ILLEGAL GAMBLING
3. Work with other regulatory bodies
The reality is that the industry has long bought into the concept of regulation and shares almost entirely the same objectives as the regulator. So regulators are not acting meaningfully or reasonably if they are not talking to the industry which has a deep understanding of the black market and the technology being employed now, and into the future, to drive it. Finally, we have seen examples of regulators using incorrect data to justify regulatory actions or to drive misleading messaging, fears or requirements. Examples of this include studies relating to gambling harm and the prevalence of the black market. Regulators owe it to their licensees and their communities to be more objective.
This is already happening to an extent, as more regulators enter into MOUs with those in other markets to combat acts of illegality. More can be done to target the black market more actively and deliberately in tandem with other regulators with industry input so that the steps taken to reduce this market are more effective. Investigations have shown that where black marketers operate under the cover of a ‘license’ these tend to be from the same regulator(s). Regulators from more reputable markets should work hard to engage these regulators, encouraging them to take action against offending operators. Conclusion Despite the legalization of gambling around the world, the black market is still ubiquitous and shows no obvious signs of slowing down. This illegal market works against the interests of responsible regulation in that it neither protects customers, limits criminal conduct nor garners fiscal revenue. The global black market impedes and threatens the ongoing commercial viability of regulated, lawful operators, and encourages criminal activity. For the reasons we have outlined, regulators, whilst talking about the issue are having limited success in disrupting the black market. They continue to give undue prominence to the wrong voices, misuse statistics, misunderstand the black market ecosystem and, significantly, fail to engage meaningfully with regulated operators. Regulators will only be effective in this crackdown, and be seen to be effective, when they engage meaningfully with the industry with which they share common objectives. When they do they will gain a mountain of experience and discover an eagerness to help.
2. Request the assistance of the Industry
An extension of the above point, engaging the industry in meaningful consultation and discussion will provide regulators with more relevant data, different solutions and alternative approaches. These could include: A joint industry-regulator marketing campaign drawing attention to the issue of the black market, the risks attached to playing on black market sites and ways to best access regulated sites; • A better understanding of the methods • utilised by black market operators including use of social networking sites and cryptocurrencies. This could extend to discussion of how to combat these and how to recruit tech companies payment service providers to be part of the solution • A fuller appreciation of the regulatory agencies, banking and payment service providers, B2B providers and affiliates that are servicing, or facilitating the black market
ANTONY GEVISSER Senior Vice President for Legal and Regulatory Affairs, Super Group For more information contact antony.gevisser@sghc.com
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IMGL MAGAZINE | DECEMBER 2024
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