can be considered. But although you said it can help, it will not stop the black or illegal market. So, million-dollar question. What is a more efficient way of stopping the black or illegal market? SB: I don’t think you can ever stop the market entirely, but maybe a reduction of the market. Taking Vanessa’s example of using the payment service providers to reduce limits and do the operators’ job, it will have an effect but I think there will always be a black market because it’s like water, it finds an egress somewhere. I think if there needs to be genuine cooperation between what you need to be doing to be a responsible operator, a responsible supplier, and there is cooperation without the threat across boundaries. One of the issues with the UK is that they’ve set as a priority for themselves this year, the elimination of the black market. And it’s a philosophical statement that’s laudable but what does it actually mean? For licensees under the UK commission, you mustn’t do this, but you can still do that and I’m not going to tell you you can’t deal with the black market. What is the licensee supposed to do with that sort of guidance? I think if you focus on things like AML, Responsible Gambling, responsible business relationships, and you have the best ecosystem with a good regulation and collaboration across borders, then I think you hit it just from a pure crime, money laundering/ terrorist financing point. And then I think you have to leave some businesses to find their own level as to what they consider an appropriate third party counterparty. But you can’t go blind into those relationships. They have to be reasonable, proper, third parties: that is all you can do. Try and lift the bar a little bit but threats to use everybody in the system as policemen, I just think are unrealistic and won’t work. MM: Peter, how is it in the Dutch market? What works when it comes to enforcement and do you have any advice for the KSA on how to do things better to stop the illegal market? PPG: I think channelization is an effective tool to fight illegal gambling. It is a balancing act to make it safe and responsible for people to gamble online with licensed operators, whilst not putting too many locks on the door and scaring people out of the legal market. I don’t have the answer, but what I would say is that I haven’t seen any market where limits are the solution to illegal gambling, or Responsible Gambling for that matter, I think it’s a bit of a red herring, to be honest. So hopefully, there will be a market and maybe it’s the Netherlands that gets limits right. Limits are part of a total set of measures that you should use, but it’s not a silver bullet. Politically, it’s really nice to say ‘you should not spend more than 200 euros per month’ because that’s politically a very viable statement. But, when you look at it it’s a bit silly, really. But speaking on behalf of my members as well, we want to be protected by the government, from unfair competition by illegal operators. So apart from the protection that consumers deserve, we also would like to receive protection. MM: I think it’s a very interesting development in the gambling industry now that we have more and more regulated markets we hear from the Responsible Gaming industry the same arguments we heard from monopolies a couple of years ago. We need to be protected because we are the responsible ones. This time around, I think it’s maybe more correct. PPG: You’re right but there’s one big difference which is if there is no open and transparent system where you can apply for a license fair and square, then the argument is less valid. But if you can be a legitimate and licensed operator and you choose not to do so, then in my book, you should face the consequences. MM: Thank you for that very good point. I would like to ask you to give a warm round of applause to this fantastic panel Thank you guys.
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