MM: And so this particular situation that I was describing maybe does not apply to you. But do you have regulators knocking on your door regularly to ask why you’re servicing a particular operator or what your thoughts are in this market? VH We sometimes have cases where an operator might show our logo on their website. And there might be cases where we don’t service that operator or we do service it, but in different markets. So for that particular market, our services are actually not available for the operator. We do have cases where the regulator, knowing that we only serve locally licensed operators in the market, checks in with us in that regard. These are cases that are thankfully quite easy to resolve with them taking the logo down. But we do experience it. MM: But how about in more gray markets where it can actually be difficult to be compliant? Do you receive letters from regulators in those markets too? VH: It depends on the case. It’s often not clear who can and cannot be serviced. We try to get comfortable by way of expert opinions, obtaining legal opinions as to who we can and cannot service. And in those cases where we have a strong argument that we might be able to support an operator who hasn’t been able to receive a license as in scenarios that were discussed earlier, it’s often possible to have a conversation with the regulator and clarify the position that we have, based on the legal opinions that we have received, and then see whether there’s any reason why we need to stop servicing them. MM: Coming back to a similar topic, do you see that regulators expect you to assist in other areas? I’m thinking, for example of player limits and the like. Is that something that regulators expect you as a PSP to look into as well? VH: That’s a very good example, actually. We do experience, especially more recently, that the obligation is more and more on payment service providers to implement deposit limits, which in my opinion, should ultimately sit with the operator rather than the PSP. It is of course, completely understandable that there need to be certain limits and we’re more than happy to support operators to implement the regulatory obligations like we do with credit card brands, for example. Or name matching requirements with the payer and the player to ensure that the person who pays into the account or receives a payout is the same person as the person that owns the play account. But ultimately, the responsibility should sit with the operator. They’re also in a much better position to analyze the player behavior. We don’t know how much their player wins or loses. They might use other deposit methods, we don’t even know how much they deposit in general into their player account. So I think it will be better to have an outcome-based approach with regard to player protection limits, rather than to have fixed limits for deposits because it always depends on the customer and how much are they able to afford. That’s why the operator is better suited as well. MM: Do you know the operators’ opinions about this? Would they like to put that responsibility on you, or are they happy to do it themselves? VH: From what we experienced, they’re happy to do it themselves. But of course, where there’s certain deposit limits, or credit card bans, etc, they need to rely on our support as well to make it happen, because otherwise it will be impossible. MM: Are game suppliers expected to take similar responsibility in the UK? I’m thinking not just then technical compliance, but game design and making sure that the games are safe and not too exciting. SB: All that will probably change, as we consult under the White Paper over the next year or two, but their focus will be on remote technical standards, reality checks and limits. That will be a key focus of game suppliers. Take, for example, speed of play. That has to be embedded within the requirements of the host, say the casino supplier that’s licensed. And there’ll be a tension between what the operator wants and what the supplier is able to provide in terms of the commercial relationship and how much money then is made out of the customer. But it will not pass muster with the Gambling Commission if it is non-compliant with current rules and recommendations. MM What I’m hearing from this panel about B2B providers contribution to enforcement, it is that some contribution
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