Conference proceedings, Zurich 2023

see more action happening on the social media influencers that are booming and that are pushing in a very cautious way, but they are pushing the offer of gambling services. And this is happening without not many consequences. AS: So we see that there are different criteria, different interpretations across the different jurisdictions and in Spain, for example, we have a general prohibition: advertising using famous individuals in gambling advertising is prohibited. From that general prohibition we have practical scenarios and the interpretation of our regulator which advertising simply a market on social media. Let’s say Federer wins 3.5. That’s already advertising with famous individual that’s already going against that prohibition of advertising with celebrity is extreme. So an individual who is known by certain qualified groups of people, depending on their hobbies or interests, like for example, let’s say an artist acting in the region of Valencia, already a famous individual, and that’s already doing advertising, we aren’t even talking about the number of followers for an influencer. I mean, it’s extreme. That’s insane. And it’s useless, in my opinion, because the operator will not promote its services, but some random operator with offices in some shady jurisdiction will just do it anyway. Then even if he gets a notification from the authorities, you will just shut down the office, open a new one in the next door and keep pushing. TB: If you’re using social media, and you’re using someone that is putting his or her account at risk, then that’s an element of pressure. I mean, right now in Argentina, the discussion is on social media and influencers, we got to a paradox where Meta was not allowing licensed operators to advertise. But it was allowing unlicensed operators that hold the license elsewhere to advertise. And we are in a situation right now where you can log into Meta, you can see people playing bingo, real time broadcasting with a piece of paper and a pen, and nothing is happening. QM: This is this is the paradox, I’m happy you mentioned this, because going back to the advertising ban, the advertising ban stipulates that it applies only to companies whose registered offices are in Italy. And two companies who, whilst they are registered abroad, hold an Italian license, which by default means that all the rest is far west. TB: And that is the point. I mean, you do the whole investment as a company to enter into a licensed jurisdiction. You play by the book, you comply with everything. And then you see all these competitors are running past you. But going, I think that one key element that probably links back to the other panel with licensing of suppliers. I mean, licensing of social media actors may not be as effective as actually enforcing account closures in cooperation with Meta. We are having the situation of famous people in Argentina that are broadcasting on Instagram, how they play when they come up from return from their holidays, now, everyone went on holiday to Europe, and they were coming back and they were showing how they are playing in a Casino and that is an issue. And there is a very different approach depending on the amount of followers the account has. And furthermore, that the whole regulatory framework was designed to be applicable to operators and not to the other participants in the industry. Furthermore, there’s no federal authority, you have to go local. And that is another element. AS: A quick one for you Yanica. From your experience, then, what recommendations can you give to the policy makers in order to better control the situation? For example, as we see in Argentina, with social media, and from your side, affiliates are also crucial in order to fight against illegal gambling? Well, we spoke about this also. But if you can say some actionable steps, how can you promote legal betting and at the same time, incorrect, illegal betting? YS: I won’t dare make any recommendations to any regulator. But what would be very helpful, and I think that’s what we can just summarize these past 20 minutes is probably it would be very helpful if we had prescriptive rules. First of all, what is an influencer? Who is an influencer? We seem to have a very low bar for famous these days. How can you decide if someone is actually famous and on the basis of what is that person, perhaps attractive to us or to vulnerable people? Is it the demographic of the following? It would be very helpful if we had some form of guidelines, and together we operators could follow those guidelines and regulators could hold operators accountable to those guidelines and probably have a more coherent and compliant system for all. So that’s probably something we’d all like to see. Then, the best advice I could give to regulators in general is “Be sensible, be realistic”. It’s okay for a regulator to want advertisers and influencers and affiliates to register to have a license, whatever they feel more comfortable with.

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