There is also an approach part to it in the way that our enforcement cycle works. In fact, sometimes we’re criticized in the media because we have a flurry of enforcement actions. There’s a reason for that because it goes in cycles. First, we try and explain what we expect out of our licensees in terms of a particular requirement. Then we start briefly looking into how they are complying, and if we see non-compliance we will normally start with warnings. In fact, we publish the amount of warnings that we issue per year in our annual report. Then after that, if we see that there is some lack of clarity, and because we expect our operators to be transparent, so we should be as well, right. So if we see that there is lack of clarity from our side as to what we expect, we will issue that clarity, then in the subsequent set of examinations we’ll start issuing the fines. If it is something that is severe, you will see notices of suspension, etc, until such time as that is embedded. So those are the two reasons why they’re very specifically low fines. I think, the larger and more punitive the penalty, the more important it is that the sort of protections of right to a fair trial, representation etc, are respected. And I think it is very common for regulators to, whilst I’m not suggesting that they don’t generally operate professionally, I think there’s a lack of understanding about the application of the Human Rights Act, for example, in the UK, to what they’re doing as a regulator. And the bigger the fine gets, the more important it’ll be and they may end up being challenged, whichever jurisdiction it might be. Questioner: This comes down to the minimum size of a regulated market. So in other words, if the black market has a reach bigger than 50%, let’s say, people shouldn’t find themselves prohibited in such a case, because that would obviously be unfair treatment as they have to compete on the black market. So if you haven’t created the circumstances for a proper regulated market, should you really be in a position to punish operators who would seek to offer legitimately the chance to gamble in circumstances where they either can’t get a license or haven’t yet got a license? BS: You have to do both. You’re a unit and that’s what we do. In Germany we have on the one hand a strict regulation for the legal operators and on the other hand, we are strictly going on combating illegal gambling. And so, we actually have in Germany a black market of round about 15% and we are very successful in payment blocking and so on against the illegal gambling and that it’s on the one hand very important. On the other hand, for the player protection, you need a strict regulation to the legal companies. Questioner: How do you arrive at a measure the 15% for the black market when it is so easy German for customers to play with operators from anywhere. BS: When we are talking about combating illegal gambling abroad, we think that we will be successful with the payment blocking because the consumer will not play at a gambling operator if they have not the opportunity to pay by credit card or by PayPal or so on. And on the other hand, we hope that we can start in a few months IP blocking. The regulation is with court, but we are optimistic that we will start with the IP blocking in a few months. In these cases it is very difficult for us to operate with financial sanctions. So, we will combating the illegal gambling in this field with other measures. On the 15% I think it will take too much time to describe fully, but we observe the market and we compare the clicks of the internet sites and so on. And so we make a calculation of several facts and figures we get on the internet and so, yes. We have a discussion, the operators and other stakeholders in Germany, how to map them on the black market. NN: the question is should the gatekeeper be able to apply far greater scrutiny at the time they issue the license as well, That’s certainly something that could be set up in the UK where until quite recently, they were giving licenses out with very little scrutiny. You had much greater scrutiny when you had acquired an operator license than if you were to seek a license. Carl, what’s your observation as a regulator to that, CB: From our end that has made the difference depending on the period of time. We’ve learned over 20 years now of online gaming, I can’t say we’ve always had fantastic onboarding, I would say we’re still not perfect for sure. But over time, you do learn what you need to look into and but it’s damned if you do damned if you don’t give a license we are criticized for not receiving enough applicants. But I take that as a compliment. You can design a policy and be well
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