hagan was awarded “Gaming Law Firm of the Year” in 2013. Julian is past President of the International Association of Gaming Advisors. 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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bettiNG oN More reGulAtioN

Simon Airey

simon Airey & Joshua domb Paul hastings

he UK Government is cracking down on problem gambling – but is it striking the right balance to ensure the continued growth of the industry? Who will be the winners and who will be the losers?

In its recent response to the consultation on proposals for gaming machines and social responsibility, the maximum stake on ﬁxed-odds betting terminals (FOBTs) was slashed from £100 to just £2. Minister for Sport & Civil Society, Tracey Crouch, clearly stressed the government’s support for “a healthy gambling industry that generates employment and investment” – but, as her introduction to the proposals quickly made clear, FOBTs were an exception. “B2 gaming machines (more commonly known as Fixed-Odds Betting Terminals (FOBTs)) are an outlier in the world of highstreet gambling because of the speed with which it is possible to lose large amounts of money,” she wrote. The Government noted that 13.6% of players in betting shops were problem gamblers, the highest rate for any form of gambling, and that over 170,000 sessions on B2 roulette ended with losses between £1,000 and £5,000. Many of the players also lived in deprived areas. “Local authorities, charities, faith groups, Parliamentarians, interest groups and academics all submitted opinions in favour of a £2 limit,” Crouch said. Whether the £2 limit will reduce problem gambling, or whether the players being targeted by this move will simply turn their attention to other gambling products, remains to be seen. What is certain is that it will hit betting shops hard, squeezing revenues at a time when they also face increasing regulatory requirements and compliance costs.

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More To Come While the £2 limit garnered the headlines, it is not the only significant change announced in the Government’s paper. The Government cites the response from the Association of British Bookmakers (ABB) to the consultation, which included a number of measures to tackle problem gambling: hard stops when voluntary time and spend limits are met; card blocking as a supplementary tool to the self-exclusion scheme; and expanding a treatment pilot supported by the ABB, aimed at areas of high economic deprivation. The Government rejected the ABB’s central call for less restrictive limit on FOBT stakes (they suggested £25), but endorsed the social responsibility measures: “We very much welcome these proposals and encourage the ABB and operators to work with the [Gambling] Commission and the RGSB on how to take these forward.” It therefore seems that the Government expects industry to implement the ABB’s additional proposals even after the £2 limit is introduced. The Government has also taken a similar approach to the Gambling Commission’s advice on gaming machines, published in March. The Government adopted the lowest figure proposed by the Commission (from a range between £2 and £30). In addition, it endorsed the Commission’s view that a stake reduction alone would not go far enough to address the risks, and supported a number of the Commission’s other proposals. These include banning the facility for machines to allow different categories of games to be played in a single session, and working with industry to make pre-commitment tools more effective – for example, by automatically terminating sessions when consumers reach time or money limits. As a result, it seems likely that retail

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premises will need to implement tracked play and precommitment tools, no doubt at considerable expense.

Caught In The Web The Government also wants to see greater eﬀorts from the online industry to tackle problem gambling. It calls for “rapid improvements” to player protections and a range of harm prevention measures; it also advocates greater use of technology and algorithms to spot harmful behaviours and patterns of play, to allow operators to intervene. “If operators fail to demonstrate suﬃcient progress then the Government and the Commission has powers to introduce additional controls or restrictions on the online sector,” it warns ominously. The Government’s paper also builds on and endorses the Commission’s proposals for online gambling, also published in March.

In particular, it notes four areas where the Commission is to bring forward proposals: • Age verification: a proposal to remove the current 72-hour period for operators to carry out age verification, and replace it with a system for verification before permission is granted to deposit funds in customer accounts or access free-to-play games • Customer identification: requirements for more information about customers at an earlier stage, and proposals for mandatory limits on spending that can only be increased once an operator has verified certain customer information, “for example via an affordability check”

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• •

Unfair terms and conditions: the Commission proposes to test how remote operators are ensuring promotions are clear and fair to consumers Ineﬀective customer interaction: steps to strengthen requirements on online operators to interact with consumers at risk from problem gambling and, again, more eﬀective use of data to identify potential indicators of harm

The paper also notes that the Commission is working on a number of other areas: the eﬀectiveness of the current consumer protections; game and product characteristics; protection of customers’ funds and dormant accounts; withdrawal of funds; and gambling on credit. The latter will inevitably have a signiﬁcant impact if deposits using credit cards are banned. As with FOBTs, the Government response is far from the last word when it comes to online gambling. Indeed, it is just one voice in an escalating debate in which a wide range of stakeholders wish to be heard.

Other Areas Three further areas covered by the Government paper are worth noting briefly. The first is proposed changes to advertising, with the Industry Group for Responsible Gambling due to amend its codes to ensure that a responsible gambling message appears for the duration of all TV adverts. The Government also argues that research, education and treatment for addiction are so important that if sustainable funding targets cannot be guaranteed, there is a strong case for a statutory levy (GambleAware is currently funded by the industry on a voluntary basis). This would effectively amount to another tax on the industry. Finally, there is a continuous focus on protection of young people throughout the paper, particularly in relation to advertising and research. The paper notes that the Committees of Advertising Practice will publish further guidance this year; it also notes that research on the effects of marketing and advertising on children, young people and vulnerable groups has been commissioned by GambleAware. It is clear that these areas will all remain under close scrutiny.

Go With The Flow Some of these changes will undoubtedly be painful for both retail and online businesses. There have already been significant objections raised by many within the industry. However, the Government and the Gambling Commission are committed to raising the bar when it comes to problem gambling and consumer protection. With increased focus on anti-money laundering also, the pressure on all gambling operators will only increase. This inevitably means more investment, rising compliance costs and challenged margins. The alternative is the risk of increased and more aggressive enforcement, bigger fines and heavier sanctions. For repeat offenders and the most serious failings, licence reviews will be the default position and an increased focus on individual PML holders is likely. Operators have little option but to try and make the best of things. In the meantime, board-level buy in will be a prerequisite to putting in place the controls required, and making available the resources for the necessary investment in personnel, training and technology. The last of these will be particularly important.

Operators should ensure that they have IT personnel and systems with sufficient expertise and functionality (especially relating to data management and analytics) to meet growing regulatory expectations and increased competition. There is, of course, an advantage to moving early. Individuals with the technical skills required are in short supply, and demand for them will only grow as time goes on. The demand for highly qualified compliance personnel will also increase. Investing in the right kind of systems and controls will pay dividends. Operators should not be cowed by recent events and concerns about a tougher regulatory environment. The key is to work smarter to minimise risk, attract the right kind of customer and turn a decent profit. This means using resources more effectively, better horizon scanning - and keeping the regulators off their back. In the longer term, comfort will be found. First, the developing regulatory environment is likely to make life increasingly tough for unscrupulous competitors who are likely to be marginalised or driven out. Second, as enhanced compliance systems and cultures become imbedded, the relative cost and disruption will level out. Third, those operators who establish and brand themselves as leaders will inevitably gain competitive advantage and attract new business and investment. Finally – for those with ambitions further afield – the advent of sports betting in the US will open up very significant new opportunities and not a dollar of investment in compliance will have been wasted. Whichever way the current challenges are viewed, the stakes are high – but the rewards are there for those who are in it for the long game. :: cGi

SIMON AIREY & JOSHUA DOMB

Simon Airey is a Partner in the Corporate Crime & Investigations practice at international law firm Paul Hastings, based in London. He specialises in global investigations, financial and regulatory crime, bribery and corruption, money laundering, tax and fraud inquiries, dawn raids and corporate compliance. He advises a large number of multinational groups in relation to their global AntiBribery & Corruption (ABC) compliance programmes and has lectured extensively in the U.S., Europe and Asia in relation to the UK Bribery Act and related matters. Joshua Domb is an Associate in the Litigation practice of Paul Hastings and is based in the firm's London office. Joshua counsels clients on a wide range of domestic and international investigations and regulatory matters. His practice includes assisting with and advising on internal investigations, Serious Fraud Office (SFO) investigations, enquiries by HM Revenue & Customs (HMRC), anti-bribery and corruption compliance, whistleblowing, anti-money laundering (AML) issues, tax investigations and national minimum wage investigations. He also has experience of acting for gambling companies on a range of compliance matters.

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hiGh rollers ANd hiGher stAKes: whY oPerAtors Must PAY AtteNtioN to custoMer sources oF weAlth T

he gambling industry is a proﬁtable source of income for the UK economy. Currently worth £13.9 billion according to the Gambling Commission, its value is only set to increase as the sector continues to build on consumer appetites for online gambling.

Katrina Jones

With the onus currently on operators to spot both illicit funds from financial criminals and problem gamblers, already-stretched compliance staff are finding themselves under a mountain of customer checks and could begin to stray away from their other regulatory requirements. The past 12 months has already seen a number of fines within the sector for ineffective money laundering controls, largely focused around the sources of customer wealth and a lack of action in flagging suspicious customers on the part of the operators. So, how can operators ensure that the funds being injected into their systems aren’t illicit?

Michael harris & Katrina Jones lexisnexis® risk solutions

Risk and Regulation The current guidance from the Gambling Commission on antimoney laundering (AML) controls is in line with the UK’s 2017 Money Laundering Regulations, which were based on the EU 4th Money Laundering Directive (4MLD). Whilst casinos had been mentioned in previous directives of this nature, 4MLD was the first time that the requirement for certain entities to carry out effective customer due diligence (CDD) has applied across the entire gambling sector. Furthermore, the Regulations included specific notices to operators to apply CDD measures for single transactions amounting to €2,000 or more. In theory, this due diligence should target so-called ‘high rolling’ customers who deposit large sums of funds in a single transaction. However, this is not being done CGiMAGAZINE.COM

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consistently by operators in practice. The Gambling Commission has recently fined two leading operators as a result of failures in anti-money laundering controls. One case saw several cases of large customer deposits, which were later shown to have come from illicit sources. This should sound an alarm bell for the whole sector, and all operators need to ensure they are taking a risk-based approach to the sources of client funds – especially for so-called “high rollers”. On this particular case, Neil McArthur, Executive Director of the Gambling Commission said: “Gambling businesses have a responsibility to ensure they keep crime out of gambling and tackle problem gambling – and as part of that, they must be constantly curious about where the money they are taking is coming from.” While it is clear that the Commission is serious about compliance, operators are seeking more specific guidance around how they can effectively conduct due diligence on their specific customer types. At the moment, they are subject to general catch-all guidance to follow a risk-based approach, and as such, sometimes fail to have the proper checks in place. Waving a red flag The statements from the Commission also identifies two important challenges for all operators: internal resource and appropriate staff training for those responsible for implementing AML controls. Senior management failure to mitigate operational risk and provide resource to carry out sufficient levels of due diligence on both new and existing customers is a key issue. That said, there are a number of ‘red flags’ which compliance staff should always look for when it comes to customer due diligence checks, whichever approach is used. The basic customer documentation required for due diligence checks such as payslips should be the first consideration, as then it can be determined whether a customer’s income level matches the level of funds being placed as a deposit. Equally, another simple step is to consider where these funds are coming from. The offence of money laundering also includes criminal spend, i.e. the use of criminal proceeds to fund gambling, so looking at the origin of these funds is paramount. Whilst the source of customer funds should always be a priority for a compliance officer, the methods through which the funds are transferred should also be met with a cautionary eye. Operators need to be especially wary of alternative methods of payment such as credit card, prepaid or stored value cards and money service businesses, such as currency exchanges and other cross-border transfer systems. The Commission also expects operators to maintain AML policies which identify the use of multiple accounts, multiple debit/credit cards and multiple online e-money accounts as areas of potential risk. The last piece of the puzzle lies with checks on the customers themselves. Staff need to ensure that they flag any customers who are from high-risk jurisdictions, included on a sanctions list or identified as a politically-exposed person (PEP). Each of these categories should be seen as a potential marker for suspicious activity, and all customers – high rollers or not – should be subject to some form of identification and verification checks.

The Customer is King The age-old retail saying of “the customer is always right” may not apply to due diligence purposes, but customers still need to

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feel respected and valued by the operators whose goods and services they are purchasing. For gambling operators, there is a fine line between adequate due diligence and customer satisfaction, as there is a significant challenge in enquiring about a customer’s wealth without offending them. As a result, we are seeing more and more landbased casinos implementing a 2-day due diligence structure, whereby the customer will book an appointment in advance to visit the establishment, and in the two days prior, the casino’s compliance staff will use that time to conduct all relevant checks on the customer and their potential risk. This is proving to be especially effective in larger cities like London, as customers – especially the high rollers – are flying in from overseas, and therefore are far more likely to book their sessions in ahead of time. On the other hand, online operators are finding that whilst they may have more data on their customers overall, the onboarding process is at times trickier due to customers having to scan in or share digital versions of all the relevant documents

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fits all” approach; a different process is needed for every type of customer, and it is up to each operator to understand its own risk exposure and implement appropriate policies to reflect this. The general guidance from the Commission states that firms need to: 1. Identify the money laundering and terrorist financing risks that are relevant to their business 2. Design and implement policies and procedures to manage and mitigate these assessed risks 3. Monitor and improve the effective operation of these controls 4. Record what has been done, and why

needed for compliance, such as payslips, P60s and other proof of identity and proof of address documents, to ensure all bases are covered. This can create friction with new customers who just want to use their funds to play the game or bet on an upcoming match, but are unable to do so until the correct checks have been conducted. One solution to this lies in Open Banking, which came into force in January 2018. Theoretically, with a customer’s approval, operators could use Open Banking to access the customer’s banking details and conduct all the appropriate checks with minimal input from the customer themselves. The sticking point here, however, lies in this theory becoming a reality. A Process-based Approach It is clear that what is holding retail and online operators back from due diligence success is the process with which they conduct this activity. There is a great deal of inconsistency in the policies and procedures adopted by individual operators, and the regulations themselves are not prescriptive. There is no “one size

The ability to action these steps ultimately depends upon the compliance resources each operator has. Ongoing monitoring is also a key part of the Commission’s guidance, and can potentially be a weak spot for operators when it comes to effective customer verification. From a regulatory perspective, operators need to evidence that they are conducting ongoing monitoring of their existing customers, outside of the onboarding process. Indeed, customer records are expected to be kept for a minimum of five years, and so operators need to ensure that their employees are trained to record and retain information for all customers. All in all, operators are facing increased regulatory scrutiny, but the processes needed to achieve compliance are often unclear. Taking a risk-based approach is a far cry from the old ‘tick box’ approach to compliance. It requires a high level of staff training staff to perform customer checks and the potential risk factors to look out for, and when to refer concerns to management without reproach. Operators themselves need to take their AML obligations seriously and have robust procedures in place to report suspicious activity to the National Crime Agency through the Suspicious Activity Report (SAR) process. Gambling businesses are in the front line in the fight against financial crime, and the industry needs a deeper understanding of the typologies adopted by financial criminals. By taking a proactive approach in ensuring proper AML controls are in place, gambling operators can begin to turn the tables on their process problems and gain a distinct advantage, especially as the regulator looks to increase compliance levels even further. :: cGi

MICHAEL HARRIS & KATRINA JONES

Michael Harris is Director of Financial Crime and Regulatory Compliance at global data analytics ﬁrm LexisNexis® Risk Solutions, providing expertise to clients in all sectors for antimoney laundering (AML), Know Your Customer and anti-bribery and corruption. Katrina Jones is Business Development Director at global data analytics ﬁrm LexisNexis® Risk Solutions, where she has a key focus on assisting customers with compliance in the gambling sector, in addition to leading the teams responsible for the business’ customer activities.

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DATA SECURITY ::

GDPR AND DATA SECURITY IN THE GAMBLING INDUSTRY A

s the implications of the General Data Protection Regulation sink in, Paul Brennecker examines its impact on the gambling industry and explains how it is not simply a compliance exercise but an industry-wide altered mind-set that is the key to eﬀective data security.

Paul Brennecker Security Risk Management (SRM)

The gambling industry has always been a target for criminals, both in reality and in fiction. From The Sting to Ocean’s Eleven and Lock, Stock and Two Smoking Barrels, the world of cinema has long relished the idea of cunning criminals taking on the casino and winning. There is something inherently satisfying about attractive and engaging rogues beating seemingly anonymous gambling enterprises in what is perceived to be an almost victimless crime. In the fictional world of Hollywood, the inevitable sequels roll out reflecting, probably unintentionally, the reality of the situation: that repeated breaches are increasingly experienced by casinos and gaming enterprises. What they do not necessarily show, however, is the other reality: that in the new era of online gambling the victims are very real. They are the individuals whose personal data is stolen. Cyber-attacks come in many forms but they can broadly be categorised into those that disrupt operations, such as distributed denial of service (DDOS) attacks, where infected computers flood the network with traffic. There are also those that are aimed at data theft, targeting customer data, especially financial information like credit card details, which can be sold on the dark web or used for identity fraud, and ransomware attacks. This type of credential abuse is particularly concerning in the gaming industry because it leads to loss of reputation and clients transferring their online business to other providers. Although the adversarial threat is significant, the threat posed CGiMAGAZINE.COM

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by insiders, often trusted employees, can pose an even greater risk to a business. With privileged access employees can intentionally or unintentionally be involved in a targeted breach of data. Staﬀ in the gambling industry have a tendency to switch roles between competitors, requiring a robust ‘Joiners, Movers, Leavers’ process. It also necessitates a heightened awareness of data leakage from within each organisation.

GDPR & PCI DSS Under the new GDPR framework which became EU law in May of this year, in the event of a data breach, firms can be fined up to 4% of revenue (or 20m Euros, whichever is higher). Since the terms of GDPR were first known, much has been written about it and the impact it has on the way companies manage their data. Yet, there is an important misconception which need to be addressed. Contrary to current public perception, there is actually no such thing as GDPR compliance. It is a regulation which requires data systems to be safe but it is open to interpretation and provides nothing in the way of detailed guidance. Nor is there an annual review to validate compliance. On the other hand, the Payment Card Industry (PCI) Data Security Standard (DSS), which regulates the gaming industry to ensure that payment card details are used with best practice and kept secure, does provide a detailed framework which specifies what needs to be done and how. PCI DSS even provides regular updates and guidance on reviews. Those who are PCI DSS compliant are therefore well on the way to meeting the

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requirements of GDPR. It is the role of Chief Information Security Oﬃcers (CISOs), Data Protection Oﬃcers (DPOs) and their advisers to work out where the gaps exist to ensure that an organisation adheres to GDPR in practice. While the PCI DSS compliance process is undeniably useful, it must be likened to an MOT; it only applies to a given moment in time. One ill-conceived change of control request or alteration to the process can render that compliance invalid. Ongoing testing and maintenance is essential and this is best managed through an altered corporate mind-set which embeds data security at every level of the organisation.

A Board Level Approach To Effective Data Security GDPR and PCI DSS complement one another and, if managed holistically, can deliver immense benefits to efficiency and reputation, while also mitigating the potential damage of a breach. But given the fact that PCI DSS compliance simply provides validation of compliance at a given moment in time, the key to data security is not to focus on specific compliance targets, following a tick box exercise once a year, but to develop a corporate mind-set which features a ‘compliance out of the box’ approach and has ongoing updating and maintenance built in. This altered mind-set requires a company-wide strategy which is developed at board level and then disseminated in practical, simple form to each and every employee or partner of the business. For this to be a realistic goal, the responsibility for data security cannot simply be devolved to the CISO or DPO; nor should it be seen as something which is only in the scope of the

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IT department. To be truly effective, it is the responsibility of the each and every member of the board to drive and oversee the organisation’s data security responsibilities. Data security should be on the agenda at every board meeting. Realistically, however, given the complexity of data security and compliance processes, specific ownership will be in the hands of these technically qualified individuals. Yet they will not be able to effectively exert influence at board level unless they are provided with the specialist support and resource. Much like the support provided to the financial department by corporate accountants or the support given to the legal department by specialist legal teams, the CISO needs to have access to specialist data security support to provide strategic guidance and technical abilities to enhance the scope of the operation.

The Role of Penetration Testing, Red Teaming and Retained Forensics in Developing a Data Security Strategy One of the key elements of data security is the development of a robust defence strategy. It is not enough, however, to develop a strategy and build a defence based on what is already known. Cyber criminals are ingenious and exploit not simply known threats and vulnerabilities, but they also have ways to detect those which are not yet known or understood. Those who only use their own understanding to develop a defence will therefore be limited by the extent of their own knowledge. Testing and challenging that knowledge on an ongoing basis is an essential element. This is where a continual programme of Threat Monitoring, Penetration Testing and the use of Retained Forensics comes in. Threat monitoring is the process of observing the changing nature of cyber-attacks. All commercial websites will be probed for vulnerabilities, initially by automated tools and once something significant is found, a more concerted manual attack may be launched. Having alerts and being set up to monitor the nature of these attacks and countering them is essential for players in the online gaming space. The next step is regular Penetration Testing, which needs to include both automated and manual elements. After all, the criminal community uses both advanced scanning tools to identify potential areas of weakness as well as the additional sophistication of the human mind to develop and explore these vulnerabilities. Imagine a room with an almost limitless number of doors. The automated penetration test will identify which doors conceal potential vulnerabilities. The manual tester then prises these doors open and looks at what is behind them. Taking the analogy a step further, Red Teaming will push the doors wide open and delve and explore into what is behind them. Red Team testers have ethical hacking qualifications from industry respected bodies such as CREST and OSCP and use their sophisticated skills to root around and uncover hitherto unforeseen vulnerabilities. Armed with this information, the process of closing off potential opportunities for cyber criminals before they are even exposed can begin. In this way a data security strategy can be developed which anticipates vulnerabilities before they are discovered, rather than simply reacting to those which are already known. These experts will work in partnership with a specialist Retained

Team to manage the defence process. In some specialist consultancies the Red Team will also be part of the Retained Forensic capability to help ensure that the process is be an ongoing one, with regular exposure to testing built in. Engaging a Retained Forensics team not only assists in managing a continually evolving the strategic defence but builds in resilience to potential attack. Given the unrelenting ingenuity of attackers, it is impossible to ever consider an organisation to be immune from attack. The strategy should therefore include detailed plans if this eventuality occurs, particularly for the prompt reporting in the event of a breach. GDPR requires any breach to be reported to the relevant regulatory authority within 72 hours and failure to do so will result in punitive action being taken. When it comes to issues of business continuity, disaster recovery and containment, having a Retained Forensics team on hand, with a thorough knowledge of the organisation’s systems, means they will be able to manage this process swiftly, thereby limiting any potential damage. It is also worth noting that not only will the engagement of a Retained Forensics team facilitate the ongoing testing of system security and provide strategic intelligence for eﬀective maintenance and development, it also demonstrates to the relevant authorities that a robust, ongoing process is in place, thereby reducing the level of potential ﬁnes.

In Summary GDPR should not be considered an encumbrance or an onerous chore. It has been developed to build in safeguards to data security systems protecting both the organisations and their customers from cybercrime. Those who embrace it with enthusiasm, building an ongoing test and exercise regime into their systems, will beneﬁt from enhanced reputation and customer loyalty. Those who make data security the responsibility of all members of the board and who develop a constantly evolving defence strategy can demonstrate to both customers and the regulatory authorities that they take security seriously. They are also in the best possible shape to resist potential attacks, or deﬂect or reduce the impact of one, making an investment in GDPR and cyber resilience a sound business decision. :: cGi PAUL BRENNECKER

Paul Brennecker is senior Information Security Consultant at Security Risk Management (SRM) Ltd (www.srmsolutions.com). An acknowledged expert on PCI DSS compliance, Paul also specialises in the gambling industry. He regularly speaks at PCI conferences and writes on issues relating to card payment security. He is currently engaged with a number of high-proﬁle organisations, assisting them with their compliance programmes. Paul joined SRM in March 2008 from Barclaycard. As their former PCI Compliance Manager, Paul successfully drove the compliance programme forward and worked closely with both VISA and MasterCard to raise awareness of the standard and was a regular key-note speaker at the industry’s security forums. He spoke at PCI London in July 2018 on the topic of Incident Response and Forensic Readiness.

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SPORTS BETTING ::

HOW EUROPEAN TECHNOLOGY AND NEW BUSINESS MODELS WILL SHAPE THE US SPORTS BETTING MARKET T

here are three things you need to know before deciding to read this editorial. The ﬁrst is that I am going to explain why the outdated, legacy technology solutions that are being used in the US market need to be replaced. The second thing you need to know is that I am an entrepreneur who has spent nearly twenty years delivering B2B solutions for online gaming and sports betting technology, so I actually know something about the subject. Finally, I’m going to assume you are up to speed on the repeal of PASPA and so I’m not going to waste your time discussing the slow rollout of state by state regulations and will instead focus on the systems that work within the state-bystate regulatory framework and across the highly fragmented US market.

David McDowell CEO & Co-Founder FSB

Let’s start by going back to 2007. The USA was in its post-UIGEA prohibition, the recession was still a year away and the European market for sports betting was positively booming. Operators, in a bid to increase turnover, had starting accepting bets on football (sorry, soccer) after the game had started. Only about 2-3% of stakes were being placed in-play, but it was blatantly obvious to all of us in the industry at the time that live betting was going to be huge. My theory, at the time, was that live data coming directly from the sporting venue would get faster and more detailed, as well as becoming more reliable and expensive as sports authorities began to license the oﬃcial data rights. Further, I believed that this live sports data would be used to drive real-time pricing models, which would fundamentally change how you run a sports betting operation. Compiling the betting odds would transition away from being a manual task and would be replaced with automated computer algorithms in the same way that these CGiMAGAZINE.COM

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changes had taken place in the financial markets. Quantitative mathematicians would work on the algorithms and the role of the trader would evolve into a specialist function to focus on the value added aspects of risk management that are harder to automate, such as customer profiling. This wasn’t just a guess, with seven years of online gaming experience already under my belt I was looking to start another company and spent that summer researching the sports betting market and writing a business plan. Fast forward to around 2011, and the problem was that reliable live sports data just wasn’t sufficient to support the expansion of live betting. Bookmakers were using broadcast TV and live streaming services so that traders could watch the games and manually type in the odds changes. Companies were building up huge trading teams with a single trader focussed on trading a single game. At the same time, people began to realise that the broadcast TV could be delayed by 7-10 seconds from real life, and some savvy punters were putting scouts into the venue to try to “beat the feeds”. It was the start of the arms race to see if the bookmaker or punter could get the data first. Companies like Runningball and BetRadar had already begun to develop professional scouting networks and created some of the first commercial data feeds for both of these types of customers. Slowly, over the next few years their coverage expanded to cover more and more events and more companies started collecting and distributing data on other sports. The sector was thriving and companies like Sporting Solutions and BetGenius started supplying odds feeds (as opposed to just the sports data); companies like Boolubus built flash-based betting interfaces so bookmakers could push live price changes to their websites; and iOS app usage exploded as mobile betting went from being “the next big thing” to the most important user experience to get right. Fast forward again to today, and there is a healthy industry of data feed suppliers providing near comprehensive coverage of events and reliable service. Just five years earlier it was near impossible to run an automated bookmaking platform, but today is is quickly becoming the norm. As an illustration, my company runs 35 different sports betting brands across 8 platforms in 10 different countries with a full time trading staff of just 12 people focussed on risk management. On a single Saturday, we will distribute some 20 million price changes out to these various platforms, with each platform used to deliver a different pricing strategy for a different client (and one platform reserved for our multi-tenanted services). Odds compiling has well and truly been replaced with on-demand data feed services and automation. So this is where we need call out legacy sports betting platform suppliers. Any sports betting platform that was designed before this important market evolution was not built for the right purpose. In the US, the regulated market was restricted to Nevada and ROI targets for any regulated US-facing company would mean that technology investments could not be justified. While the US market has the best access to investment capital, sports betting was seen as toxic and the VC funds would instead push $1billion of investment into daily fantasy sports. The large US casino equipment suppliers largely ignored sports betting as well, because the casino operators were not asking for it. Europe has seen significant capital investments into developing sports betting technology and so European technology is significantly more advanced. But that does not mean that all of the European suppliers

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have invested wisely either. Over the last decade, software development tools and systems architecture has fundamentally changed. The large, monolithic platforms that were designed for a global “.com” era of online gaming are not fit for purpose in today’s “.country” regulatory framework, where flexibility trumps legacy technology. Sure, these legacy suppliers boast about having some of the largest UK sports betting operators as their customers, but these same operators have been eclipsed by a small start-up called Bet365 who took control of their platform was not held back by a legacy technology supplier. The pursuit of maximising profit through the “time and materials” business model, means that large European incumbent suppliers find themselves today rooted to an outdated technology architecture with multiple forked code bases and unable to benefit from the efficiencies that modern companies take for granted. Implementing a legacy platform being sold by the large European suppliers might sound like a safe choice, after all “nobody got fired for hiring IBM”, but it is also ensuring a multi-year implementation schedule at the highest possible operating cost. Cost efficiency is the reason why the fully-managed services have become the fastest growing sector in the market today. The fully managed business model is great for anyone who does not want to buy a platform, hire a trading team and run a sports book. This can include large and small casino operators,

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lottery operators, media companies entering the space and even existing European operators are using these services to move into new territories. The SaaS business model means that the operational costs are kept to a minimum and shared across multiple operators. I am such a huge fan of this business model that I built my company on it. But they are not right for everyone and further caution is merited when examining these solutions as well. For example, the odds are often the same for all operators and the customer experience from some suppliers tends to be a cookie cutter approach with all websites looking practically identical. To set themselves apart from the pack, the larger managed services suppliers will boast of having a trading team with several hundred traders and this is generally accepted by the uninformed as operating at an impressive scale. I would suggest exactly the opposite: that the success of these suppliers comes from having been spun out of a successful B2C operation and they are in fact held back by their own legacy software issues that require huge manual trading teams. In fact, we were able to win business away from one of these suppliers, who’s sales pitch boasts the most sophisticated risk management systems in the market today, because their traders were manually screen scraping their data and did not even know that they were taking late bets. But the biggest problem with the managed services model,

in my opinion, is probity. Several of these suppliers have been funded by their black market operations which can include places like Turkey, China and Iran. I thought that black market suppliers would be prevented from entering the US market, yet at the time of writing they are joining trade associations and signing deals. I expect there will be another chapter to this story. Let’s get back on track. The fully-managed business model, when executed properly, will be perfect for most casino and racetrack operators in the highly fragmented US market. Rather than investing millions into their own platform and trading teams, these customers can quickly and efficiently offer their ownbranded sports betting services and focus on differentiating themselves with the user experience and tactical price boost offers. But I would suggest that any multi-state operator who wants to capture a significant market share in the US should find a way to maintain more control over their business. Again, purchasing a legacy technology platform that needs to be installed into each state at great cost is not an attractive option either. This is where licensing a modern, highly automated sports betting platform driven by data feeds can offer the benefits of retaining full control with the cost efficiency of a managed service. Modern architecture can deliver centralised control over the data feeds and risk management functions and should allow for distributed sports betting platforms to be quickly deployed into different regulatory environments. As an example, we have an African client who operates in five different territories, some territories have gross profits tax while other territories have turnover taxation. The client needed a different strategy for managing their margins across these different territories to cope with the different taxation rules. In response, we setup two different platforms on our private cloud hosting facility and sent different price strategies (one was a high margin and the other was a lower margin) into the two different platforms. You would never deploy that solution if you had to spend millions of pounds on each platform implementation, but with modern technology launching a new SaaS platform is easy. If you consider the proposed tax rates in different states, not to mention proposed integrity fees by the leagues, it is easy to see that a multi-state operator will need to operate a different pricing strategy for each different state. I am extremely bullish on the US market for sports betting, but it will be a slow and complicated path to building a market worth some $5billion. In my opinion, selecting the right technology partner will be the difference between winning and looking for a new management team. :: cGi

DAVID MCDOWELL

David is Chief Executive Oﬃcer and Co-Founder of FSB. Before starting FSB, David was the COO/CFO and co-founder of the casino platform supplier GAN plc. David’s success in building the GAN operations and ﬁnance functions from the ground up provided unparalleled insight for running B2B services within the gaming industry. David has an MBA from London Business School and an engineering degree from Kettering University in Michigan.

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sPorts bettiNG ::

sPortsbettiNG: the wAY ForwArd For A uNiQue PlAYer eXPerieNce N

avigate to Google, insert “bet on sports” in the search field and a myriad of bookmakers will invade your page. Welcome to the world of sportsbetting. List upon list of operators offering an infinite amount of bets from an endless range of markets. Each and everyone of them offers promises the same betting opportunities and the best possible player experience. But do they really offer unicity? To put it bluntly… no!

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Quantity vs UX Long gone are the days when quantity was synonymous of a good product. In fact, this approach has long since been sidelined, with bookmakers getting to grasp with the reality that offering an infinite list of bets will not only end up exasperating the player, but will probably see the player jump ship to a rival operator. As a result, nearly all of the big players in the betting world are now seeking to offer easy, convenient, and tailored ways to bet, with much greater emphasis placed on the mobile device. But whilst this notion generates a huge nod of approval it goes without saying that such an achievement is no easy feat. And it is at this stage that technology has to play a vital role. Recommendation engines and machine learning have been around for years, especially when it comes to the mass-consumer universe. But this is not the case in the iGaming industry, with the industry in general still not being able to truly reap the benefits from this disruptive technology. However, similarly as to how they proved to be pivotal in other entertainment industries, this form of disruptive technology will essentially define who the winners will be as the sportsbetting scene becomes ever more intent on a more rewarding player experience. And with mobile technology gaining ever more popularity amongst punters, the road ahead for some operators will prove to be a difficult hurdle to clear. CGiMAGAZINE.COM

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Changing The Mobile Approach Why? Responsive design has previously been about enabling any given site to work regardless of the device it will be viewed on. However, making it responsive to each individual user is a far harder task. When it comes to the mobile dimension, practicality is the key word for success. Nowadays for betting companies to offer just a mobile version of their existing websites is just not feasible anymore. The mobile experience must be both functional and easy to use. Either that or operators will end up not being able to retain a huge chunk of punters amongst their loyal fold of players. Indeed, the whole process of building a suitably tech-enabled yet personalised mobile sports-betting offering is no simple mission. A system needs to be able to collect large amounts of information about any given player, analyse and learn from that data, identify player behaviours, categorise players by their similarities, predict what they are likely to want to bet on next and subsequently offer one-to-one marketing messages. Providing a layout that is designed around the individual player and the device used, whilst at the same time permitting the operators to anticipate their punters’ expectations is the key to attracting players and giving them a unique experience. Such a scenario will also provide operators with the perfect scenario to be successful on the retention side of the business by keeping their players loyal to the brand. This continuous evolution in terms of the mobile sportsbetting will see players revert time and again to the same sportbook’s offers without feeling the necessity to jump from one bookmaker to another. Thus it’s relatively easy to conclude that it all boils down to the system’s capability in terms of true customization, with the player being presented with the right product at the right time, offered the correct rewards – and without having to rely on possibly intrusive blind bonusing and push notifications.

A Sound Technological Infrastructure However, a great player experience does not depend solely on the personalization of the content. It also relies heavily on fundamental technological aspects. Recent studies have shown that the predominant share of punters rate the responsiveness and speed of delivery as a top priority in their betting experience, even deeming it more important than the brand through which they are placing their bets on. And with the player becoming ever more demanding, operators must ensure that the betting experience they are providing – especially on mobile – must have no latency issues, is not offset by sudden spikes in demand, and has no downtime whatsoever. With only a relatively small percentage of millennials considering themselves as loyal to a specific brand, the technological aspect carries a lot of weight when it comes to dealing with customer experience. One could even dare say that the mobile sportsbetting industry in particular will stand to benefit or fail on how well they execute around realtime.

The Millenials: Issue or Opportunity? It goes without saying that one of the main challenges that operators are facing is the inevitable shift to cater for a new kind of player … the millennial. We are talking about a player who, is always connected, will not tend to spend a lot of his time searching for his events of preference, will have a shorter attention span, and who will ultimately seek to have a tailored experience always on the go. We are referring to an evolution of the sportsbetting industry where the traditional product approach will have to morph, with the

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end user experiences being different for different users, and with the possibility of new niche propositions cropping up. To tap into this somewhat volatile player tendency, operators must ultimately ensure that their offerings are both engaging and diverse. But to do this a deep understanding of this new demographic of players is a must. Millenials seek enjoyment through technology, and the gambling industry certainly has the potential to provide this, and therefore the potential to attract and retain them. Furthermore, with so many online activities, from social media to gaming, younger players don’t want to spend any longer on site than they have to. Various analysis on the player journey show the time spent searching for bets – especially inplay selections – is an area that still needs to be addressed. And in these terms the providers and operators that deliver the fastest, smoothest experiences will reap the rewards by attracting and retaining this new fold of punters.

Personalised Variety With the growth in worldwide gambling showing few signs of slowing, it is safe to assume that interest in betting on everything from top goalscorer to the number of fouls will continue to increase exponentially. The desire by customers to build their own bets is becoming an everyday part of the offering. It is thus of the utmost importance for operators to provide players with variety in order to galvanize the players’ attention on those events that are of particular interest to him, but not essentially related to a specific circumstance. The last World Cup has been the epitome in this sense of variety, with punters offered different offerings based on varying factors, such as the possibility to bet on who would have been voted as best goalkeeper, or assist man. One could well argue that sportsbetting is entering a new dimension, with infinite content to attract players who are increasingly taking on a more demanding stance. However, the real innovation lies in truly being able to give the player the power to decide where to bet and on which product. It’s about knowing what the clients prefer and using that information to inform them about future offers to gain their attention, trust and ultimately their loyalty. How much can the operators benefit from what the future keeps in hold ultimately lies in the mentality and approach they will undertake. It is no secret that the whole industry as a whole lags behind other business environments when it comes to endorsing disruptive technologies at its core activities. Who will ultimately reap the benefits of this evolution will be the player, who will be placed at the center of a more tailored and customized betting experience. :: cGi

DAVID RUGGERI

David was appointed Director of the newly formed BtoBet Sports department in March 2018. Previously, David was BtoBet Head of Sportsbook, with a strong experience with Italy’s top bookmakers where he was instrumental in the launch of legal sports-betting in Italy. Entering BtoBet, his acknowledged expertise is also within other European and worldwide regulated markets. Now, as Director of BtoBet Sport division in Rome, Ruggeri will focus on international bookmakers’ needs and sportsbook players’ preferences.

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eGAMiNG ::

eGAMiNG: treNds ANd PredictioNs For the rest oF 2018 I

n a sector renowned for rapid growth and explosive change, predicting where e-Gaming goes next is always something of a double-edged sword. On the one hand, there are clear and obvious trends, easily identiﬁable by those that work in and around the industry. On the other lies the pitfall of making bold estimations that could come completely undone by new, innovative technologies and practices. In this piece, I have looked at several industry trends that even the most sensible e-Gaming commentator would struggle to dispute, but have also touched on some of the challenges that will need to be overcome.

Anthony ure head of e-gaming isle of Man department for enterprise

Blockchain and eGaming One of the most exciting examples of modern, innovative integration of technology is e-Gaming’s intersection with blockchain. The global sector has already started to apply blockchain in various areas, from key information storage to payment processing, and it’s starting to feel like the next several months could see some tangible take-off for the platform’s use. For e-Gaming specifically, blockchain can play a crucial role in authentication and validation (by making the process of validating transactions much more secure), payment processing (making monetary payments faster and more efficient), and transparency (with everyone using the same, de-centralised platform to record and transfer information). In the future I would also expect blockchain applications to be used for player KYC. Of course, there remain several challenges that must first be addressed. One example is that there is currently a lack of technical understanding as to the best way to implement blockchain technologies into old and inflexible computer systems. The industry must find ways of navigating this issue if they are to reap the benefits of a technology that carries enormous potential. The adoption of AR/VR technology

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:: eGAMiNG

<< Research from the International Data Corporation has found that worldwide spending on AR/VR products and services is expected to reach $27 billion in 2018, a 92% increase year over year. >> Of course, there are also a number of technological innovations that will affect consumer experience more directly. The excitement surrounding the adoption of virtual and augmented reality technologies has gathered real pace over the past year or so, as eGaming businesses think of increasingly creative ways to reach new markets and engage potential viewers. In such a competitive landscape there is huge pressure on companies to offer customers unique, new and authentic gaming experiences, so it is no surprise that there is a race to see how AR/VR technology can be creatively utilised. Research from the International Data Corporation has found that worldwide spending on AR/VR products and services is expected to reach $27 billion in 2018, a 92% increase year over year. If eGaming companies can latch onto this growth, and find ways of integrating the technology into their respective platforms, they will be well placed to benefit from this exploding trend.

eSports and interest from sponsors As a fundamental part of the eGaming industry, it would be impossible to write a prediction piece without touching on eSports, and more speciﬁcally its rapid rise into a multi-million-dollar, worldwide industry. The most notable driver of this growth has, unsurprisingly, been the continued support of global sponsors, which has had an extraordinary impact on the industry’s revenue stream. According to the latest Newzoo report, sponsorship is expected to contribute $359.4 million to the industry in 2018, compared to $234.6 million in 2017, an increase of over 50% in just a single year! As with any successful industry, a greater valuation, combined with ever-increasing audience numbers, will attract more and more funding. For competitive gaming, this has taken shape in the form of sponsors and gaming sponsorships. These deals are helping push international competitions from a niche market segment into mainstream entertainment spectacles. As the industry continues to grow, the revenue provided by these streams will only continue to grow. Over the course of the next year, I expect to see sponsorship deals increase in both the size of deals made and the number of sponsorships secured. On the Isle of Man, we have been actively supporting and nurturing eSports companies and licensing high quality sites for more than three years, including one of the industry leaders UNIKRN. Other exciting operators, including Rivalry.gg have also been licensed here recently, and there are further licensees in the pipeline. For companies to attract funding from sponsors, and to sustain growth, they need to be supported correctly, and so jurisdictions such as ourselves will play a crucial role in enabling businesses to beneﬁt from a market that is embracing the sector. The presence of strong regulation will help to allay the concerns around fraud within eSports.

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Continued growth of the Asian market eGaming’s rapid growth in the Asian market has been well documented over the past several years, and this trend shows no signs of slowing. The Asia Pacific region’s share of global market revenue continues to grow exponentially, as businesses battle to reach a young, new and passionate fanbase. This trend reflects the fact that, for the next few years at least, demand in Asian countries outstrips supply. A talented player base, competitive domestic competitions and the accessibility of the digital world has created an audience that are extremely tech savvy, as well as immensely passionate. For the next few years, operators that offer further high-quality products will stand to benefit from this demand, but a certain degree of haste is required. Infrastructure and operational systems may be playing catch up now, but the sector is fiercely competitive and it won’t be long until several companies are battling for dominance over this potentially lucrative region. Conclusion There can be no doubt that the trends mentioned in this piece will all continue to shape the e-Gaming industry, in both the short and the long term. The question we need to be asking ourselves, as experts within the sector, is by how much, and to what extent will audience behaviours change the way that e-Gaming businesses interact with their customers? The most exciting thing about these developments is that each factor represents the exploration of a new frontier. Be it technological, geographical, or commercial, each trend is a new challenge to be navigated in its own right, and it is up to us as an industry to find ways of embracing and adopting these innovations so that we continue to remain as dynamic and disruptive as possible. Our ability to adapt and change as an industry is something that we should be proud of. I look forward to the months ahead, and am increasingly optimistic about the sector’s direction. References https://www.idc.com/getdoc.jsp?containerId=prUS43860118 https://newzoo.com/solutions/standard/market-forecasts/global-esportsmarket-report/

ANTHONY URE

Anthony was appointed Head of e-Gaming at the Isle of Man Department for Enterprise in 2017. He has spent over 30 years working for some of the biggest names in the industry such as Ladbrokes and IGT.

EVENT SPOTLIGHT ::

G2E: LOOKING AHEAD AND BUILDING ON PREVIOUS SUCCESSES P

resented by the American Gaming Association (AGA) and organized by Reed Exhibitions, Global Gaming Expo (G2E), returns to the Sands Expo and Convention Center in Las Vegas in October.

CGi caught up with AGA’s Vice President of Industry Relations Allie Barth and G2E’s Event Director Korbi Carrison as they look ahead to G2E 2018 and highlight the newest advancements and additions to the show.

Korbi Carrison

CGI: How do you move forward and build on the successes from G2E 2017?

Interview with Korbi Carrison & Allie Barth Global Gaming Expo (G2E) / American Gaming Association

Korbi Carrison (KC): As the world’s premier event for the casino and gaming industry, Global Gaming Expo must continually deliver what’s relevant and exciting to our attendees year-to-year. We strive to make G2E a better platform every year for companies to grow their businesses by researching feedback from previous events and looking forward to identify big-impact opportunities on the horizon. When it came time to start planning sessions and speakers for 2018, we analyzed the industry’s reaction to what truly worked, what didn’t and topics people would be interested in learning about for the future. We continue to push the envelope, look at the current landscape and see how we can best activate G2E in a way that’s most valuable to the gaming industry. What are you expecting the major topics to be at G2E this year?

Allie Barth (AB): Undoubtably, sports betting. Due to the United States Supreme Court’s May 2018 repeal of PASPA, the Professional and Amateur Sports Protection Act, this issue has quickly become the biggest change in product oﬀering that our CGiMAGAZINE.COM

:: eveNt sPotliGht

industry has seen since TITO. States and Tribal sovereign nations are considering the next steps to legalize and regulate sports betting within their jurisdictions. The issue and opportunity are that many don’t know how to successfully operate a legal sports betting market. Therefore, we have created the Sports Betting Symposium at G2E that will bring together experts, early adopters and gaming industry professionals to map out the future of legal sports betting in our country. We have seen a lot of interest in attending the Sports Betting Symposium by those eager to learn how to successfully integrate sports betting into their product oﬀering as well as those who are simply curious to better understand the business opportunity and regulatory frameworks being discussed/adopted across the U.S. Much of the country is looking to destinations that have run successful sports betting operations for decades, like Nevada and the United Kingdom, to learn about successful practices and procedures. In those markets, operators, suppliers, consumers and other stakeholders beneﬁt from regulation and oversight that protect contests, participants and gaming providers, enabling a

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popular, safe form of entertainment. Another major point of discussion regarding sports betting will be the ability for sports betting companies to increase revenue exponentially in the United States. Many sports books, product developers and software creators have the unique opportunity to grow their businesses vastly by taking their already proven product – and expanding its footprint into markets that were previously inaccessible. Other key topics the symposium will cover include legislative issues and business strategy.

Has G2E oﬀered anything like the Sports Betting Symposium before?

AB: The AGA has been addressing the subject of legal, regulated sports betting with its membership for many years; two years ago, AGA brought the topic to G2E with the NBA former commissioner David Stern as a keynote speaker and Earvin “Magic” Johnson last year. This year’s G2E is the ﬁrst time that legalized sports betting across the United States is not just a possibility, but a reality.

eveNt sPotliGht ::

Therefore, G2E will to go more in depth than ever before, including an interactive expo hall tour designed to showcase product solutions. With so much incredible technology available, we wanted to ensure that attendees interested in sports betting can see everything relevant to their businesses. Attendees will get to demo the products, talk with developers and ask any questions they may have of sports betting experts during the symposium. In previous years, G2E has featured cutting-edge keynote speakers that delve into exciting topics from across the world of gaming. What keynote presentations do you have in store this year?

AB: We’ll have another exciting sports betting speaker again this year that will be announced soon. For this year’s Thursday keynote, we will debut the Innovation Incubator at G2E. Start-ups and students will have the opportunity to pitch their greatest innovations in gaming and hospitality to FUBU Founder and CEO Daymond John as well as The Pink Ceiling and Sprout CEO Cindy Eckert (Whitehead) in front of a live audience. At the Innovation Incubator at G2E, four ﬁnalists, chosen by a panel of gaming industry experts, will present their concepts to John and Eckert, followed by a fast-paced Q&A where the headlining guests will examine the potential business opportunity of each presentation. The winning presentation, dubbed the Shark’s Choice, will be awarded a cash prize, as well as a complimentary booth at G2E 2019 to showcase their innovation. The audience will vote for a second prize, the Customer Choice, which will also receive a complimentary booth at G2E 2019. AGA’s Innovation Lab at G2E has oﬀered a similar platform for students and startups at G2E over the last two years with great interest and popularity; we’re excited to move this concept to the Special Events Stage and deliver an interactive program unlike anything the gaming industry has experienced before. Is there anything that you are implementing in education this year as a result of guests’ feedback?

AB: One major comment we’ve noticed, which has increased each year, is that many people – across all sectors of the industry, from commercial operators, tribal operators and suppliers – find it difficult to recruit and retain top talent. As a result, we began offering more leadership seminars. Last year, both sessions led by Bill Benjamin were in the top ten most-attended events of the entire show. When we saw how receptive guests were to Benjamin and his leadership-focused seminars, we decided to expand his role to further explore success, leadership, collaboration and improving performance.

KC: We’ve also expanded our coverage of esports and integrated resort topics. Sample sessions include The Business of Esports: Lessons from the Marketplace; Esports Opportunities: Looking Towards the Future, and Retail, Dining and Entertainment – Determining the Right Mix to Maximize ROI. What are you looking forward to this year in particluar?

KC: While the education and networking opportunities at G2E are

tremendous, the oﬀerings in the expo hall are the buzz of the show. It’s exciting to see the new technologies that debut and evolve from year to year not only in the core gaming segment, but also with gaming peripherals and integrated resort vendors. The industry is evolving quickly and there are some real hidden gems just waiting to be discovered in the expo hall.

What advice do you have for someone who is attending G2E for the ﬁrst time?

KC: Scope out the education sessions prior to the show and make a plan. Mark down your “must-attend” sessions of greatest relevance to your career and plan the rest of your G2E schedule around them. I recommend scheduling most of your meetings in the Expo Hall before you get to the event, as everyone’s calendars fill up quite quickly on those dates. Be sure to use our pre-show planning tool, My Show, where you can not only build your schedule but we’ll also recommend custom Exhibitor and Education Sessions based on your registration profile and what you are looking for at G2E. Another piece of advice is to attend at least a few of the networking events. The networking that occurs at G2E is an invaluable opportunity to connect with colleagues and business from around the world. Any final overarching thoughts on G2E 2018?

KC: Anyone who attends G2E 2018 will get an inside look at cutting-edge developments in slots, table games, security, iGaming, casino design, casino management systems, staﬀ resources and casino property marketing solutions. We’ll present strengthened educational programming on topics including tribal gaming, sports betting, illegal gambling, integrated resorts, esports, skill-based and next-generation games, regionalization, millennial customers and ﬁnancial compliance. If you want to accelerate your business and personal growth, you won’t want to miss G2E. :: cGi

KORBI CARRISON & ALLIE BARTH

Reed Exhibitions and the American Gaming Association (AGA) announced in February 2018 that Korbi Carrison was named Event Director for the Global Gaming Expo (G2E), the world-class international gaming trade show. Serving as the new event director, Carrison will be responsible for designing, building and delivering a dynamic experience to the tens-of-thousands of gaming-industry professionals who travel from around the world to attend G2E in Las Vegas each year. Allie Barth is the vice president of industry relations for the American Gaming Association (AGA). In her role, Barth leads the AGA’s educational strategy, advances member engagement to provide demonstrable value to the association’s member companies and professionals, and oversees the Global Gaming Expo (G2E) brand and portfolio of events: G2E Las Vegas and G2E Asia.

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IN-PLAY BETTING ::

ThE PsYchoLoGY of IN-PLAY sPorTs BETTING: A BrIEf ovErvIEw M

Mark D. Griﬃths

ost people reading this will be aware that in-play betting (also known as ‘live action’ betting or ‘inrunning’ betting) refers to the wagering on an event that has started but not yet ﬁnished. Here, gamblers have the option to continue to bet once an event has started, and adapt their bets depending on how the event is progressing (e.g., on a sporting event such as a football or cricket match).

Mark D. Griﬃths & Elizabeth A. Killick International Gaming Research Unit Psychology Department Nottingham Trent University

In-play betting first appeared towards the end of the 1990s when some bookmakers would take bets over the telephone while a sports event was in progress, and has now evolved into a popular online service in many countries. For example, in the UK, up to 25% of online gamblers have placed a bet in-play (Gambling Commission, 2016). The introduction of in-play betting has allowed bookmakers to increase the number of markets available to bet on during sports events, and gamblers are able to place bets based on many different types of in-game activity during the matches. For example, in football matches it is possible to bet in on in-play markets including the match result, half-time score, number of goals scored in the first or second half of the game, the number of yellow cards during the match, and the name of the goal scorers, etc. The availability of a particular sport and inplay markets varies from bookmaker to bookmaker. Researchers have previously referred to the role of structural characteristics in the acquisition, maintenance and development of online gambling behaviours (Parke & Griffiths, 2007). Structural characteristics are those features that are inherent within the game itself and include features that are responsible for reinforcement and may in some cases facilitate excessive gambling (Griffiths et al. 2006). These characteristics include, but are not limited to, bet frequency (the number of bets placed within a given time frame), event frequency (the number of CGiMAGAZINE.COM

:: iN-PlAY bettiNG

<< In-play sports betting has structural characteristics that have changed the mechanics of gambling for sports bettors, as they are now able to place a larger number of bets during a single sports game... >> gambling events that are available to bet on in a given period), and pay-out frequency (the time between the end of the betting event and receiving the winning payment) (Griffiths & Auer, 2013). In-play sports betting has structural characteristics that have changed the mechanics of gambling for sports bettors, as they are now able to place a larger number of bets during a single sports game (as opposed to a single bet on who is going to win). It has been argued that structural characteristics of an event, including higher event frequency betting, are associated with problem gambling (Griffiths & Auer, 2013; Harris & Griffiths, 2017). One of the most important differences between being able to place an in-running sports bet opposed to a pre-match bet, is that the nature of the market has been turned what was previously a discontinuous form of gambling into a continuous one (Griffiths, 2012; Griffiths & Auer, 2013). The gambling studies literature has suggested that in-play sports betting may offer more of a risk to problem gamblers because it allows the option for high-speed continuous betting and requires rapid and impulsive decisions in absence of time for reflection (Lopez-Gonzalez et al., 2017). Sports betting is one of the most commonly promoted forms of gambling in many countries and access to this marketing activity has been associated with sports betting problems (Hing et al. 2016; Lopez-Gonzalez, Estévez & Griffiths, 2017a). Advertisements often promote online sports betting as being easily accessible, anywhere at any time, using a mobile or other internet compatible device (Hing et al. 2017; Lopez-Gonzalez, Estévez & Griffiths, 2017a). There has also been a growth in inplay sports betting advertising. For example, within a sample of British and Spanish sports betting advertisements, in-play betting was prevalent in just under half of the adverts (Lopez-Gonzalez, Guerrero-Solé & Griffiths, 2017). One popular form of gambling advertising is the promotion of wagering inducements. These are often inducements that are promoted during a live event, and it has been suggested that doing so may promote impulse betting, where those placing a bet have an immediate chance to place the incentivised bet via a platform (Lamont, Hing & Vitartas, 2016). Inducements promoted during an in-match sporting event have been cited as a practice that may encourage in-play impulse betting intentions (Lamont et al., 2016). Gambling companies have been known to promote mobile betting over other forms of gambling in their advertisements

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(Lopez-Gonzalez, Guerrero-Solé, & Griffiths, 2017) by overstating the illusion of control that gamblers perceive when placing bets via their smartphones (Lopez-Gonzalez, Estévez & Griffiths, 2017b). A main cognitive heuristic involved in the maintenance of gambling behaviour is the illusion of control (Langer 1975). The illusion of control generates an expectency of success that is innapropriately higher than is objectively warranted (Langer, 1975). In-play sports has the potential to enhance the illusion of control because gamblers are often able to dictate the speed of play, the volume of betting, and amount of money wagered, which may enhance both psychological perception and investments of control over their sports bet placement. Whilst in-play sports betting features (such as the ‘cash out’ feature) are increasing in popularity amongst online gambling operators (Lopez-Gonzalez & Griffiths, 2016) and despite the growing body of research investigating the psychosocial and individual psychological factors determining gambling behaviour, much less attention has been devoted to understanding these factors in the context of in-play sports betting and the market characteristics of online sports betting. Given that so little research has been carried out, we recently carried out a systematic literature review to summarise all the studies that had examined in-play betting (i.e., Killick & Griffiths, 2018). Using a wide variety of academic databases, we found only 16 papers which included empirical data or theorised about inplay sports betting in the gambling studies literature. Thirteen of the papers were empirical and three of the papers were theoretical and/or commentary based providing some kind of critique of in-play sports betting (see Table 1).

Empirical studies on in-play betting Of the 13 empirical studies published, nine of them analysed actual gambling using behavioural tracking data (provided by the online gambling operator bwin) and four analysed self-report data from surveys.

Non-empirical studies of in-play betting A number of scholars in the gambling studies field have argued that structural characteristics of gambling, including activities with higher event frequencies, are associated with problem gambling (Griffiths & Auer, 2013; Harris & Griffiths, 2017). In short, those activities that can be gambled on continuously such as slot machines (which can have event frequencies of up to 30 times a

IN-PLAY BETTING ::

Table 1: Academic papers that discuss or empirically studied in-play sports betting (in alphabetical order of ﬁrst author)

STUDY/PAPER

METHODOLOGY

SAMPLE SIZE

Braverman and Shaﬀer (2010)

Behavioural tracking

530

Braverman et al. (2013)

Behavioural tracking

4,056

Broda et al. (2008)

Behavioural tracking

160

Brosowski, Meyer & Hayer (2008)

Behavioural tracking

27,653

Gray et al. (2012)

Behavioural tracking

2,066

Griﬃths and Auer (2013)

Theoretical

N/A

Hing et al. (2016)

Self-report

639

Hing et al. (2017)

Self-report

1,816

MAIN FINDINGS

In-play bettors who were categorized by high-intensity, frequency and variability of amount staked during their ﬁrst month of gambling were more likely to report gambling-related problems when closing their accounts.

Two groups of internet gamblers were found to have a higher risk of developing gambling-related problems. The first group engaged in three of more different gambling activities and showed high wager variability on casino games in their first month of using the gambling website. The second group participated in two different gambling activities and demonstrated high variability for in-play wagers.

Bettors who surpassed a self-imposed or default limit demonstrated a higher involvement in sports betting (i.e., bets per day and stake size). After receiving the notification, indicators of unfavourable gambling behaviours did not decline. There were no reported differences in the betting patterns of results for fixed-odds and in-play betting.

Gambling involvement levels, including gambling on multiple game types, were predictive of gambling-related problems. Engaging in in-play betting or poker were signiﬁcant predictors of at-risk gambling after controlling for multiple game involvement.

Online gamblers who triggered a responsible gambling alert were distinguished from control cases using indices of the intensity of gambling activity (e.g., number of bets per betting day, total number of bets made). Those who triggered the responsible gambling alert were likely to engage in in-play sports betting than those who did not.

The paper argued that structural characteristics, including event frequency, appear to be a contributing factor in problem gambling. It was argued that in-play betting had changed the structural characteristics of sports betting from one that was typically discontinuous (e.g., a weekly bet on the outcome of a football game) to a ‘continuous’ form of gambling with an increased event frequency that is associated with problem gambling.

The risk of experiencing gambling-related problems was associated with a higher number of bets being placed in-play, before an event has started; and on impulse before or during a match.

Impulsive sports bettors (characterised as having higher trait impulsiveness, more frequent sports betting behaviour, higher problem gambling severity and a shorter history of sports betting) were more likely to bet on in-play sporting events than overall match outcomes.

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:: IN-PLAY BETTING

STUDY/PAPER

METHODOLOGY

SAMPLE SIZE

MAIN FINDINGS

LaBrie et al (2007)

Behavioural tracking

40,499

LaPlante et al. (2008)

Behavioural tracking

47,603

In-play bettors placed on average 2.8 wagers of €4 every fourth day compared with ﬁxed-odds bettors who placed 2.5 bets of €4 every fourth day. Mean net losses were smaller for in-play bets. Those who bet in-play on sports (as opposed to those who bet before matches) were categorized more often as heavily involved gamblers.

LaPlante et al. (2014)

Self-report

1,440

Lopez-Gonzalez and Griﬃths (2017)

Theoretical

N/A

Lopez-Gonzalez and Griﬃths (2018)

Self-report

659

Nelson et al. (2008)

Behavioural tracking

567

Parke and Griﬃths (2007)

Theoretical

N/A

Xuan and Shaﬀer (2009)

Behavioural tracking

226

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Most of the sample demonstrated a rapid decrease in the number of bets made and the stake size wagered. Betting frequency was higher for ﬁxed-odds events. However, after three months, the amount wagered on in-play events surpassed wagers placed on ﬁxed-odds events.

In-play sports betting demonstrated a signiﬁcant relationship with potential gambling-related problems, after controlling for depth and breadth of gambling involvement.

It was theorised that the in-play ‘cash-out’ feature has structural characteristics that allows bettors to feel more in control of their bets and may make gamblers lose control of their bets.

Problem gambling severity was positively associated with (i) how much gamblers talked about betting with other people prior to bet placement, and (ii) how often online betting functions such as ‘cash out’ were utilized and time spent betting. In-play sports betting was found to be more prevalent among problem gamblers when compared to moderate-risk gamblers, low-risk gambler and non-problem gamblers.

Bettors who utilised a self-limit (SL) feature were more likely to prefer in-play betting on match outcomes opposed to betting on ﬁxed-odds events. Bettors who used the SL feature placed more bets per day but wagered less money per bet on in-play betting than non-SL players. After utilising the SL feature, subscribers reduced gambling activity. However, for sports-betting gamblers. The frequency, amount and percentage-loss of wagers did not change.

It was theorised that because of the change in structural characteristics that in-play gambling provided that in-play betting may contribute to problem gambling because of (i) an increase in perceived skill, (ii) within-session chasing on the same match or event, and (iii) by making the sporting events more interesting and/or exciting.

Prior to closing their gambling accounts, self-identiﬁed inplay betting problem gamblers, whilst experiencing increasing losses, were more likely to try to recoup their losses by increasing their stake per bets on events that had less risky (i.e., shorter) odds. A decrease in gambling frequency in-play problem bettors was observed prior to account closure.

iN-PlAY bettiNG ::

<< As can be seen from this brief review, the most commonly used empirical method of investigating in-play gambling behaviours has been via the use of behavioural tracking data... >> minute on an online slot machine) tend to have a much higher association with problem gambling than activities such as a biweekly lotto game (with an event frequency of twice a week) (Griffiths & Auer, 2013). In relation to in-play-betting, Parke and Griffiths (2007) were the first scholars to speculate that in-play betting may contribute to prolonged, excessive, un-planned, or problem gambling due to: (i) a growth in ‘perceived skill’ (through studying, analysing or spctating the betting event); (ii) chasing losses/winnings on the same or different sporting event by placing further bets during the event; and (iii) by making the sporting event more stimulating or exciting. Papers by Griffiths and Auer (2013) and Lopez-Gonzalez and Griffiths (2017) made a number of similar observations. Previously, bet duration (the time from placing the bet, until its settlement) was fixed. However, bet durations can now be amended via in-play ‘cash out’ features (Lopez-Gonzalez & Griffiths, 2017). In-play betting utilising ‘cash out’ features have the potential to make sports-bettors more vulnerable to cognitive bias (Lopez-Gonzalez & Griffiths, 2017). In the past, sports betting was typically a discontinuous form of gambling with the vast majority of sports bettors gambling weekly on the outcome of a particular event (e.g., a football match). However, some papers have specifically argued that in-play betting and use of the ‘cash out’ feature now allows sports betting to be a continuous form of gambling (Griffiths & Auer, 2013; Lopez-Gonzalez & Griffiths, 2017). This has radically changed the traditional sports betting market which was once a discontinuous (low-risk) gambling activity to a more continuous (high-risk) gambling activity. In-play sports bettors who experience gambling-related problems may feel more inclined to engage in less planned, impulsive, and immediate forms of gambling and the time between bet placement and the reward (or lack of) is greatly shortened (Parke & Griffiths, 2007; Griffiths & Auer, 2013). A paper published by Lopez-Gonzalez and Griffiths (2017) is the only paper that explicitly discusses the implication of in-play ‘cash out’ sports betting features. They suggested that one of the implications of ‘cash out’ in relation to problem gambling is that there is a conception of gambling on sports as an investment, like that of trading on the stock market. This was then confirmed empirically showing that sports betting advertisements contribute to self-perceptions of bettors as specialists of sports, promoting game analysis to beat gambling companies (Lopez-Gonzalez, Guerrero-Solé, Estévez & Griffiths, 2017). The notion that the bettor can view themselves as a professional that can improve their probability of winning may serve as a motivating factor to gamble (Lopez-Gonzalez & Griffiths, 2017). Problematic online

bettors have been found to consider themselves to be semiprofessional gambler, and in the case of horse racing bettors, they are more likely to self-report being a professional gambler (Hing, Russell & Browne, 2017).

So what do these studies tell us? As can be seen from this brief review, the most commonly used empirical method of investigating in-play gambling behaviours has been via the use of behavioural tracking data (although all of this has come from the same bwin dataset). Research published using the bwin dataset has reported that engaging in in-play gambling appears to be an important marker for gambling-related problems (LaBrie et al. 2007; LaPlante et al. 2008; Nelson et al. 2008). These studies described gambling-related behavioural factors associated with highly involved sports bettors (e.g., number of bets and the total amount wagered) and identified a sub-group of bettors who maintained a high involvement in online gambling via in-play betting (LaBrie et al 2007; LaPlante et al. 2008). Other studies found that participation in in-play sports betting is an independent predictor of problem gambling severity when gambling involvement is controlled for (Brosowski, Meyer & Hayer. 2008; Xuan & Shaffer, 2009). It was also found that gamblers who utilised an online provider’s limit setting tool were more likely to engage in in-play betting than other forms of gambling (Gray et al. 2012; Nelson et al. 2008). After setting a voluntary limit, those who previously participated in fixed-odds and in-play sports betting were more likely to stop betting in-play than to stop betting on fixed-odds selections (Nelson et al. 2008). Nelson et al. (2008) suggest that this could indicate that the players consider in-play betting to be more of a risk. Overall, the reviewed studies suggest that multiple, frequent and larger inplay bets appeared likely indicators that differentiated high-risk sports bettors from lower risk sports bettors. Although the results described using the bwin dataset allow for real life gambling behaviour to be studied, they are not without limitations. Firstly, studies that utilise these datasets did not describe the gamblers’ perceptions, clinical characteristics or the social consequences associated with their betting behaviour (Griffiths, 2014; Shaffer et al. 2010). There was no information provided about users’ income (Shaffer et al. 2010) and previous research has indicated that the impact of gambling is partially dependent upon the gambler’s financial status, therefore, it is necessary to consider the amount spent gambling in relation to the amount of money that is available (Gray et al. 2012). Due the lack of psychosocial information about the meaning and consequences of gamblers, it is not possible to infer any clinical CGiMAGAZINE.COM

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characteristics regarding the impact of internet gambling on the lives of individual subscribers (Griffiths, 2014; Shaffer et al. 2010). One disadvantage of using online behavioural tracking is that internet gamblers may also gamble both online and in person, for example, at casinos or other gambling venues, and are unlikely to gamble at just one site (Wardle et al., 2011). Therefore, estimates of Internet gambling usage may not be an accurate representation of how much Internet subscribers gamble (Shaffer et al. 2010). In relation to the self-report studies and non-empirical studies concerning in-play sports betting, researchers have constantly referred to the role of structural characteristics in the acquisition, maintenance and development of online gambling behaviour (Parke & Griffiths, 2007) and have demonstrated an association between problem gambling and such features as event frequency, bet frequency, and the speed of rewards (Griffiths, 2012; Harris & Griffiths, 2017). The gambling studies literature has suggested that in-play sports betting may offer more of a risk to problem gamblers because it allows the option for high-speed continuous betting and requires rapid and impulsive decisions in absence of time for reflection (Hing et al. 2014a, 2014b; Lopez-Gonzalez et al., 2017; Nelson et al. 2008). Therefore, in relation to problem gambling, in-play betting offers structural factors that may contribute to the development of gambling-related problems. These characteristics include, but are not limited to bet frequency, event frequency, event duration, and pay-out frequency. Research has found in-play betting to be associated with people who were categorised as problem gamblers (LopezGonzalez and Griffiths, 2018). Lopez-Gonzalez and Griffiths (2018) offered a potential explanation for this. More specifically, gamblers who are experiencing gambling-related problems may be inclined to place impulsive, less planned, and readily available forms of gambling such as in-play. However, using the data from the present studies is not possible to identify a causal link between problem gambling and the use of different gambling types due to the correlational and cross-sectional nature of the few studies that have been carried out to date (Lopez-Gonzalez and Griffiths, 2018). Understanding factors that determine in-play betting behaviour, including understanding the risk factors for problem gambling amongst in-play sports bettors, is an important area of research given the continuing growth of the online sports betting industry. Overall, research to date suggests that this way of gambling has the potential to be more harmful than other ways of gambling (e.g., gambling on fixed odds) because of the inherent structural characteristics. :: cGi References Braverman, J., LaPlante, D. A., Nelson, S. E. & Shaffer, H. J. (2013). Using cross-game behavioral markers for early identification of high-Risk internet gamblers. Psychology of Addictive Behaviors, 27(3), 868–877. Braverman, J., LaPlante, D. A., Nelson, S. E. & Shaffer, H. J. (2013). Using cross-game behavioral markers for early identification of high-Risk internet gamblers. Psychology of Addictive Behaviors, 27(3), 868–877. Braverman, J., & Shaffer, H. J. (2010). How do gamblers start gambling: Identifying behavioural markers for high-risk internet gambling. European Journal of Public Health, 22(2), 273–278. Broda, A., LaPlante, D. A., Nelson, S. E., LaBrie, A. R., Bosworth, L. B. &

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Shaffer, H. J. (2008). Virtual harm reduction efforts for Internet gambling: effects of deposit limits on actual Internet sports gambling behavior. Harm Reduction Journal, 5, 12. Gambling Commission (2016). In-play (in-running) betting: Position paper. Retrieved November 21, 2017, from: http://www.gamblingcommission.gov.uk/pdf/In-running-betting-positionpaper.pdf Gray, H. M., LaPlante, D. A., & Shaffer, H. J. (2012). Behavioral characteristics of Internet gamblers who trigger corporate responsible gambling interventions. Psychology of Addictive Behaviors, 26(3), 527– 535. Griffiths, M. D. (2012). Mind games (A brief psychosocial overview of inplay betting). i-Gaming Business Affiliate, June/July, 44 Griffiths, M. D. (2014). The use of behavioural tracking methodologies in the study of online gambling. SAGE Research Methods Cases. London: Sage. doi: 10.4135/978144627305013517480 Griffiths, M. D., & Auer, M. (2013). The irrelevancy of game-type in the acquisition , development, and maintenance of problem gambling, Frontiers in Psychology, 3, 621. Griffiths, M. D., Parke, A., Wood, R., & Parke, J. (2006). Internet gambling: An overview of psychosocial impacts. UNLV Gaming Research & Review Journal, 10, 27–39 Harris, A. & Griffiths, M.D. (2017). The impact of speed of play in gambling on psychological and behavioural factors: A critical review. Journal of Gambling Studies. Epub ahead of print. doi: 10.1007/s10899-017-97017 Hing, N., Li, E., Vitartas, P., & Russell, A. M. T. (2017). On the spur of the moment: Intrinsic predictors of impulse sports betting. Journal of Gambling Studies. Epub ahead of print. doi: 10.1007/s10899-017-9719-x Hing, N., Cherney, L., Gainsbury, S., Lubman, D., Wood, R., & Blaszczynski, A. (2014a). Maintaining and losing control during Internet gambling: A qualitative study of gamblers’ experiences. New Media and Society, 17(7), 1075–1095. Hing, N., Gainsbury, S., Blaszczynski, A., Wood, R., Lubman, D., & Russell, A. (2014b). Interactive gambling. Melbourne: Gambling Research Australia. Hing, N., Lamont, M., Vitartas, P., & Fink, E. (2015). Sports-embedded gambling promotions: A study of exposure, sports betting intention and problem gambling amongst adults. International Journal of Mental health and Addiction, 68, 2057–2066. doi: 10.1007/s11469-014-9519-9 Hing, N., Russell, A, M.T, & Browne, M (2017). Risk factors for gambling problems on online electronic gaming machines, race betting and sports betting. Frontiers in Psychology, 8, 779. doi:10.3389/fpsyg.2017.00779 Hing, N., Russell, A.M.T., Vitartas, P., & Lamont, M. (2016). Demographic, behavioural and normative risk factors for gambling problems amongst sports bettors. Journal of Gambling Studies, 32(2), 625-641. doi:

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10.1007/s10899-015-9571-9

Studies. Epub ahead of print doi: 10.1007/s10899-017-9727-x

Hing, N., Russell, A.M.T., Lamont, M & Vitartas (2017). Bet anywhere, anytime: An analysis of internet sports bettors' responses to gambling promotions during sports broadcasts by problem gambling severity. Journal of Gambling Studies, 33(4), 1051-1065. doi: 10.1007/s10899-0179671-9

Lopez-Gonzalez, H., Guerrero-Solé, F., & Griﬃths, M. D. (2017). A content analysis of how ‘normal’ sports betting behaviour is represented in gambling advertising, Addiction Research & Theory. Epub ahead of print. doi:10.1080/16066359.2017.1353082

Killick, E.A. & Griffiths, M.D. (2018). In-play sports betting: A scoping study. International Journal of Mental Health and Addictions. https://doi.org/10.1007/s11469-018-9896-6 LaBrie, R. A., Laplante, D. A., Nelson, S. E., Schumann, Æ. A., & Shaffer, H. J. (2007). Assessing the playing field: A prospective longitudinal study of internet sports gambling behavior. Journal of Gambling Studies, 23(3), 347–362. doi: 10.1007/s10899-007-9067-3 Lamont, M., Hing, N., & Virtartas, P. (2016). Affective responses to gambling promotions during televised sport: A qualitative analysis. Sport Management Review, 19(3), 319-331. doi: 10.1016/j.smr.2015.06.002 Langer, E. J. (1975). The illusion of control. Journal of Personality and Social Psychology, 31(2), 311–328. doi:10.1037/0022-3514.32.2.311 LaPlante, D. A., Nelson, S. E., & Gray, H. M. (2014). Breadth and depth involvement: Understanding Internet gambling involvement and its relationship to gambling problems. Psychology of Addictive Behaviors, 28(2), 396–403. doi: 10.1037/a0033810 LaPlante, D. A., Schumann, A., LaBrie, R. A., & Shaffer, H. J. (2008). Population trends in Internet sports gambling. Computers in Human Behavior, 24, 2399–2414. https://doi.org/10.1016/j.chb.2008.02.015

Nelson, S. E., Laplante, D. A., Peller, A. J., Schumann, A., Labrie, R. A., & Shaffer, H. J. (2008) Real limits in the virtual world: Self-limiting behavior of internet gamblers. Journal of Gambling Studies, 24(4), 463–477. Parke, J. & Griffiths, M. D. (2007). The role of structural characteristics in gambling. In Smith, G., Hodgins, D. & Williams, R. (Eds.), Research and measurement issues in gambling studies (pp.211-243). New York: Elsevier. Shaffer, H. J., Allyson, J. P., LaPlante, D. A., Nelson, S. E.,& Labrie, R. A. (2010). Toward a paradigm shift in Internet gambling research: From opinion and self-report to actual behavior. Addiction Research & Theory, 18, 270–283. Wardle, H., Moody, A., Griffiths, M. D., Orford, J. & Volberg, R. (2011). Defining the online gambler and patterns of behaviour integration: Evidence from the British Gambling Prevalence Survey 2010. International Gambling Studies, 11, 339-356. Xuan, Z., & Shaffer, H. (2009). How do gamblers end gambling: Longitudinal analysis of internet gambling behaviors prior to account closure due to gambling related problems. Journal of Gambling Studies, 25, 239–252.

Lopez-Gonzalez, H, Estévez, A., & Griffiths, M. D (2017a). Marketing and advertising online sports betting: A problem gambling perspective. Journal of Sport and Social Issues, 41(3), 256-272. doi: 10.1177/0193723517705545 Lopez-Gonzalez, H., Estévez, A. & Griffiths, M.D. (2017b). Controlling the illusion of control: A grounded theory of sports betting advertising in the UK. International Gambling Studies. Epub ahead of print. doi: 10.1080/14459795.2017.1377747 Lopez-Gonzalez, H., Estévez, A. & Griffiths, M. D. (2018). Internet-based structural characteristics of sports betting and problem gambling severity: Is there a relationship? International Journal of Mental Health Addiction. Epub ahead of print. doi.org/10.1007/s11469-018-9876-x Lopez-Gonzalez, H. & Griffiths, M.D. (2016). Is European online gambling regulation adequately addressing in-play betting advertising? Gaming Law Review and Economics, 20, 495-503. Lopez-Gonzalez, H., & Griffiths, M. D. (2017). “Cashing out” in sports betting: Implications for problem gambling and regulation. Gaming Law Review, 21(4), 323–326. Lopez-Gonzalez, H. Guerrero-Solé, F., Estévez, A. & Griffiths, M.D. (2017). Betting is loving and bettors are predators: A Conceptual Metaphor Approach to online sports betting advertising. Journal of Gambling

DR. MARK GRIFFITHS & ELIZABETH KILLICK

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 750 refereed research papers, five books, 150+ book chapters and over 1500 other articles. He has won 19 national/international awards for his work including the US National Council on Problem Gambling Lifetime Research Award (2013). Elizabeth Killick is a doctoral research student of Professor Griffiths at Nottingham Trent University (UK) and is currently writing her PhD thesis on marketing practices in sports betting.

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