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European Gaming Congress 2024
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Compliance Updates

Special Interview: A Conversation with Tom Farrell, CMO of ClearStake

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Affordability is currently the word on everyone’s lips. Operators continue to face a ‘sustainability conundrum’ – they must fulfil their regulatory obligations and commitments to player protection, while ensuring their business remains profitable. For many, affordability can spell disaster, with up to 90% of customers lost when asked to prove they have the money they are wanting to spend. However, using Open Banking to carry out these financial checks as quickly as possible may be the answer to boosting retention and retaining otherwise lost revenues.

The DCMS recently published a public consultation on the UK gambling White Paper, while the Gambling Commission launched its own on financial risk checks, bringing their importance of affordability to the top of the agenda – but operators must now strike the balance between minimising harm and maximising revenue. Affordability checks that take too long risk sending customers to competitors, or worse, the black market.

One of the key remedies to the high level of churn experienced in the past is making sure financial risk checks can be carried out quickly and with as little friction as possible, so that customers can complete them with as much ease as approving a payment while online shopping. Operators have to reach a decision quickly because the longer players wait, the more likely it is they will go elsewhere while they’re waiting.

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Of course, there are some people who under no circumstances will share financial data with someone like a gambling operator. There’s also a group of people who won’t share data because they know they are gambling beyond their means. This is of course the system working as it should and that’s a good thing. But there’s a third group of people for whom it’s too much effort. They’re asked to provide bank statements, at which point they go to a competitor, as the hoops they have to jump through are not worth it.

For a customer using Open Bank technology, such as ClearStake, what used to involve downloading and printing bank statements and a wait while the operator reviews the data, now takes just 30 seconds and a few clicks. A decision is recommended to the operator immediately and theoretically, the whole process can take less than a minute. Players click a link, and they are taken to a super slick and simple process where they press a couple of buttons and the relevant financial data is shared securely. They are always in control of their data and they can revoke permission at any time.

Our software categorises every transaction and we can calculate whatever the operator wants to see. It could be disposable income, net gambling spend, total income, or current balance on the account. Our software can also evaluate the rate of change so operators can see accelerating gambling spend or consistently declining savings and work out if the player’s gambling activity is still within the safe bounds of their current financial position.

Without responsible gaming and Enhanced Due Diligence (EDD) checks, gambling risks being over-regulated out of existence as the product will become unprofitable. To answer the sustainability conundrum many operators face, we need to find a middle ground. Sustainability means not letting people spend beyond their means. It means letting people have a bet if they can afford to, while not taking more money than they can spend.

Over the last two or three years, the Gambling Commission got strict on affordability checks. They asked operators how they know someone could afford to lose ‘x’ amount. The White Paper effectively agreed with the Gambling Commission and has clarified that if someone is losing £2,000 in the space of three months or £1,000 in one month, operators should be confident about the player’s financial situation. The headline was that affordability and EDD checks should be taking place.

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This discussion around affordability is not only limited to the UK, and we are seeing lawmakers and regulators in several other countries considering measures in this area.

The industry therefore needs to be proactive as the problem will never go away if it keeps allowing people to bet money they don’t have. In the public mind, gambling will have the same fate as cigarettes which are currently being regulated out of existence.

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Philippine Senator Pushes for Inquiry into Banks’ Role in Pogo Funding

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Philippine Senator Sherwin Gatchalian has proposed Senate Resolution 1193 to investigate the failure of local banks to detect POGO-related suspicious transactions tied to criminal activities, following the case of former Bamban, Tarlac Mayor Alice Guo.

Gatchalian, in his resolution, highlighted bank transactions involving Guo’s companies, which amounted to hundreds of millions of pesos and allegedly funded the construction of a POGO hub in Bamban. The amount far exceeded the financial capacity reflected in the companies’ financial statements.

He pointed out a significant increase in cash flows, check disbursements, and transactions involving Guo’s accounts, peaking in 2020—an anomaly given that the COVID-19 pandemic had severely disrupted businesses and economies worldwide.

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Gatchalian noted that despite these large transactions, the banking system failed to flag them as suspicious. He raised concerns about the banks’ inability to report such dubious activities, questioning the effectiveness of their internal controls and procedures for identifying and reporting suspicious behaviour.

The senator emphasised that financial institutions are responsible for analysing financial data to detect transactions that may indicate money laundering.

These circumstances, according to Gatchalian, raise doubts about the adequacy of current Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regulations and guidelines for banks and financial institutions.

Gatchalian also pointed out that the Philippines remains on the Financial Action Task Force (FATF) grey list. The country must improve its AML/CTF efforts, including prosecuting money laundering and terrorism financing, addressing beneficial ownership information and strengthening cross-border declaration measures.

While President Ferdinand Marcos Jr. has instructed all government agencies to meet the necessary requirements to remove the country from the FATF grey list, Gatchalian stressed that private sector compliance is equally crucial to strengthening the country’s AML/CFT regime. This includes increased adherence to obligations, such as reporting covered and suspicious transactions.

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Compliance Updates

Spillemyndigheden: Status on Expected New Rules for Charity Lottery and Liberalised Land-Based Bingo

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On 20 March 2024, the government and all parties in the Danish Parliament reached an agreement on lotteries and liberalised land-based bingo. A bill to implement the agreement is expected to be presented when the Danish Parliament reopens in October.

Status on New Rules
A draft bill was sent out for consultation before the summer holiday, and the consultation period has now expired. The bill is expected to be presented when the Danish Parliament reopens in October.

The Ministry of Taxation will also send out a draft of a new executive order on charity lottery and an executive order on liberalised land-based bingo for consultation. It will appear on the Danish Gambling Authority’s website when it is possible to submit consultation responses to the executive orders.

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“At the Danish Gambling Authority, we are working to be as ready as possible when the new rules are expected to be finally adopted later this fall. The Ministry of Taxation is in charge of the creation of the new rules, so for us at the Danish Gambling Authority, it’s about being prepared for when the new rules will be implemented,” the Danish Gambling Authority said.

“Among other things, we are preparing a new application process for charity lottery. Through a series of questions, it guides applicants to apply for the right licence for their lottery. It will also prepare them to comply with the rules once the applicants have been granted a licence and then hold a lottery.

“We are also preparing the application process for liberalised land-based bingo.

“As part of the preparations, a communication network has been established with representatives from a broad group of stakeholders. The purpose of this network is to target the guidance efforts so that the Danish Gambling Authority can provide the best possible guidance to associations, companies and others who want to hold a lottery for a good cause.”

Webinar on the New Rules for Charity Lottery
As part of the guidance efforts, the Danish Gambling Authority will host a webinar on Tuesday, 26 November 2024 from 1 pm (The webinar is in Danish). You can register now by sending an email to Simone Wellendorph Lehmann at [email protected], no later than 24 November 2024 at 12 noon.

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The webinar will not cover the rules for liberalised land-based bingo. There will be separate guidance on this area. The webinar will be canceled if the bill is not passed at this time. If it is cancelled, it will be announced on the Danish Gambling Authority’s website.

Transition Phase from the Current to the New Charity Lottery Rules
In the draft bill that was sent out for consultation, it is planned that applicants will be able to apply for a licence under the new rules from 21 November 2024 with a possible start date for the licence from 1 January 2025.

If, due to planning or similar reasons, an applicant needs to apply for a licence before 21 November 2024, but does not want to hold a lottery until 2025, according to the draft bill, the applicant will receive a licence under the current rules, but with the option to let this licence lapse and then apply for a licence under the new rules after 21 November 2024.

The post Spillemyndigheden: Status on Expected New Rules for Charity Lottery and Liberalised Land-Based Bingo appeared first on European Gaming Industry News.

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Compliance Updates

JCM Global Awarded License by New Mexico Gaming Control Board

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JCM Global (JCM) has successfully passed regulatory review and is now licensed by the New Mexico Gaming Control Board. This license enables JCM to sell and service customers directly throughout the state.

This license is the latest in JCM’s wide array of awarded gaming licenses across North America and around the world and underscores JCM’s commitment to holding itself to the highest regulatory standards. JCM now maintains more than 170 active gaming licenses.

“Achieving this licensing in New Mexico clearly demonstrates that JCM is willing to meet our customers where they are. Our mission is to give every customer the best possible service and support, and now we can provide that directly for our industry leading transaction and automation solutions throughout New Mexico instead of through third party vendors,” said Dave Kubajak, JCM Global SVP Sales, Marketing, and Operations.

JCM provides a broad range of products to casinos in New Mexico including iVIZION and UBA Pro bill validators, GEN5 thermal printers, ICB Intelligent Cash Box System, FUZION system with AML monitoring, and DSS Digital Signage Solutions.

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