specific rules on KYC, or to understand the training of the AML officer. And actually, without big complaints, everyone is implementing these requirements and taking into account the new guidance. So I think this is the way to go, it shows that the process can be successful, and much more efficient. JK: There seems to be a trend towards the imposition of bigger fines. So if we look towards North America, is that a trend that we’re just going to follow because we almost inevitably do so? Are we going to go with the big fines? Birgitte, did you impose any big fines in your time? BS: We did issue fines but we weren’t allowed to share it. That was the legislation in Denmark at the time that we couldn’t tell. But that’s half of the impact that sanctions are supposed to have. So of course you need to be able to tell, but we couldn’t at the time. I think the trend is a dangerous one and sometimes I worry if everybody is looking at each other and copying each other without taking a step back to consider what are we all getting ourselves into? Is this actually about the legislation or the regulation not being able to express exactly what they want to put down? Understandable requirements or fair, realistic requirements? So have you failed in some way to communicate with industry, so they feel they need to provoke you, or simply run the business as they best can, with or without you? And then you end up in court? Either way, it’s a sad thing. I think we all need to be skeptical about sanctions. It’s a serious matter. It’s not so much the money itself, but it’s the reputation and damage for business, not only in your own jurisdiction, but worldwide nowadays. It’s not only local or European. If you sanction a company, it will hit Australia in a minute. So I think you have to be extremely careful. Is this actually a fair sanction for wrongdoing or not? JK: Martin, what we’re seeing in Europe is the vindication of the consumer with the recent push from Europe to put in place group representative action so that people can vindicate group rights. Is that going to have an impact here on the sector? MS: I’ve been pushing consumer protection in the field of gambling for 20 years but I’m going to be a bit tough here, maybe a bit shocking. Gambling policymaking is summed up in four words: Give Me The Money. Everybody wants a share of the money and where does the money come from? The money in the end comes from gamblers, from people who are gambling. So who are the people who need to be protected? We’re always talking about the young and those people who have addiction problems, and so on. But the biggest group of people who need protection are consumers, people who are consuming gambling services. And I 100% agree with what you say that consumer protection in the field of gambling is an absolutely essential future development. JK: Matthias are your clients doing enough in that regard do you think? MS: Our regulation is very prescriptive with a lot of safeguards in terms of all sorts of limits that are required: €1000 maximum deposit limit, for example, weekly spending limits that operators have to abide by, so I would say the licensed operators are mostly doing a good job in implementing that. Putting my litigator hat on, there’s also a kind of a corporate and liability angle. It may be an unromantic thing to say, but operators may also want to have good consumer protection and player protection policies in place, because if you don’t, you might find players suing you. That is a trend we obviously see in Germany and that we’ve seen in Austria now for a few years, where, in some cases, there are issues with EU law and how national regulation complies with EU law. But if you’re in such an unclear situation and don’t have good consumer protection and player protection practices in place, then, of course, the other side will have a better argument before the court. They can say the operator didn’t care for us, they should have seen that my clients spend €50,000 on gambling. So this is why it makes sense for operators to have these policies in place. JK: Birgitte do you have any advice for our new Irish regulators? What should they look out for? BS: I think actually, they should be here. That’s what you need to do. You need to be out of the office and you need to get your people out of the office and into the real world. It sounds so simple but if you don’t get down from your high horse then you won’t succeed. And you will have a growing illegal gray market around you because you don’t have the
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