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done something interesting in, say, a different sector on a particular data science technique. Sometimes, you want to bring that in-house to create a team environment and give them a context within which they move forward, which can be easier within the organization. But you also need certainty. If I want an answer to a particular question, I don’t want to wait six months to recruit the skills to deliver it. SP: IAGR is handing out its awards this evening celebrating excellence in regulation. Have you seen examples of best practice either around data or in other areas in different parts of the world? BH: I try not to talk about best practice. When talking to our members, I’m not there to tell them how things should be done. I’m there to encourage a conversation and a dialogue and get them to share what they’re up to, how they’re doing it and why they’re doing it. That way, people can look at the various approaches and decide whether that’s something that would work for them too. To take the data example, do I want to have every single transaction with every operator in my jurisdiction? Or do I need a different level of detail to enable me to measure the outcomes that I’m interested in? It’s less about best practice and more about sharing lots of different examples of people doing things that are working. I think there’s often a lazy narrative around regulators being slow and turgid compared to an industry which is light and agile and chasing innovation. From what I see, things are much closer than that. When you listen to the debates that regulators are having here, they clearly have an interest in responding quickly to market challenges. There is no desire to move slowly. Sometimes, that happens because of legislation. But you hear a lot of voices asking how can we create a framework for a new product and move that through quickly. How do we respond with data faster than we’ve been able to before? How do we evaluate the impact of what we’ve done faster so that we can change direction if we need to as we go forward? That’s one of the things I’ve learned, particularly over the last year, as I’ve talked to more and more people. I’ve had the chance to learn how they think and what they want to do, and you see some of
it starting to come through at conferences like this and in the collaborative work we’re doing. SP: Interesting that you mention collaboration, is it now an obligation for regulators to cooperate internationally or is it still possible for them to view their market in isolation? BH: As we have already said, while we share many similarities, every jurisdiction is slightly different, and there could be good reasons why a jurisdiction decides to be more insular. That said, when you can share your own experience, have it questioned and debated, and then listen to the experience of others, you naturally become better informed and build the evidence base to push forward in your own market. SP: The issue of international collaboration and cross border information sharing has been discussed here at numerous sessions particularly when it comes to enforcement. How do you see this developing with jurisdictions sharing information and acting together to drive out illegal gambling? BH: People would probably be surprised at how much information is already shared between regulators. It’s not something that surfaces very often in public discourse, but I know, for example, that different jurisdictions have been signing MOUs with each other this week. And these MOUs are starting to look very different from those that were signed, say, five years ago. One area concerns the potential to share information where a bad actor is in one regulator’s jurisdiction. They can ask a question of another and then start collectively to bring more influence to bear on that actor. But I think regulators are far better informed now, from the point of view of enforcement than they were two years ago. It’s the kind of activity that goes unseen. There has yet to be a landmark case where this type of information sharing has materially come to light such that people would think more about it. However, considerable dialogue has been going on between regulators. SP: MOUs are the formal and legal ways that we record ways of communicating and exchanging information, but what is realistically possible outside MOUs?
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IMGL MAGAZINE | DECEMBER 2024
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