Conference proceedings, Zurich 2023

the activities that we regulate generate in terms of the casinos. I did some research and found the revenue generated from casino activity to the Gaming Commission, the government gave the University of Puerto Rico US$600 million in the last 10 years, some tourism funds promoting Puerto Rico’s touristic destination received over US$500 million And in general taxation to the government of Puerto Rico over US$200 Millions. Some parts of our society consider gambling as a social evil and the distribution design was to make something good out of what some people consider bad. So it’s a good balance. And obviously, we offer the public strict regulation and a safe environment to bet. RJ: If I understand you right, Marc, you are looking at do you protect players and create an environment of gambling where they can have the joy of gambling not being dominated by the negative influences of it. And so we have in our legislation, a distinction between low risk lotteries, for example, and high risk games of chance, and slot machines. Land based and all kinds of online gambling is considered as high risk from a point of view of being compulsive or posing an addiction problem. On the other hand, also preventing immoderate playing and having huge losses within a short time. And we have a very extensive legal framework to protect players. So on one hand, trying to create an attractive legal offer, otherwise, you see people drifting to the black market where there are no restrictions and our licensees go through a tough license application process. On top of that, in our supervisory and enforcement activities, as I said, we have certain priorities related to protecting the player. Our key goals are preventing illegal activity and crime, protecting the consumer and preventing addiction. Of the checks that we perform, the license application is a very important one, before you are allowed to enter the market. And once having entered the market, we look for closely at the behavior of licensees. Player protection, duty of care, AML, targeting vulnerable groups via bonuses or advertising, and bring that together, that should create a safe environment. And on top of that, of course, we conduct a fight on illegal gambling, which is a continuous process. MD: Let’s talk about that, because I know there’s been a lot of discussion about advertising restrictions, but there also has been a lot of talk about player protection and stemming the illegal marketplace. So talk a little bit about how you as regulators guide policymakers on how to approach the illegal market. What tools do you need to stem the illegal market in your jurisdiction, both in terms of protecting the revenues so you have tax revenues, you have honest gaming and also protect the consumer. So how do you approach that as the regulator and how do you advise your legislative policymakers as they shape the master acts and decide the authority that you need? RJ: In the Netherlands I think one of the key words for us is deterrence. So what we do is monitor constantly the 100 biggest websites as visited by Dutch consumers. We give warnings, we give cease and desist orders. We give fines and those fines can be up to several million euros. Then it’s about discouraging facilitators, facilitators like payment service providers, or affiliate websites for advertising. Marketing that are being used. Quite recently, also, we cooperated with major platforms for illegal activity that we see on platforms, like Facebook, like Instagram, which is quite a new phenomenon to us. And we consider the opportunities of the new Digital Services Act because you also want to address illegal messages via Google or other platforms. When it comes to our advisory activities to government, when we see certain gaps or where are we lacking certain instruments we would like to have, for example, better ID verification or different investigatory powers over those websites like mystery shopping, then we advise the Ministry of Justice, and Parliament to pick up on that. And next year, we’ll have an evaluation of the first years of our Remote Gambling Act which is a splendid possibility to bring all our experiences together and of course, also experiences of the legislator, of operators, trade associations, and have an overall evaluation. MD: Caroline, would you have anything that you would want to add on that in terms of your jurisdiction and how you interface with your government colleagues to deal with illegal market participants? CC: Combatting illegal gambling is definitely a huge challenge. I think for every regulator, it would be. I don’t think any regulator will get to the point of saying they’ve got it right because the legal market is a direct competition for the licensed market. And they’re always coming up with innovative ways to beat the system. But in our legislation,

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