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2018 ISSUE 35



Welcome... Publisher Jamie Kean jkean@cgimagazine.com Client Services Director Tracie Birch tbirch@cgimagazine.com Editorial Assistant Harry Wainwright hwainwright@cgimagazine.com Production Designer Nancy Rae nrae@cgimagazine.com Circulation Manager Natasha Harvey nharvey@cgimagazine.com Commercial Director Daniel Lewis dlewis@cgimagazine.com Account Manager Nathan Charles ncharles@cgimagazine.com

Editorial Contributors Richard Williams, Susan O’Leary, Mark Halstead, Amy Riches, Sabrina Soldà, Anthony Ure, Marion Gamel, Mark Griffiths, Michael Auer, Darin Oliver.

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s we come towards the end of another successful year at CGi

and with 2019 planning well under way for everyone, we are

excited to welcome another host of industry leaders for our

final quarterly edition of the year, all willing to share their thoughts,

ideas and wisdom with us, as we approach the festive season.

Richard Williams (Joelson), opens things up with a detailed

analysis of age verification and how the Gambling Commission looks

determined to tackle the risks of underage gambling. Susan O’Leary

(Alderney eGambling) shares her thoughts on regulation and licensing

and how it benefits both operators and suppliers.

Mark Halstead (iSoftBet) discusses regulated, regulating and newly

regulated markets, whilst Amy Riches (Evolution Gaming) takes a look a

at the incredible rate of change that live casino has seen over the last 12


Sabrina Soldà (BtoBet) analyses the emerging African market and

the obstacles iGaming operators are having to overcome, whilst

Anthony Ure (Isle of Man Department for Enterprise) looks ahead to

what the Isle of Man is planning over the next 12 months.

Marion Gamel provides us with a detailed explanation of the OKR

technique and how she believes it can help set communication goals and results within organisations.

Mark Griffiths & Michael Auer share their thoughts on limit

setting, whilst Mike Kenward (GamCare) discusses current responsible

gambling issues.

And to conclude, Darin Oliver (Blockdraw) introduces us to a new

blockchain coin offering that is currently being developed.

ISSN 2398-4252

© 2018 Danancy Media Limited. The opinion expressed in each article is the opinion of its author and does not necessarily reflect the opinion of the publisher. Any form of reproduction of any content in this publication without the written permission of the publisher is strictly prohibited.

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Jamie Kean, Publisher The next edition (Issue 36) of CGi will be published on 1st February.



Partnership, Assistance and Guidance for your daily operational needs.







Betting on Better age verification: next steps from the gamBling commission richard Williams, Joelson


Why have a licence if you don’t need one?


the opportunities and challenges of entering neWly regulated markets

susan o’leary, alderney egambling

mark halstead, isoftBet


a neW era of live casino


navigating africa: its challenges and Benefits

amy riches, evolution gaming

sabrina soldà, BtoBet CGiMAGAZINE.COM















Anthony Ure, Isle of Man Department for Enterprise

Marion Gamel

Mark D. Griffiths & Michael Auer

Mike Kenward, Gamcare

Darin Oliver, blockdraw





he Gambling Commission looks determined to tackle the risks of underage gambling. In its Review of online gambling published in March 2018, the Commission set out several policy recommendations as part of a push to implement responsible gambling measures in Great Britain and enhance the regulatory framework for online gambling. These concerned age verification, customer identification, unclear and/or unfair terms and conditions, and ineffective customer interaction.

Richard Williams licensing, gambling & regulatory partner Joelson

On age and identify verification, the Commission has since carried these forward with the launch on 5th September 2018 of a twelve-week public consultation on the proposals. It is encouraging a range of stakeholders to respond, including current or prospective gambling licensees, identity verification solution providers and gambling customers, as well as those impacted by gambling more broadly. Once the consultation has closed in late November 2018, any resulting changes to the Licensing Conditions and Codes of Practice (LCCP) will come into force in April 2019. Operators, therefore, have only a short time left to influence the proposed measures. The current state of play For land-based operators, age verification remains relatively straightforward, generally being able to rely on checks of physical identity and proof of identity and address documents. For online operators, however, things are much more complicated. Under the current LCCP requirements, remote licensees must verify the age of a remote customer within 72 hours of the individual opening an account, and winnings cannot be withdrawn until the customer’s age has been verified. If age




verification has not been completed after 72 hours, the account must be frozen and no further gambling is permitted. Where individuals are found to be underage, the licensee is required to return all stakes to the customer, but no winnings. Less strict procedures currently apply in the case of customers registering and gambling using a credit card, where licensees are only required to undertake random age verification checks. These rules date back to 2007 – before the explosion in online gambling in the decade since. Indeed, the Commission notes in its Review that Great Britain has the largest regulated online gambling market in the world, generating approximately £4.7 billion gross gambling yield per year. In part, the Commission’s determination to review age verification simply reflects the growth of online gambling and addresses its concerns that the current rules no longer adequately protect children. The 72-hour window allows the possibility of underage gambling for up to three days before detection, even if underage individuals must ultimately have their stakes returned and winnings rescinded.

The case for change In some ways, the proposals sit at odds with the evidence in the Review itself. The data shows there is little sign of an epidemic of underage online gambling. The Commission’s publication references data from a survey for its Young People and Gambling 2017 study, that showed 3% of 11 to 16 year olds had gambled online – “a relatively small amount”, it conceded. But that is only part of the story. First, despite the low figures reported in the 2017 survey, the consultation draws on industry



data that shows significantly higher – and growing – numbers of individuals gambling remotely who are unable to prove their age when challenged. There were 56,584 incidents in the year to September 2017 (up from 50,256 two years earlier) for remote operators, compared to 13,444 cases for non-remote betting offcourse, on-course and in pools (down from 21,330 cases two years before), and just 16 cases in non-remote casinos (down from 34). It also relies as part of the consultation on the Responsible Gambling Strategy Board’s June 2018 report on young people and gambling, agreeing that there is a “strong precautionary basis” to scrap the 72-hour rule. Second, it is also clear that a shift towards innovative types of online gambling, such as mobile and free to play gambling products has had an impact on the number of young people being attracted to gambling. More than one in ten (11%) of 11-16 year in the 2017 survey said they had participated in ‘skins’ betting and the same proportion had used free to play gambling-style social games. In fact, free to play games (social or otherwise) are a particular area of concern for the Commission. Whilst it notes in its review that these games “are not gambling”, it considers that they are a stepping stone to real-money gambling. As a result, its proposals intend to revise the LCCP to ensure that play-for-free versions of gambling games are only available after age verification has been completed. (This will, however, only apply to Commission licensed operators and therefore will not deal with unlicensed operators who solely provide play for free gambling type games.) Perhaps most significantly, the Commission’s proposals do not


<< For some operators these proposals would, if implemented, involve a signicant change to their procedures. This would interrupt depositing and playing following sign-up unless age verication is instantaneous and streamlined. >> just reflect developments in online gambling and changing risks since the original LCCP provisions on age and identity verification were drafted; they are also a response to advancements in technology and data available for age verification over that time. As the consultation document notes: “Verification software and solution providers have suggested that age verification for most gambling customers can now be completed within a matter of minutes or seconds.”

What to expect With the Commission’s proposals still in consultation there remains an opportunity to influence the final provisions of a revised LCCP. Whatever the outcome, however, it’s inevitable that age verification requirements are likely to be strengthened from April 2019. It is worth highlighting a number of the key proposals: • The Commission proposes scrapping the 72-hour rule. Instead, licensees will be required to complete age verification prior to depositing or gambling • Licensees must also age verify a customer before permitting use of free-to-play gambling games on their websites. • The exemption from age verification for credit card deposits will be removed, so operators will have to conduct the same level of age verification checks for these customers as with any other form of deposit

Finally, it should be noted that the Gambling Commission’s interests are not solely restricted to protecting under 18s; it is keen to set age verification in a wider context of ensuring responsible gambling. The Review, for instance, noted benefits in operators knowing more about their customers at the start of the commercial relationship: “Identification of potentially harmful play is greatly assisted if operators can verify other key personal characteristics at the point of registration, such as whether someone is unemployed.” It is particularly concerned about the findings of an ongoing Competition & Markets Authority (CMA) investigation which established that operators are often using identity checks as a device to delay or prevent withdrawals. The Commission proposals therefore go beyond simply proposing changes to age verification procedures. It will specify that any identity

information required for a customer to promptly withdraw funds must “where practicable” be obtained and verified before the customer is allowed to gamble.

Next steps For some operators these proposals would, if implemented, involve a significant change to their procedures. This would interrupt depositing and playing following sign-up unless age verification is instantaneous and streamlined. However, as the Commission’s Review noted, many firms already use technology to verify age much more quickly than the 72-hour limit requires. The consultation explicitly states that licensees will be able to continue using third-party verification software or credit reference database searches to verify age. It’s really only where those automated checks fail that obtaining manual age and identity documents will lead to delay. In fact, as the Commission continues to vigorously pursue the protection of gambling customers in Great Britain, there are much more significant changes in the pipeline than this. The consultation raises the prospect of mandatory account limits, for instance, which will be the focus of a future consultation. Having to verify age and identity at the outset of a business relationship is one thing, but having mandatory account limits imposed is another, much more concerning proposal for operators to mull over. :: CGi RICHARD WILLIAMS

Richard Williams has 20 years post qualification as a specialist lawyer to the licensing and gambling industry. He is joint head of the gambling, licensing and regulatory team at Joelson, whose office is at Portland Place in central London. Richard advises both remote and land-based gambling operators ranging from start-ups to established operators. He works closely with gambling clients and has a particular interest in cryptocurrency, LCCP compliance and reporting, CAP/BCAP codes, ASA rulings, marketing advice and drafting promotional and general terms and conditions. Richard is a regular speaker at national and international gambling conferences and attends conferences annually in London, Gibraltar, Malta and the Isle of Man.



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he global iGaming market is a mix of preregulated, newly regulated and established markets, but we are seeing a major shift towards more jurisdictions embracing regulatory frameworks. In regions such as Asia, Africa, Latin America, Europe and the USA, lawmakers are moving towards regulation with commitment and determination – and at speed.

Susan O’Leary ceo alderney egambling

Those active in regulated markets are required to be licensed, be it by a global regulator such as the Alderney Gambling Control Commission (AGCC) or a local regulator (and sometimes both) in order to offer games to players. But there are still many markets where operators and suppliers can offer online gambling products without having to comply with any rules or requirements, and without being licensed. Operating without restrictions may seem like the ideal environment in which to run an online gambling business, but in reality, the opposite is true. Unlicensed companies simply don’t meet the same high standards as those licensed by established regulators, they don’t afford their players the same protections and they open themselves up to risks such as money laundering, fraud and even legal challenges. So what is regulation and licensing? Regulation and licensing ensure that consumers engaging with online gambling products are protected from potential harm and can access their favourite games in a safe and secure manner, and at reputable operator sites. As an extension of this, regulators ensure that gambling is being conducted fairly and CGiMAGAZINE.COM



honestly, and that operator and supplier systems are auditable and secure. Regulation is also about keeping criminal activity out of gaming, particularly when it comes to money laundering, fraud, and terrorist financing. As a result of this, we can be certain that operators and suppliers are working to the highest possible standards, that they can be held to account against clear rules and requirements, and that consumers and players are properly protected and can enjoy gambling products in a healthy and happy environment. There are many benefits to operators and suppliers obtaining a licence from a globally renowned regulator such as the AGCC. How regulation and licensing benefits operators and suppliers By obtaining a licence from an established regulator, you can be confident that you are working to best practices and gold standards, regardless of what markets you are active in. Just because the jurisdiction where you offer gambling products doesn’t have specific rules and requirements doesn’t mean you shouldn’t ensure you are meeting internationally-recognised standards. There is a raft of benefits to doing this First and foremost, it is about embracing an ethos and adopting a state of mind that allows you to take a strategic approach to your business that ensures you are playing by the rules and doing the right thing. This, in turn, allows you to set your business apart from, and move clear of, your competitors. It also opens the door to working with other regulated operators and suppliers that are often market/world leaders. These organisations simply won’t partner with unlicensed organisations. Being licensed adds a layer of security and robustness for businesses with both parties adhering to the same internationally recognised standards and requirements. This provides a solid foundation for reciprocal and stable partnerships that can evolve in a safe and secure environment to deliver mutual long-term success. Another benefit of obtaining a licence is that the majority of financial institutions, banks and payment processors will not work with unlicensed companies – the risk simply outweighs the reward. This can be a huge issue for operators as banking and payment processing, in particular offering safe, secure and fast transactions to players, is a vital component of any iGaming businesses and can be the difference between success and failure. Holding a licence from a trusted regulator such as the AGCC is more than enough to mitigate this perceived risk and provides financial institutions with the confidence they need to work with iGaming operators. This has a lot to do with the anti-money laundering (AML) and counter terrorist financing (CTF) protocols operators are required to have in place in order to obtain a licence. The AGCC framework has been endorsed by Moneyval and the Financial Action Task Force (FATF) providing licensees and their financial partners additional peace of mind.



Being licensed allows operators and suppliers to drive exponential growth. Players feel safer registering and depositing with operators licensed by a top tier regulator. This allows you to increase customer acquisition, improve retention, and take loyalty to the next level. In short, licensing allows you to unlock the full potential of your business. This leads on to another key benefit; your exit strategy. The global iGaming sector is full of success stories; it is one of the only industries where start-ups can become multi-millionpound enterprises almost overnight. This has resulted in a regular stream of mergers and acquisitions, as well as IPOs and even ICOs. For the former, investors, lenders and regulators want to know they are dealing with transparent and reputable companies, and meeting regulatory standards goes a long way to achieving this. When it comes to initial public offerings/initial coin offerings, it is simply not possible to list a gambling operation on a recognised stock exchange unless it is licensed by a reputable regulator. Alderney has experience of working with licensees that have been acquired and/or floated on a stock exchange. Why operators and suppliers fear regulation Despite the clear benefits of regulation and licensing, operators and suppliers often fear the process. This is because they assume being licensed will see them become tangled up in redtape and over regulation, preventing them from maximising the business opportunities in front of them. This is understandable, and in some cases iGaming organisations can have their wings clipped by being licensed. That said, the AGCC takes a unique, risk-based approach to regulation that means it only applies the necessary requirements to your business and/or the markets you intend to enter. This allows licensees to remain lean and nimble, and to take full advantage of the opportunities on the table in each market they target. It can only do this due to nearly 20 years of experience regulating the industry’s power players. How Alderney can help Alderney’s approach is to regulate fairly and appropriately to mitigate the risks and protect the players. Most importantly, our approach and method works. Licensees know that if they apply the Alderney framework to their business model, they will be protecting players and running their business in line with internationally recognised best practice. Each licensee has an industry-experienced, designated relationship manager and a bespoke and tailored framework to mitigate the specific risks of their offering. This approach is only possible because Alderney has an established framework in place based on practical industry experience that has demonstrated its capacity to keep pace with the rapid rate at which the industry has, and continues, to change and evolve. Most of the team at the AGCC and all of the licensee-facing managers have worked in the industry so they really do get it.


The framework is so flexible that it covers all aspects of gambling and does not need to be adjusted to cater for new trends or fads. So while other jurisdictions are reworking their frameworks to ensure they are fit for purpose, there has been no need to reinvent Alderney’s all-encompassing model. For example, while others are making knee-jerk reactions to responsible gambling, social gambling and eSports betting to name a few, the AGCC is already able to embrace these new developments within its existing licence framework. As one of the most experienced regulators in the world, the AGCC really understands the full iGaming ecosystem. The AGCC appreciates that the network of operators, suppliers and players work symbiotically and that factors such as responsible gambling and technical and social issues must all work in harmony. If one of these elements runs off course, the knock-on effect is felt through the entire system. It is crucial to consider the complete picture in order to be able to effectively regulate operators and suppliers; this requires hands-on experience. Alderney’s experience also allows it to take a risk-based approach to regulation and licensing, as mentioned above. This means it can ensure the regulations being applied to a business are proportionate and prevent the licensee from being held back by over-regulation. An example of this is the innovative Asia Betting Model that accommodates the “agency” wagering system used across the region. The model ensures that operators and suppliers are working to the highest possible standards, but in a way that allows them to offer the products and services the market needs. We have only been able to deploy such innovative licensing models due to our ongoing presence and collaborations with key decision makers in new, re and pre-regulated markets such as Asia, Africa and the USA. We have spent a lot of time on the ground in these jurisdictions, sharing our experience with lawmakers, regulators and governments. In India, we have been working very closely with the All India Gaming Federation to help put a self-regulatory framework in place for operators and suppliers looking to enter the market prior to the government enacting its own laws. We are doing the same with organisations in Africa, taking a collaborative approach to building robust, future proof regulatory models. Regulation is not just the future, it is the now Licence uptake at the Alderney Gambling Control Commission is higher than ever, and one of the key reasons for this is that operators and suppliers understand that regulation and licensing are the future of the iGaming industry. As more jurisdictions deploy frameworks and require operators and suppliers to play by the rules, the opportunities in pre-regulated markets will continue to dwindle. By obtaining a licence from the AGCC, operators – whether established brands seeking global expansion, start-ups looking to gain the first mover advantage in emerging markets, or midtier organisations increasing the scale and scope of their

business – can ensure they are doing the right thing and are working to best practices, regardless of where they are plying their trade. What’s more, the AGCC is the only regulator that can provide the stability and consistency operators and suppliers need to navigate uncertainty while driving growth in iGaming markets around the world. It really is an exciting time for the whole industry; in Asia, Africa, Latin American and the US, we are seeing jurisdictions approach regulation with renewed vigour and excitement. Lawmakers in these markets are keen to learn from experienced regulators, and the AGCC is thrilled to be playing such a central and collaborative role in shaping their rules and requirements. We have been regulating iGaming operators and suppliers for a long time now, and we have built a formidable reputation for helping our licensees enter key markets around the world in a way that ensures players are properly protected but that also allows the organisation to push boundaries and drive innovation. This is only possible because of the consistent and steady foundation we provide our licensees from which to grow their iGaming businesses, regardless of what verticals they offer and what markets they operate in. Regulation and licensing are not just the future, they are the now and the AGCC is here to guide you through the process and ensure you adapt to, and capitalise on, the changing face of the industry. :: CGi


Susan is a lawyer who has represented some of the world’s leading eGambling operators and gambling service providers including many of Alderney’s licensees and has a keen sense of what they require from a jurisdiction: a strong pragmatic regulator who understands the commercial environment, a resilient technical infrastructure, a favourable tax system, excellent support services and a fees system that allows businesses to grow.





he gaming industry has a short but battle-scarred history of working in regulated, regulating and newly regulated markets. It has allocated extensive man-hours and resources, not to mention spent large sums of money on legal bills, lobbying, taxation, staffing, partnerships, licensing and compliance and marketing.

Mark halstead compliance manager isoftBet

This, it seems, is the price operators and suppliers must pay to play in newly licensed frameworks. But even when these markets are open for business, and mature over time, the climate can often change with regulators imposing new rules and requirements around certification or responsible gaming for instance. In addition, new authoritative powers can be sworn in and immediately lay down their own laws, while the cultural outlook on gambling is also susceptible to change following public and/or media pressure to further tighten regulations. In short, regulated markets are a minefield littered with obstacles and challenges along the way, and an area that must be navigated cautiously, but while still attempting to be among the first to market with the best local customers. The bonus to being compliant, investing in compliance, and working closely with regulators, however is that once gaming companies become accustomed to specific market conditions and absorb the necessary tax and financial consequences, healthy revenues can begin to flow, and you can establish a leading market position that you are confident of securing for the long-term. In summary, if you are prepared to work within the boundaries of the process and are persistent, but remain patient, then the rewards of working in regulated markets can far outweigh the hard work and the costs involved. CGiMAGAZINE.COM



Reasons to enter regulated markets The importance of regulated markets and regulated earnings has shifted significantly in recent years. Investors, customers and new prospects today all look to invest and work with partners that have quality products and a presence across the most stable, mature and profitable regulated territories. As a premium games developer and software provider, we pride ourselves on always being the first, or among the wave of pioneering firms to enter regulated markets. Our customers demand this of iSoftBet and look to us to be able to offer all our cutting-edge table and slot games, as well as more than 1,000 games from more than 30 leading third-party suppliers via our Game Aggregation Platform (GAP) in every regulated market possible. Being able to achieve this has led to significant growth and a very healthy pipeline of new customers. If you are to succeed in regulated markets it is imperative to be totally committed to compliance. We have an experienced team on hand 24/7 to manage all our regulated market activity, ensuring they work closely with local regulators and stay abreast of any changes to market conditions anywhere in the world. As a supplier, we have three gaming licences in the UK, Alderney and Romania, all of which allow us to supply our products to clients in the largest and most important markets. Alongside these direct licences we are certified and have game certifications for all our games and products across 15 regulated markets, adhering to strict gaming standards in each one. We are also in the process of finalising certification in Malta, Sweden, the Czech Republic, Bulgaria and Colombia. The latter four of these markets are either newly regulated or in the process of regulating, while new Maltese requirements mean that we must provide regulators with a letter of recognition to secure a licence. Once accepted, this will open a stream of new opportunities with some significant brands based there, as well as several new licensees moving to the island due to uncertainty in other territories, largely those impacted by potential Brexit implications.

Regulated market essentials To ensure we adhere to local licensing and regulatory rules every one of our 150 table and slot games, as well as our GAP content aggregation platform, must be certified by an independent testing lab. The principal challenge of regulated markets for gaming businesses is that every country has an entirely different framework, taxation regime and requirements – no market in Europe, for example, is harmonised. This has long been an industry pipedream but is highly unlikely to ever materialise. This being the case means companies must adapt and localise their products to each regulated market. Sweden, for example, that opens a new regulatory framework on January 1st 2019, has certain marketing restrictions stating that brands are only allowed to offer a one-time customer welcome bonus. This effectively ends the era of daily specials and collecting loyalty points for cash bonuses and free spins. As a result, many casino suppliers and operators will have to prepare for measures such as this and tailor their games accordingly. If they don’t, they could fall short at the certification stage and, potentially both lose investment and valuable ground that competitors will all too willingly swallow up in their absence. Conversely, measures such as this often generate innovation, and new ways of rewarding and incentivising players



will undoubtedly come as a result. To be able to operate in regulated markets you need to be able to adhere to regulations and to deliver the most appropriate and best quality products that local brands want. We work closely with regulators and with some of the industry’s biggest brands in every major regulated territory, so have therefore built up a great deal of knowledge during that time. Our experience in regulated markets has been positive and it is encouraging to see more countries adopt regulated frameworks. The overall effect is that customers can register, deposit and play games within a safe and secure environment, and only with compliant and responsible providers and brands. The UK and the UK Gambling Commission employs some of the most stringent gaming rules and regulations but is very much


familiar with, this can often lead to problems and you will need the regulations to use certified translation services. Certain terms can often be misconstrued, and this can lead to disastrous consequences if not managed appropriately.

the gold standard when it comes to licensing. It has strict rules in place, including annual audits, but has often altered these over the last few years to meet new legislation including a central register for self-exclusion; RTP live monitoring; GDPR and Competition and Markets Authority rules on making gaming fairer for players. We have an excellent relationship with the UKGC and have always met the standards it imposes, particularly when certifying games. This is something not many suppliers can claim, and several have had to remove games as a result. The key is to invest in and employ the right talent to understand all the regulations in place at the time of applying for a licence or certifying games. We ensure we undergo a thorough and rigorous process when doing this, particularly when looking at documents in a native language. If it is a language you’re not

Looking to new horizons We are constantly exploring which markets are regulating or looking to regulate and have identified four key markets that are or will soon open. We will enter each of these territories by certifying all the relevant and permitted products and games and will be one of the first suppliers to offer local and international brands our cutting-edge tools and game titles. Sweden, regulating on 1st January 2019, will be the first. Many brands have been operating there for many years with the country labelled ‘grey’, i.e. online gaming products have not been permitted but nor have they been banned, and the authorities have not strictly clamped down on any activity. This will change at the beginning of next year with a licensed market. However, even then, of the 55 applications received to date, many are said to lack the required level of information and delays could occur with some operators said to be uncertain as to the interpretation of terms used in the new regulations. Focusing on detail is essential when approaching new markets and you should always go in over prepared. Elsewhere in Europe, we are also actively approaching the already open Czech Republic where we are in the process of certifying more than 30 games, as well as Bulgaria which is at an earlier stage. The Czech Republic has been online since 2017, however the licensing process has been slower than expected, while the supplier market is currently limited. We have already been working with several customers in readiness for when we can go live. Once this market is finalised, we will work to certify our products in Bulgaria whereby each game will need to be modified for the local market. The final market on our current roadmap is Colombia. We are running this process in conjunction with the certification programme for the Czech Republic and certifying a mixture of table and slot games, while also working with a local brand partner that is applying for a licence. With new legislation, new technology and new powers enforcing laws and the legal process, the entry into and management of regulated markets is a relentless but equally rewarding process, and we wouldn’t have it any other way. :: CGi


Mark Halstead is the Compliance Manager at iSoftBet where he ensures regulatory compliance is firmly embedded within the development and delivery of the company’s product portfolio. He plays a leading role in securing licences for iSoftBet in multiple regulated markets including the UK, Alderney, Italy and Romania to name a few. Mark has worked with reputable companies in the iGaming and financial sectors including BGO Entertainment and SLP Engineering, among others. Mark is dedicated to his family... as well as the world of compliance.





he last 12 months have seen some landmark developments in Live Casino, with game content moving into new and exciting areas. Not only that, but regulated Live Casino is really taking off in the USA, that most colourful of gambling markets.

Amy Riches Head of Marketing Evolution Gaming

Anyone involved in the Live Casino sector over the past 10 to 12 years will tell you that the rate of change has been phenomenal. In 2018, therefore, one might have expected development and innovation to tail off a little and for the market to settle down. So is the Live Casino sector plateauing? Based on our experience at Evolution Gaming, with our customer base of top-tier local and global operators, nothing could be further from the truth. In the past 12 months, the boundaries of Live Casino have been well and truly pushed in every sense. And there’s no sign of the momentum slowing, In terms of product development, we seem to be moving into a new era of ultra- entertaining and interactive products. That’s incredibly exciting for players and equally exciting for operators. Traditional casino classics such as Roulette, Blackjack, Baccarat and Poker variants remain very strong, but two key things are happening to content. Firstly, those casino classics are being extended and enhanced with the addition of extra layers of betting opportunity and potential winnings for players: RNG elements added alongside and as an integral part of the live game; massive multipliers; Progressive Jackpots offering additional prizes of in the millions of euros and more. Secondly, Live Casino games are evolving to deliver more entertainment, interaction and thrills to players as the games themselves build in TV game show type characteristics and the CGiMAGAZINE.COM



dealers become game presenters. A perfect example of this is our Lightning Roulette game, which encompasses both of the two trends I have described above. Lightning Roulette is a unique extended online Live Roulette game that has proved to be immensely popular with players across our operator network. In Lightning Roulette, online players enjoy all the usual Roulette bets and more. Alongside the traditional Roulette table bets, every game round also features one to five randomly generated lucky numbers. In each game round lucky payouts of between 50:1 and 500:1 are also randomly generated, and these pay out on Straight Up bets placed on that round’s lucky numbers. All of this added excitement is presented within an electrifying game setting and User Interface that both reflect the game’s Lightning theme. Lightning bolts and sound effects build drama and tension to create a uniquely different and thrilling Live Roulette experience. As Todd Haushalter, our Chief Product Officer, said of Lighting Roulette recently: “It was time for a game like Lightning Roulette to emerge. Everything in 2018 is getting more intense as attention spans shorten, entertainment options are more abundant and even music has more beats per minute.” And when asked what he sees as being the next step for Live Casino, his answer also referenced this new era of game content: “It is going to be highly entertaining games that are almost like TV shows that you can gamble along with at home. We think of Netflix, YouTube, and video games as our competition so we are bringing games that are equally entertaining.” Our Dream Catcher money wheel — which won Digital Product of the Year at last year’s Global Gaming Awards — is another good example of this new era of Live Casino games. Dream Catcher is a new take on the large vertically mounted Money Wheels that are a prominent feature and proven favourite in many land-based casinos. The studio set-up for Dream Catcher follows much the same principle as Lightning Roulette. The setting is not so much a static backdrop that replicates casino interiors and décor, but more like a full-fledged TV studio setting for a game show. Around Dream Catcher’s spinning wheel and the game presenter is a state-of-the-art multi-camera studio installation with light and sound effects auto-synchronised to the game action. This enables players to enjoy a fully immersive gaming experience in which the mounting excitement is relayed to their screens using a series of dynamic camera angles and close-ups. Like Lightning Roulette, the release of our Dream Catcher money wheel was a key milestone that enabled us to expand Live Casino into a completely new area. What’s really interesting is that these new game types are appealing to players who previously wouldn’t necessarily have been attracted by Live Casino table games, such as slots players. Not only that, but this new style of game is also appealing to players who typically wouldn’t be attracted by online casino games full stop. These two games should not be seen as isolated examples. Everything is becoming much more interactive and appealing to



wider player bases. The boundaries are constantly being pushed. In terms of geographic boundaries, much the same is true. New markets continue to open up as a result of re-regulation, and Evolution is constantly focused on turning those market opportunities into significant early market share for its licensees.


more players than ever before. Perhaps the most talked about development of all in recent months is the awakening of the US market for online gaming. This August we expanded into New Jersey with the opening of our new US studio serving US operators. We’ve been monitoring the US market for several years and felt very strongly that 2018 was the right time to launch an Evolution studio there. So far, we've been proved right — a number of top online and land-based operators in New Jersey have already signed with us, and there are more in the pipeline. We believe that in the long run, the US will be a very good market for Live Casino gaming and we are very excited to be part of it. Alongside all of this we have seen another important development: the convergence of online and land-based play made possible by our Dual Play Roulette and Dual Play Baccarat tables. Our own Dual Play tables have been adopted by the cream of land-based casinos including iconic venues such as The Ritz Club and The Hippodrome in London, and many more land-based venues across the UK and Europe, and also in New Jersey. The land-based sector is another important market for us. We expect to see continued healthy growth in Dual Play tables, which are sited on the gaming floors of land-based casinos and enable a virtually unlimited number of online players to play at the same land-based table alongside on-premise players. Markets everywhere, to a certain degree, depend on attracting customers with the thrill of the new and the different. As a possible pointer to the future health of Live Casino, it’s interesting to note that we have never had more new game developments in the pipeline than we do right now. We’ll be unveiling a great deal of this innovative work at ICE in February 2019. At ICE 2017 we launched Dream Catcher. We followed that at ICE 2018 with Lightning Roulette. Both titles offer the chance to win big, both have been runaway successes; and both are very much a part of this new era of entertaining games. So, not only a new era of Live Casino, but a new era that is clearly working for players and operators. The key to success when developing these new games, we believe, is always to focus on the players. We don’t push the boundaries because the technology allows us to; we do it because we want to give players what they want and what we know they will respond positively to. When asked “Product-wise, what are Evolution’s targets for the next five years?”, we don’t overcomplicate things. Our answer is generally, “Simply to offer all different types of players, in every market, games they will love.” :: CGi

Indeed, this year has seen some big expansions in infrastructure for Evolution with the opening of new studios in Atlantic City, New Jersey, USA; in Vancouver, Canada; and in Tbilisi in Georgia. That expansion of our studio estate significantly increases our footprint across the globe and allows us to present our games to


Amy Riches is Head of Marketing at Evolution Gaming, a role that sees her involved across corporate and product marketing for Evolution’s world-leading Live Casino services.





o say that Africa is one of the most compelling scenarios for the iGaming industry in terms of its potential is an understatement. Although still deemed to be in its infancy stages, the continent has everything in order to maintain a strong growth and be at the industry’s forefront.

Sabrina Soldà chief marketing officer BtoBet

And it is relatively easy to understand why. With a population of 126 billion people, Africa is the second most populous continent in the world. It is crucially however a young continent, with 67% of its population under the age of 35, and its working population expected to grow exponentially to reach the 450 million mark over a span of 20 years. Even though each country is constituted by a varying number of factors – be it language, culture, regulations, tax regimes and payment methods – they all have one denominating element that constitutes a common aspect … and that is the innate passion for sports, particularly football. And that coupled with the fact that the entire region has skipped desktop and gone straight to mobile is what makes the region attractive and full of potential.

Conundrums Despite such a promising perspective, the fact remains that due to a varying number of factors, Africa poses quite a number of challenges for those operators who seek to venture in the market. There have been various instances where established international companies did not reap the expected results in Africa. And this mainly lies with their lacking a clear understanding of the local jurisdictions, culture and environment. So first and foremost even before considering the setting up or expansion of a gambling activity in Africa, there are certain CGiMAGAZINE.COM



questions that prospective licensees should pose to themselves: Which countries are already regulated, and which are set to embark on the regulatory path in the coming years? What licenses are available? What products can be offered to players? What are the main differences and aspects that characterize the different regions? These are all questions that should not only be considered but also need answering. It is fairly reasonable to state that by far, one of the most significant obstacles for African iGaming operators concerns the financial aspect. This is mainly due to the high fees related to highend iGaming services which are mainly associated with the more established European market. A scenario that not only forbids the African gambling companies access to advanced technology, but also limits their growth on the long term due to the technological limitations presented to their players. Operators must also keep in mind that the player experience itself varies dramatically from other scenarios, and what constitutes a successful model in the European market varies greatly from the winning model that should be adapted in Africa. Because whilst licensees may well be base their business activities based on the “unlimited” data usage scenario that is practically the dogma on mainland Europe, this is certainly not the case in Africa, where internet is deemed to be relatively expensive and thus it is imperative for the players to be presented with content that is filtered according to their preferences. Another important challenge falls on the substantial gap as regards the payment and money-transfer systems available. It is a wide known fact that a big chunk of the population is still categorized as falling under the “unbanked consumers”. A high portion of the population does not have access to any financial services, thus explaining the high popularity of alternative payment methods. However mobile payments are predominant in the region, with operators charging payments directly to the users’ mobile phone bill. The advent of this form of payment method has allowed companies to circumvent the issue of so many customers not having a bank account. Even though other forms of payments are available – such as credit cards, e-wallets, bank transfers and prepaid cards – not all forms of transfer will be supported in every country. Nonetheless, it must be clear that the first hurdle that ought to be cleared is the technology itself, especially since most of the industry is still predominantly retail and only recently has there been a shift towards expanding the activities towards the desktop and online. There are innumerable instances where software providers continue to provide African operators with the same advanced product used in more technologically adapt scenarios. But is this the right approach? Clearly not. Strictly speaking the technology that is put at their disposal must be adapted to the local needs and system configurations used in the region. Therefore, mobile solutions must be adapted to older devices, and the same must be done with the advanced retail tools which must be adapted to a less complex retail and management system that is utilized in the region. On the other hand, it must be duly noted that many gambling activities are now pushing for technological solutions to help them diversify and differentiate their brand in a way that will help them stand out and acquire a greater market share as well as retaining their current fold of players. This in itself is a clear



indication that the market is maturing and together with the greater penetration and improvements in mobile and payments infrastructure businesses are searching for new solutions to migrate from a pure retail to a mobile business model. Throw into the mix the fact that being predominantly landbased, African operators are continuously facing a skills and expertise shortage when it comes to mobile betting and gaming,


and Africa could well be one of the most difficult conundrums even for the most established gambling organizations.

Doing the right thing Notwithstanding, not everything is all doom and gloom. Far from it… In such an emerging market it’s very difficult to manage all this from an overseas location meaning that to try and run

operations from Europe or elsewhere without people on the ground in Africa is a daring task that could well prove to be calamitous. This is crucial in order to understand the local culture and environment as well as potential problems and opportunities. And whilst being physically present in every corner of the world could well be a daring task even for the largest organizations, most industry experts share the same idea that the most successful way to enter intricate scenarios such as the African market is via a local partner. Whilst it is essential for operators to team up with global and established partners, in such cases it is just not apt from a business perspective to rely solely on a global approach. Thinking of the bigger picture, whilst losing sight of all the characteristics that shape up the local market could well end up to be a messy business on the long term. It is thus imperative to adapt the local stance, keeping in mind that the more information you have, the more successful you can be and the bigger reach you can get. And it is this approach that BtoBet has recently undertaken, initiating a global network of Certified Partners through its White Label Certification Program, with all its Certified Partners being highly proficient in delivering a very high quality of service in their region of competence. A process that not only simplifies the initial process of setting up an online gambling business, especially in the African context, but also provides licensees with a wealth of local knowledge and a means of accessing a simplified yet very technologically advanced solution for the region, ensuring the best possible gaming experience to their players … all fundamental aspects to the eventual success of their business. There can be no doubt as to the potential of the African market, but it’s also equally clear that any prospective moves into the area need to be fully planned and mapped out to be able to succeed. That’s a fact and there’s no denying about that. The rate of success in the region highly depends on the operators themselves having at their disposal the thorough know-how of all the problematics that the region poses and how to circumnavigate them. The promise of small investments reaping substantial revenues may tend to provide a rush from potential investors and businesses to start or expand their activities in the region, however attention must be placed in all the key elements that will determine whether or not an enterprise will fail in due time. The key for success in the region ultimately lies in the operators’ choice of selecting the right technical partners with the right portfolio consisting of experience, the scalability of the products it offers, and ultimately the necessary know-how to solve all the problematics that the region poses. :: CGi


As BtoBet Chief Marketing Officer Sabrina plans and implements BtoBet’s inbound marketing strategy to drive awareness and demand in the global market. She has over 17 years of experience working closely with multinational advertising agencies and has enjoyed a successful career as a Marketing and Communications manager for many companies in the iGaming industry.



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JASWANT DEOL Sportsbook Director Betway






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Anthony Ure head of egaming isle of man department for enterprise

s we enter the last few months of 2018, businesses begin turning their attention to the year ahead and their strategies for the coming 12 months.

For us here at the Isle of Man government, it’s safe to say that our plans are well underway to ensure that we head into 2019 on the front foot, and we are extremely excited to have begun working on our new strategies. Of course, whilst we continue to occupy ourselves with ideas for the future, and what 2019 may hold, it is also an appropriate time to reflect on the year that has just gone by, and look back at some of the feats that we have managed to accomplish. The past several months have been witness to a huge period of change for the Isle of Man’s digital department. Our previous ‘Department for Economic Development’ was transformed into the ‘Department for Enterprise’, with a focus on creating an environment to enable businesses to flourish on the Isle of Man. As a result, our four new executive agencies were established: Digital Isle of Man, Finance Isle of Man, Business Isle of Man and Visit Isle of Man. At Digital Isle of Man, the change has proved incredibly exciting, and we have spent the past few months discussing how we take our eGaming strategy forward in what is an exceptionally competitive and fast-paced business environment. Our board, made up of forward thinking industry experts from across the eGaming and digital sector, has been working closely with the Isle of Man government to identify areas where we can co-operate to grow the sector and improve our existing offering. Part of the new approach from the agency has been to increase the level of involvement from the private sector throughout all stages of the planning process, so that they are CGiMAGAZINE.COM



able to voice their opinions, as well as contribute to any future strategies that we put in place. One of the ways that we have improved this partnership is by encouraging private sector lead workshops to facilitate discussions, something which we have started running already and have so far included Tech Trials, eSports and Blockchain working groups. We believe that businesses have a lot of extremely useful things to say, and these sessions have been immensely useful exercises for gathering valuable feedback. The workshops are also one of the ways that we can continue to demonstrate our unwavering commitment to the businesses that currently choose to operate here, and helps us to sustain engagement from both public and private sector parties. The most recent Isle of Man eGaming report notes that the Island’s ICT and eGaming sector contributes 30% to the Island’s total GDP, and is currently the fastest growing sector on-Island. Last month, the Chief Minister opened the 9th Isle of Man KPMG eGaming summit, which served as a timely reminder of just how far we have come over the past several years. We are already



looking forward to the event next year, when we’ll celebrate our 10th year anniversary. Events like these provide some muchneeded perspective, and truly showcase just how far we have come as an industry on the Island. With that in mind, it has become clear to us that our strategic vision for the sector, and the offering that we currently provide, needs to be refreshed. We have a strong legacy within the industry, but in a world that is rapidly changing, and with technology continually opening up new avenues for growth that previously never existed, those that fail to keep up with the latest trends will inevitably be left behind. We have to stay competitive, and a review of our existing strategies has allowed us to refocus our efforts to where they are really needed. We have already seen how, over the past year alone, blockchain and cryptocurrency revolutions have completely changed the way technology companies think, and that the necessities of what constitutes a ‘competitive’ jurisdiction have evolved considerably. Companies need more resources, they require more talent and they need freedom to prosper, all of


<< EGaming companies, payment service providers and the gambling sector will all play crucial roles in shaping what our future offering looks like. 2019 will see a renewed strategic focus on diversication for the eGaming sector, as we look at broadening out our existing offering. >> which are areas that must be matched with the right level of support from government. EGaming companies, payment service providers and the gambling sector will all play crucial roles in shaping what our future offering looks like. 2019 will see a renewed strategic focus on diversification for the eGaming sector, as we look at broadening out our existing offering. We believe that there is a greater need within the industry for increased integration, so that businesses can collaborate more easily and that the physical environments we create are more conducive to innovation. The Isle of Man has always had a strong sense of local community, and so part of this broadening out process will look at how we can continue to build on what is an already well-established, balanced ecosystem. The Gambling Supervision Commission is also undertaking a review of all its existing gambling regulation, in consultation with industry, to bring it all into one consolidated, flexible and robust act. This should ensure that the businesses that choose to locate themselves here operate under regulation that is both effective and fair. Furthermore, we want greater partnerships with other jurisdictions. The world is becoming increasingly betterconnected, and isolation in the modern environment stands to benefit no one. More partnerships are certainly an area that we will look to develop. Whilst we should be asking ourselves, ‘‘what can the world offer us?’’, we also need to ask, ‘‘what can we offer the world?’’. We also want the talent that we attract here to feel supported. We are very fortunate to have some of the best minds in the eGaming industry based on the Isle of Man, and we want to make sure that they feel like this is the place they need to be in order to reach their full potential. We currently have some of the most exciting projects we have ever had on the Island, as well as several world class brands (including Pokerstars and Microgaming), that add a range of experiences to the sector. Talent has always been at the heart of our strategy, and we will continue to recognise the role that people play in making our Island such a unique place to work and grow. Another area we are currently focusing our attention on is the development of an unrivalled and forward-thinking telecoms

infrastructure strategy which includes the Department for Enterprise’s newly proposed National Telecoms Strategy. If approved, this will put the Isle of Man at the forefront of telecoms innovation and include benefits to the Island such as: access to ultrafast broadband with speeds of up to 1Gbps within the next five years, a fast and reliable telecoms infrastructure to allow businesses the opportunity to roll out 5G in the future, and the appropriate foundations in place to benefit both residents and businesses, as well as grow and develop new and existing sectors on the Island. We are proud to say that one of our sector’s defining attributes is its ability to continuously learn from its previous experiences, moving forward in innovative and trailblazing ways. Jurisdictions, like our own, will be evaluating their own offerings ahead of the new year. Businesses should be encouraged by this. After all, the pace of growth that they are setting demands that we work with them to enable and foster their success. Otherwise, they will look elsewhere to do business. As I have outlined in this article, over the past several months we have been working tirelessly to ensure that our proposition remains one of the best in the world. The eGaming sector remains an extremely high priority for us, and we think that 2019 holds a great deal of promise for the industry. If there’s one thing that we have become certain of, it’s that the challenges our industry faces are always met with unbridled optimism, matched only by an uncanny ability to navigate potential hurdles. The past year has taught us that we should never underestimate our industry’s ability to beat expectations, reach new audiences and soar to new heights. :: CGi


Anthony was appointed Head of e-Gaming at the Isle of Man Department for Enterprise in 2017. He has spent over 30 years working for some of the biggest names in the industry such as Ladbrokes and IGT.



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Marion Gamel

coach CEOs and Entrepreneurs all over the world. Amongst the challenges they face and the changes they have to adapt to, there’s a topic that often surfaces in our conversations: Efficiency.

Whether a company is a new start up of 5 employees, a multinational group listed on the stock market, digital or not, whether a company offer products or services, efficiency is one of the key ingredients to its success. Efficiency, although it is paramount to growth and success, is invisible, elusive to track, and hard to teach. While there’s no silver bullet that maximises efficiency, there’s a tool that everyone has heard about, yet it remains seldomly used by companies: OKRs. In my role, as an executive coach, I encourage leaders to make changes today, no matter how big or small, that will empower the company to reach tomorrow’s target. OKRs are not new, neither are they sexy. Granted, a new company mission statement or strategy would be lot more exciting. However, the secret of efficiency often lies in the HOW much more than the WHAT, and when it comes to HOW we do things, a good tool is often the solution. Having been introduced to OKRs at Google in 2003, I have now been using OKRs for 15 years. WHAT ARE OKRS? You’ll find several definitions of OKRs online, this is one of my favourites: Objectives and Key Results (OKR) is a technique for setting CGiMAGAZINE.COM



and communicating goals and results in organizations. Its main purpose is to connect company, team and personal objectives to make sure people move together in the right direction. OKRs ensure that each individual knows what's expected of them at work. OKRs are kept public, so teams know what others are focusing on. A BIT OF HISTORY OKRs were first introduced at Intel in the 70’s. They’ve since been used by Apple, Accenture, Amazon, Dell, Dropbox, Eventbrite, Linkedin, Oracle, SalesForce, Spotify, Twitter, Uber, Netflix… to name a few companies who’ve relied for decades on OKRs to improve or maintain efficiency. WHY USE OKRS? The list of benefits that both companies and their employees realm from OKRs is long and strong. Company: • Everyone contributes to the big goals • Clarity about what gets done, by whom and when • No big project is dropped • Easy to track progress made on key projects • Communication flows, as a result, collaboration is optimal • Deal with promotions and salary reviews in the most transparent and fair manner Employees: • Everyone works on what truly matters • Ownership of an area, autonomy, accountability • Employees’ roles are clearly defined. • When additional unplanned tasks present themselves, OKRs empower employees to re-prioritise • Easy to self rate own progress and growth. Clarity on what was achieved • Clarity about dependencies: Who is waiting for who’s work • Employees manage their own workflow, ambition. They selfrate their achievements and draw their own growth-path THE ARCHITECTURE OF OKRS In their simplest form, team or individual OKRS comprise a list of a few objectives, that are aligned with the pillars of the company strategy. Under each objective, are listed a handful of key results. These key results are the steps or tasks that must be achieved in order to reach the objective. With clear objectives, anyone in your team can say : “THIS is what I am focusing on this quarter, and what I will deliver to the business.” Key results empower individuals to say: “THIS is how I am going to achieve my objective.” YOU’VE BEEN USING OKRS UNKNOWINGLY I deliver workshops for companies to help them implement OKRs at team and at individual level. I often surprise people who’ve



never used OKRs at work, by telling them that they’ve actually been using OKRs all their life! Let’s take an example that everyone should be able to relate to: You want to buy your first apartment within the next 6 months. Getting on the property ladder is your Objective. There’s a list of things you need to do and put in place to reach this objective: • Find out how much a bank could lend you, at what rate and under which conditions, how much deposit you need to put in • Calculate how much you could save in 6 months for a deposit • Set the maximum price you can afford, in the neighbourhood that you like • Visit about 10 properties • Make an offer The list of things that have to be done in order for you to be in a position to buy a first property is your Key Results. OKRs are a structured way to make a commitment, and a plan to reach that objective. While every company makes a commitment to pay a precise compensation package to their employees, to train them and to treat them well, OKRs empower employees to be specific about the commitment they make in return. SOME OKR EXAMPLES Let’s take a fictional company, who offers casino games online. The company’s goal is to become one of a top 5 players in Italy, Spain and Denmark within the year, and the strategy to get there is three-fold: • Attract 100,000 new customers, via the widest range of casino games and the most generous bonuses • Delight customers with a state of the art interface on desktop and mobile devices, and with the best customer experience and support • Retain over 50% of its existing customers for a year, thanks to an ever-growing mix of blockbuster and unique casino games and a generous loyalty program The marketing team will have its hands full! This is what one of the Objective and Key Results for this team will look like, for a quarter: Objective: Acquire 25,000 new customers, at an average cost per acquisition of €110, with a predicted life expectancy of 1 year, for a budget of €2.75million. Key results: 1. Attract 5,000 new users of high quality via affiliate marketing at a cost per acquisition of €50 (€250,000 quarterly budget) 2. Attract 10,000 new users of high quality through SEO, at a cost per acquisition of €10 (€100,000 quarterly budget)


<< OKRs are not about adding more work, they’re about listing individuals’ commitments and key deliverables and making them public so others know what to expect of you and what is expected of them. >> 3. Attract 10,000 new users of high quality through performance marketing at a cost per acquisition of €50 (€500,000 quarterly budget) 4. Improve brand awareness and affinity in each key market, through TV, sponsorship and Social media (€2,000,000 quarterly budget) 5. Predict customer lifetime value and life expectancy within 15 days of acquisition Now let’s take as an example the head of affiliate marketing, and look at one of her individual OKRs. Objective: Acquire 5,000 users of high quality via affiliate marketing at a cost per acquisition of €50 (€50,000 quarterly budget) Key results: 1. Optimise our existing relationships with top 5 Affiliate partners in each of the 3 markets, secure top placement on homepage and negotiate a cost per acquisition below Euro50 2. Test 5 new affiliate partners in each market within the first 2 months of the quarter, analyse and keep the top two performers per market. 3. Stop working with the 10% poorest performing affiliate partners in each market by the 2nd month of the quarter, re invest in top affiliates before the end of the quarter 4. Hire a new Affiliate Marketing manager for Italy, retain the Affiliate marketing managers in place in other markets 5. Sharpen tracking and reporting tools to offer affiliate partners the best possible experience and fastest payments and reach an affiliate satisfaction level of 8/10 Often when I show examples of OKRs, people react by telling me “But…. this is exactly what I already do!”. OKRs are not about adding more work, they’re about listing individuals’ commitments and key deliverables and making them public so others know what to expect of you and what is expected of them. OKRs make it easy for everyone to be aware of the dependencies and domino effect that is the reality of every

company, and their role in it. OKR TIPS Each company “does” OKRs differently. I for instance ask my team to add the strategy pillar they’re feeding into, next to each of their objectives, to make sure no one’s working on something that’s not 100% aligned with our company big goals. There are some tips that I find useful to fully benefit from OKRs: Objectives: • 3 to 5 maximum. With more than 5, employees are spreading themselves too thin to be impactful • Measurable, there has to be a number or percentage in there • Time bound, meaning a clear delivery date • Challenging (bigger every quarter). No sandbagging allowed! • Shared with stakeholders, manager and teams who are part of the individual’s network of dependencies. No hiding! • Some objectives may look very similar quarter on quarter, and that’s to be expected if the individual’s role remains the same Key results: • Maximum 5 key results per objective, or it turns into a laundry list • Measurable so employees can rate their own progress monthly. Everything these days is measurable, via digital tracking, internal or external surveys... • Something relatively big that will take a generous amount of time and resources. Key results should not be ‘business as usual’: Attending a meeting is not a key result. • Talent management (hiring, retaining, growing…) should be a key result for managers, as it’s and essential and time consuming activity • The sum of someone’s key results should not represent more than 70% of this person’s time. It’s a simple rule to ensure that everyone remains agile during the quarter, as unexpected tasks will come up CGiMAGAZINE.COM



OKRS & TIME 1 - Use OKRs to set the pace: OKRs are a great way for an employee to cut the quarter into chunks and to know what to deliver on a monthly or even on a weekly basis, to plan his workload. Let’s take an example of Simon, a sales manager. His objective is to deliver 5 new clients this quarter, signed and ready to go. • He knows that in order to get five clients, he needs to answers about 10 Requests For Proposal (RFPs) • Being invited to answer ten RFPs requires for him to pitch face to face to twenty potential clients • To get to twenty meetings, he needs to meet about forty potential clients and tell them about the product he’s selling • He can meet forty potential clients by attending three industry conferences • He also needs a great sales pitch All these tasks, or key results, can be spread out on a timeline, helping Simon plan his tasks or key results by week as well as their order of execution, required resources and his focus. 2 - There’s a seasonality to OKRs Most companies have a yearly strategy. They then divide the year into quarters. Most commonly, OKRs are done quarterly. Here’s an explanation of what happens, and when, during the quarter: • 1st week January: Individual Q1 OKRs are drafted and shared with colleagues to ensure there is complete transparency on commitments, delivery dates and dependencies • 2nd week January: Individual Q2 OKRs are approved by managers and made public • Mid February: Half way through the quarter is a good time for employees to self assess how they’re performing versus their OKRs, to discuss any under or over delivery with their manager, and to inform colleagues and dependencies • Last week of March: Employees self-rate their Q1 OKRs and share their analysis with their manager • First week of April: Q2 OKRs are drafted and shared with colleagues. • 2nd week of April: Q2 OKRs are approved by managers… OKR FAQ Leaders are likely to get some level of push back by employees about starting to use individual OKRs. This happens every time a new process is introduced. Some employees may feel uncomfortable about writing down their own commitments about their individual deliverables. This type of hurdle will be overcome within a couple of quarters. One of the best things a leader can do is show the way, be a good sport, and do his own OKRs shared across the company. Here are some frequent questions and concerns I hear about OKRs: OKRs are for large companies, we’re only small! OKRs are used by Eventbrite, a company of a few hundreds



employees. Google only had a few dozens of employees when they started using OKRs in the early 2000’s. I prefer to do my job, rather than spending time listing what to do OKRs take 30 min to draft, once a quarter. Telling colleagues what you commit to delivering is part of your job. I’m a manager, how do I make sure everyone in my team uses OKRs? 1. Do your own OKRs, and teach your team how 2. Empower team members to teach others 3. Early in the quarter - check your team OKRs and give feedback. We already have a performance evaluation process, we don’t need another one OKRs are not a performance evaluation tool. They help each and every employee to: • Self-rate his work. He monitors his deliverables and growth. OKRs are like golf, you’re competing with yourself • Keep track of his contribution to key projects in the last three to twelve months, which is very hard when everyone is so busy but extremely helpful when it’s time to ask for a promotion • Position his work when he speaks to a Senior Executive. Indeed, listing his three objectives and explaining how they feed into the overall company strategy will help a C-level executive understand the employee’s role and responsibilities Efficiency is the keyword in most companies. A key step to improve Efficiency is to increase the level of ownership, accountability and transparency about commitments and deliverables. OKRs are a transformational tool because they empower employees to understand how they fit into the domino effect of the product chain. OKRs bring a sense of responsibility and autonomy, even to the most junior employees. OKRs may not be the newest or sexiest of tools, but they are the backbone of the world’s top companies and used by the most innovative startups. Tools and processes are not the most exciting way to transform a company’s efficiency- a new company mission statement or strategy would feel much more glorious - but sometimes, the devil is in the detail and it turns out that an old tool is still the sharpest. :: CGi MARION GAMEL

Marion Gamel is a C-level executive with over 20 years of experience. Having started her career as an entrepreneur, she then worked for Google and Eventbrite and was Chief Marketing Officer at Betsson Group. Marion has been coaching leaders around the world since 2015 and is a Registered Business Coach.



Dr. Mark D. Griffiths

ver the last couple of years, the gambling industry has identified social responsibility as a major cornerstone of their business (Harris & Griffiths, 2017). The main goal of social responsibility practices in gambling is the application of procedures and tools that help minimize gambling-related harm. Because of its technological infrastructure, researchers have pointed out that many responsible gambling (RG) initiatives may actually be more effective online. Previous research has shown that information technology developments which are helpful in reducing negative consequences associated with gambling are endorsed by regular gamblers (Parke & Griffiths, 2012).

Mark D. Griffiths &  Michael Auer

Limit-setting has become one of the more widespread types of social responsibility tools used by gambling operators who offer their products online and/or via a player card. Via these precommitment tools, operators allow players to pre-set the amount of time and/or money they wish to spend on gambling in a specified time period (typically per day, week, and/or per calendar month). Some scholars and members of the gambling industry view this method as a way of putting informed player choice at the heart of responsible gambling (Griffiths & Wood, 2008). There are a number of different ways that operators can implement limit-setting. More specifically, a player’s spending can be restricted in terms of play limits, deposit limits, bet limits or loss limits (Wood & Griffiths, 2010): • •

Play limit – This is the maximum amount of money (or time) that a gambler can play with (or for) at any given time. Deposit limit – This is the maximum amount of money that a gambler can deposit into their playing account at any given time. CGiMAGAZINE.COM



• •

Bet limit – This is the maximum amount of money that a gambler can bet on a single game (or concurrent games). Loss limit – This is the maximum amount of money that a gambler can lose in any one session or sessions.

Operators and legislators also vary with respect to the obligation of limit-setting. Wood and Griffiths (2010) noted that in some cases, limit-setting is voluntary (i.e., the gambler can make their own choice as to whether take advantage of the limit setting tools on offer) while in others they are mandatory (i.e., the gambler has to set limits if they want to access the games operated by a specific gambling service provider). Some gambling operators offer the flexibility for players to choose different limits for different game-types (e.g., casino, sports-betting, poker). More recently, Walker, Litvin, Sobel and St-Pierre (2015) proposed the use of win limits. These are limits which reduce the amount of money a gambler can win. They tested this feature with a number of players and a simulated slot machine and found that a selfenforced win limit resulted in increased player performance and reduced casino profit. We recently reported the results of a survey of 2,352 customers of the Norwegian operator Norsk Tipping (Auer, Reiestad & Griffiths, 2018). In this study, the attitude towards a newly introduced maximum monthly loss limit of NOK 20,000 (approximately €2100) was investigated. The majority of players found the mandatory spending limit useful and helpful. However, a sizeable minority of high-risk gamblers (approximately onethird) had a less favourable attitude towards global money limits. This may have been because some of the participants in this risk group felt that the limits impeded their typical gambling activity in some way. Even so, the majority (i.e., two-thirds) of high-risk players had positive views in contrast to a decade-old study by Bernhard et al. (2006) who found that gamblers in Canada strongly opposed mandatory limits. Over the past 15 years a number of studies have examined the extent to which online gambling operators include different types of limit-setting on their gambling website. In an evaluation of the social responsibility practices of 30 British online gaming companies, Smeaton and Griffiths (2004) found that there was a wide variety of bet limits among the gaming sites they visited. The study found that minimum bet size among the 30 companies was £1, whereas the maximum bet size (of those companies that set upper limits) was £20,000. Many of the gambling websites they evaluated typically had £250-£1000 maximum bets and £10-£25 minimum bets. However, this study is now very old and carried out when social responsibility was only just emerging as an issue for gambling operators. Kazhaal et al. (2011) examined 74 online poker sites and found that less than half of these sites offered any limit-setting tools. Fifty of world’s most well-known online gambling sites were visited and reviewed by Bonello and Griffiths (2017) regarding social responsibility practices. Out of the 50 sites, 45 of them (90%) offered players the opportunity to voluntarily set monetary spending limits. Deposit and spending limits were the most common types of limit setting. Spending limits by product type was only offered by one operator. Marionneau et al. (2017) reviewed consumer protection among all 18 licensed online operators in France. Betting limits as well as deposit limits were offered by all 18 operators. Calvosa (2017) reviewed ten regulated



online gambling sites in Italy and all ten had a mandatory requirement for players to choose a deposit limit before they could play. However, in some countries, limit-setting is mandatory which explains why some researchers reported rates of 100% among operators. In some jurisdictions, like the one in Austria, mandatory limits were introduced to protect the most vulnerable individuals (Auer & Griffiths, 2013). The only way for the player to continue gambling is to choose other gaming sites which do not protect players with mandatory limits. As appropriate prevention tools, voluntary responsible gaming features require a certain level of self-awareness. Players should be introduced to responsible gaming from the very start of their gambling during registration on a specific site. Wohl, Gainsbury, Stewart and Sztainert (2013) showed that players who watched an animated video prior to gambling more often stayed within their preset limits than players who did not watch the video. To our knowledge, most operators who introduce limits also regularly ask their players to update them. This is also a procedure that is highly recommended because players might only become familiar with their own gambling behaviour over time. Very few studies have examined the behaviour of gamblers following the setting of monetary limits. Among video lottery players in Nova Scotia, a Canadian study by Focal Research (2007) found that RG features (including limit-setting tools) generally reduced the overall levels of player expenditure. However, Wood and Griffiths (2010) pointed out the specific impact of monetary limit-setting was not separated out from the other RG features. Since that study was published, identified VLT play which was a precursor for voluntary limit setting, was discontinued in 2015 in Nova Scotia. In a laboratory study, Stewart and Wohl (2013) investigated the effect of a pop-up reminder concerning the setting of monetary limits. They found that individuals were significantly more likely to stick to their limits while gambling if they received a pop-up reminder which informed them that they reached their pre-set spending limit compared to those that did not. In a similar study, Wohl et al. (2013) examined the efficacy of two different responsible gambling tools (a pop-up message and an educational animated video) in relation to money limit adherence while gambling on a slot machine (n=72). The authors reported that both tools were effective in helping gamblers keep within their predetermined financial spending limits. In a virtual reality casino study of comprising 43 participants, Kim et al. (2014) found that participants who were explicitly asked to consider setting a time limit on their EGM play were significantly more likely to do so and spent less time gambling than those who were not given such instructions. The other studies that have been carried out have used behavioural tracking data provided by online gambling operators. Broda, LaPlante, Nelson, LaBrie, Bosworth and Shaffer (2008) investigated the effects of player deposit limits among 47,000 sports bettors over a two-year period using data provided by bwin Interactive Entertainment. They examined the gambling behaviour of those who tried to exceed their deposit limit compared to all other players that did not. The deposit limit was simply the amount of money that was deposited into the gambler’s online account (excluding any winnings that the gambler had accumulated). At the time data were collected in


<< In some jurisdictions, like the one in Austria, mandatory limits were introduced to protect the most vulnerable individuals. The only way for the player to continue gambling is to choose other gaming sites which do not protect players with mandatory limits. >> 2005, it was mandatory for bwin players to set a deposit limit. Furthermore, players could not set a limit of more than €1000 a day or €5000 a month. There was also the facility for players to set their own deposit limits below that of the mandatory requirement. The results showed that only 0.3% of the gamblers tried to exceed their deposit limit. It was argued by Wood and Griffiths (2010) that the large daily and monthly mandatory limits may have been the main reason for so few gamblers trying to exceed their limits. In fact, Broda et al. (2008) reported that most gamblers in their sample got nowhere near the maximum deposit limit. More specifically, 95% of gamblers never deposited more than €1050 per month (i.e., approximately one-fifth of the monthly maximum €5000). It is also worth noting that the study did not report any findings relating to those who tried to exceed their own personally set expenditure limits. We carried out a study using data from a random sample of 100,000 players who gambled on the win2day gambling website during a three-month period (Auer & Griffiths, 2013). The sample comprised 5,000 registered gamblers who chose to set themselves limits while playing on win2day where deposits were limited to €800 per week. The results of this study demonstrated that overall, voluntary limit-setting had a specific and statistically significant effect on high intensity gamblers. High intensity gamblers significantly decreased their play compared to similar players who did not choose a limit. Therefore, we concluded that voluntary limit-setting had an appropriate effect in the desired target group (i.e., the most gaming intense players). More specifically, the analysis showed that (in general) gaming-intense players specifically changed their behaviour in a positive way after they limited themselves with respect to both time and money spent. In most of the analyses (with the exception of poker players), the setting of voluntary time duration limits was less important than voluntary monetary limits. It should also be noted that our study is the only study ever to analyse voluntary time limits using a real-world data set. More recently, using player card data provided by Norsk Tipping, we carried out a study to determine whether the receiving of personalized feedback about exceeding 80% of a personally set monetary personal limit had an effect on subsequent playing behaviour compared to those gamblers that

did not receive personalized feedback. In effect, our study can be viewed as a real-world analogue of the studies conducted by Stewart and Wohl (2013) and Wohl, et al. (2013) in which the effect of pop-up messages on the adherence of limit-setting was tested. Both of these previous studies were laboratory studies and only the effect of the adherence to the pre-set limit within a gambling session was tested. Our study tested whether players receiving feedback about exceeding 80% of the monthly personal global loss had an effect on their gambling behaviour in the following three months. From a sample of 54,002 players, a total of 7,884 players (14.5%) received at least once piece of feedback that they had exceeded 80% of their personal global monthly loss limit between January and March 2017. Our results showed that those gamblers receiving personalized feedback in relation to limit-setting showed significant reductions in the amount of money gambled. However, we also found that there was no significant effect among the top 10% of players with the highest losses. This study is the latest in a growing number of studies that have evaluated the efficacy of responsible gambling tools in real world settings using real gamblers in real time and real gambling websites (as opposed to efficacy evaluations in laboratory situations where the sample size is often very small and not necessarily representative of real gamblers because of the use of convenience sampling). The findings of our latest study (and other studies outlined above) are of use to many different stakeholder groups including researchers in the gambling studies field (who can attempt to replicate and extend the present study in other jurisdictions and cultures), and the gambling industry (who can employ such responsible gambling features knowing there is an empirical base demonstrating the efficacy of responsible gambling tools), as well as regulators and policymakers who can recommend or enforce that gambling operators utilize responsible gambling tools as a way of minimizing harm and protecting players. References Auer, M. & Griffiths M. D (2013). Voluntary limit setting and player choice in most intense online gamblers: An empirical study of gambling behaviour. Journal of Gambling Studies, 29, 647-660.




Auer, M. & Griffiths, M. D. (2014). An empirical investigation of theoretical loss and gambling intensity. Journal of Gambling Studies, 30, 879-887. Auer, M. & Griffiths, M. D. (2018). The effect of loss-limit reminders on gambling behavior: A real world study of Norwegian gamblers. Journal of Behavioral Addictions, in press. Auer, M., Reiestad, S.H. & Griffiths, M.D. (2018). Global limit setting as a responsible gambling tool: What do players think? International Journal of Mental Health and Addiction. Epub ahead of print. https://doi.org/10.1007/s11469-018-9892-x Bernhard, B.J., Lucas, A.F. & Jang, D. (2006). Responsible gaming device research report. Reno, NV: University of Nevada, Las Vegas International Gaming Institute. Bonello, M., Griffiths, M.D. (2017). Analyzing consumer protection for gamblers across different online gambling operators: A descriptive study. Gaming Law Review and Economics, 21, 278-285. Broda, A., LaPlante, D. A., Nelson, S. E., LaBrie, R. A., Bosworth, L. B. & Shaffer, H. J. (2008). Virtual harm reduction efforts for Internet gambling: effects of deposit limits on actual Internet sports gambling behaviour. Harm Reduction Journal, 5, 27.

Smeaton, M. & Griffiths, M.D. (2004). Internet gambling and social responsibility: An exploratory study, CyberPsychology and Behavior, 7, 4957. Stewart, M. J. & Wohl, M. J. A. (2013). Pop-up messages, dissociation, and craving: How monetary limit reminders facilitate adherence in a session of slot machine gambling. Psychology of Addictive Behaviors, 27, 268-273. Walker, D. M., Litvin, S. W., Sobel, R. S., St-Pierre, R. A. (2015). Setting winlimits: An alternative approach to “responsible gambling”. Journal of Gambling Studies, 31, 965-986. Wohl, M. J., Gainsbury, S., Stewart, M. J., & Sztainert, T. (2013). Facilitating responsible gambling: The relative effectiveness of education-based animation and monetary limit setting pop-up messages among electronic gaming machine players. Journal of Gambling Studies,29, 703-717. Wood, R.T.A. & Griffiths, M.D. (2010). Social responsibility in online gambling: Voluntary limit setting. World Online Gambling Law Report, 9(11), 10-11.

Calvosa, P. (2017). Responsible gambling strategies for internet gambling: An empirical investigation into the Italian gambling market. International Journal of Business Management, 12(7), 17-34. Focal Research 2007). Assessment of the behavioural Impact of the Responsible Gaming Device (RGD) Features: Analysis of Nova Scotia player-card Data. The Windsor Trial. Report prepared for the Nova Scotia Gaming Corporation. Griffiths, M.D. & Wood, R.T.A. (2008). Responsible gaming and best practice: How can academics help? Casino and Gaming International, 4(1), 107-112. Harris, A. & Griffiths, M. D. (2017). A critical review of the harmminimisation tools available for electronic gambling. Journal of Gambling Studies, 33, 187–221. Kazhaal Y., Chatton, A., Bouvard, A., Khiari, H., Achab, A., & Zullino, D. (2011). Internet poker websites and pathological gambling prevention policy. Journal of Gambling Studies, 29, 51-59. Marrionneau, V., Järvinen-Tassopolous, J. (2017). Consumer protection in licensed online gambling markets in France: the role of responsible gambling tools. Addiction Research and Theory, 6, 436-443. Kim, H. S., Wohl, M. J., Stewart, M. K., Sztainert, T., Gainsbury, S. M. (2014). Limit your time, gamble responsibly: Setting a time limit (via pop-up message) on an electronic gaming machine reduces time on device. International Gambling Studies. 14, 266-278. Parke, A. & Griffiths, M.D. (2012). Beyond illusion of control: An interpretative phenomenological analysis of gambling in the context of information technology. Addiction Research and Theory, 20, 250-260.




Dr. Mark Griffiths is Distinguished Professor of Behavioural Addiction at Nottingham Trent University, and Director of the International Gaming Research Unit. He is internationally known for his work into gambling and gaming addictions. He has published over 750 refereed research papers, five books, 150+ book chapters and over 1500 other articles. He has won 19 national/international awards for his work including the US National Council on Problem Gambling Lifetime Research Award (2013). Dr. Michael Auer is a Director at neccton Ltd. He has a Master’s degree in Statistics from the University of Vienna and a PhD from Nottingham Trent University. He has authored more than 20 refereed papers in the area of responsible gaming and personalized feedback, and specializes in analysis of large real-world datasets comprising gamblers’ data. He co-developed the behavioural tracking tool mentor (with Dr. Griffiths). Dr. Auer is also a frequent speaker at conferences and he advises gaming operators, regulators, prevention, and treatment organizations.



myself have worked in the responsible gambling field for more than a decade, including on the National Gambling HelpLine for seven years. Since then I have worked on the ways in which we gather data in this sector and on some specific projects like risk minimisation and outreach with young people and the criminal justice system.

Mike Kenward development director gamcare

Over the last year I have been taking a lead on the industry-facing work that GamCare does. We have worked with operators for many years offering training and accreditation to try to raise awareness of problem gambling and get it on the organisational agenda at various operators. This is no longer the challenge. Operators usually have a good understanding of the issues associated with problem gambling, and have given at least a cursory thought to how it should be managed organisationally. We are now at a stage where we can move towards a new set of priorities for the sector, which go further than being aware of problem gambling and having policies and procedures for handling it, and move the whole sector upwards and forwards towards greater collective action in dealing with gambling related harm. Reducing gambling related harm is in everyone’s best interest. In my opinion, the current priorities for the sector should be: • Having an organisational strategy to minimise harm; • Evaluating what you are doing; • Sharing what is working (and what isn’t working). This is not just about the gambling industry, but is a priority framework for all of us.

Having an organisational strategy to minimise harm ‘Owning’ responsible gambling initiatives, and leading them from the CGiMAGAZINE.COM



top of the organisation towards a shared, articulated goal for everyone in the business is key for all agents in the sector. In organisations where strategy is well led, it forms part of the culture. People expect to talk about it. Conversations occur throughout the business about how to minimise risk around a particular product or environment. People affected by problems are known to the business and handled with care. We recently published our organisational strategy, which includes our core work of support and treatment for problem gamblers, but expands out into more targeted work with vulnerable groups, and education to minimise the development of problems amongst those at increased risk. We know that engagement and collaboration, driving innovation, is essential across the sector. What might this look like? • A board meeting where responsible gambling matters are discussed and addressed. • Key Performance Indicators that reinforce commitment to safer gambling activities. • Personalised messaging to people exhibiting signs of harm; delivered with confidence and assurance that responsible gambling is not a taboo subject for operators to discuss. What doesn’t this look like? • Having a Responsible Gambling lead onto whom to dump anything related to responsible gambling. • Having a policy sitting on a shelf which nobody reads, and which is never updated.

Evaluating the impact of what you are doing This is something everyone is trying to work out how to do and I am not an expert in it by any means, but by my reckoning it shouldn’t be terribly complicated. A simple logic-model (or theory of change) underpinning the activity you are engaging in would make a great starting place for evaluating the impact of what you are doing and whether it is working. Crucial to this is the upfront thinking that’s needed to create the framework for measurement, rather than trying to work out if you’ve succeeded after the event. In GamCare’s national Youth Outreach Programme, we set out our long-term ambition to reduce harm caused to young people by gambling, and worked back from that. We identified the groups that would be most influential in bringing that goal about. We measure young people’s knowledge of gambling issues before and after the workshops we run with them, and we measure confidence and application of knowledge amongst youth facing professionals. Of course, there are several assumptions that this will bring about the change we seek, but it’s a start.

What does this look like? • Identifying the long-term impact you want to achieve, and some ways you might measure it. • Working back from that and thinking about what short-term outcomes need to be achieved to reach your long-term impact. • Identifying activities which directly bring about those shortterm impacts, and understanding where you are making assumptions and accounting for them.



What doesn’t this look like? • A scatter gun approach to reducing harm, without a longterm vision. • Evaluation after the event. • Spending a fortune on a massive report that nobody reads.

Sharing what is working (and what isn’t) We agree with broader sentiments being expressed elsewhere that responsible gambling is not an area where operators should be competing for commercial advantage. It is a much bigger game than that, with a much more valuable prize: reduced harm. To win it, all players need to be transparent about which of their initiatives appears to be having an impact, and which don’t. They need to publish their evaluations and give and receive any criticism in the spirit of a continuous improvement. In the charity field, we need to do the same. Working together with other stakeholders to identify best practice and codify it is key. There are new players coming into the field all the time; it is incumbent on us as a charity that has been involved in this work for 21 years to lead the way and encourage innovation and growth.

Our Response We have been busy building a suite of products that have these goals embedded within them. Our training products come with an evaluation module, where we contact trainees six and twelve months after training to establish how well change has been embedded after their session. With our new ‘Responsible Gambling Labs’, we are inviting stakeholders from across the sector to bring us problems to solve. To do this, we bring academics, treatment practitioners and those who have recovered from a gambling problem together to discuss and recommend solutions. We want to publish the results to share across all fields. The Safer Gambling Standard (our refreshed accreditation product, replacing GamCare Certification and launching soon), brings all aspects of this work together. We have codified standards which operators must evidence their adherence to. The Standard will provide a clear framework for operators to be recognised for and continue to work towards the highest possible standards in responsible gambling. The standard will be reviewed by an independent expert panel including our services users each year, and results of the accreditations will be published online to give customers a truly independent view into where they can gamble most safely. We believe that laying out a roadmap for a more responsible sector will raise minimum standards everywhere and encourage the most innovative operators to continue to push the standards even higher, making the gambling landscape safer for everyone, everywhere. :: CGi MIKE KENWARD

Mike has worked in the gambling field for over 10 years, starting out in industry as a croupier in a busy central London casino. Mike moved on to GamCare, spending several years in frontline roles before joining the business development team. Mike now uses his knowledge of problem gambling to inform the development of GamCare’s industry-facing services, building products that drive a more socially responsible culture, aiming to protect those at risk of gambling-related harm.



darin Oliver founder Blockdraw technologies

he problem with most blockchain developers is they approach the process as developers and not as businessmen who understand the industry. This is going to be their undoing! The bulk of initial coin offerings are run by technology geeks who have no real understanding of how to build or operate a business. Moreover, the traditional infrastructure that a venture or private equity fund would provide is lacking, since it’s so easy to raise the money. This simply isn’t the case with Blockdraw: not only do I have decades of experience running successful businesses, but my time at the AGCC showed me everything I needed to know about how to run a gambling business properly. Our COO, Konstantinos Despotakis, is a former online gambling CEO and also a former Deputy Director of Compliance at the AGCC. I hired Kim Lumbard, Blockdraw’s current CTO, at Surge Trading, so we have known each other for over a decade. Kim, who taught Information Theory at Caltech, was integral in helping us solve the important problems we wanted to crack. We simply do not know of any other blockchain-based online gambling business with the management, regulatory and technical knowledge and experience that we have in place.

Why are we building Blockdraw? As an ex-online gambling regulator I understand that the current regulatory system is not effective at protecting players from various types of fraud committed by operators, such as what happened at Full Tilt Poker. I learned that regulation is at best a band-aid. The entire online gambling industry is based on the idea that the player must trust a third party or the regulator of that third party. Such a system is ripe for disruption and we are determined to crack it wide open. Our team also understood that none of the current blockchain implementations were tackling the problems and their solutions in a way that would work within the existing business frameworks. CGiMAGAZINE.COM



One of our biggest edges over our competition is that we know what we don’t know. When I founded my company, I did so knowing a lot about the underlying technology and with an intimate knowledge of the industry, not to mention tens of thousands of hours as an entrepreneur. A lot is happening in the online gambling space, but nearly every single operator is approaching the process as a developer, trying to build the coolest technology. We came at Blockdraw from a very different angle.

What do all the stakeholders need and how can everyone benefit from the technology? We wanted to merge the best of all available technologies and still have trustlessness, verifiability, IP protection and security as standard. Everything a real business needs to be successful when disrupting an existing industry. Blockchain casinos have the opportunity to transform the online gambling industry. But why isn’t it happening? Because the current models are not going to be acceptable either to mainstream regulators or to serious operators with reputations to protect. What online public gambling company will accept an open-source state channel with all the game logic and IP exposed? And if you want mass acceptance, you need the marketing muscle of a profitable gambling business. No board would accept that, and many regulators would be concerned about the security risks. Even today only a few regulators will accept cloud computing due to the perceived risks! The idea that you are going to release a native app into the wild with no regulation and no protection of underage or vulnerable players is nonsense. Governments (and even society in the context of gambling) will not stand for it — but this doesn’t mean there isn’t a win-win solution. We decided to look at all our competitors along with the available technological options, and look for a better way: 1. Most systems rely on casino operators to be a trusted third party. That means player funds are held hostage and are vulnerable to compromise. 2. Blockchain technologies are still maturing. While they offer great public verifiability, they are too slow, too insecure, and too expensive. 3. Most companies use advanced state channels on blockchains. These are high performance with robust distributed accounting, but suffer from inherent security flaws and have no built-in legal / compliance features. They will struggle to gain acceptance among regulators and mainstream operators. 4. The legal status is also still maturing. This affects not only regulation, but also the legal capacities and recourses of all parties involved.

Once we understood the problems, we sought the solutions: 1. We used a combination of the best technologies to create a process that would work for all parties. 2. We harnessed a sophisticated non-shuffling cryptographicbased mental poker algorithm for truly trustless, peer-to-peer decentralized gameplay. That means everyone has to play by the rules, including us! All funds are owned by players and managed on the public Ethereum chain. 3. We created the L.E.A.P. system to run the most advanced distributed casino platform in the world. It’s faster, more secure, and cheaper to operate. It runs off multiple servers, giving high redundancy and low latency. But that’s not all that our patent-pending technology offers: a) the L.E.A.P. process



is designed from the ground up to be demonstrably fair, verifiable, trustless, and to cater to the needs of the mainstream online gambling industry; b) we are devising innovative “black box” verification systems to satisfy even the most skeptical users and regulators. 4. L.E.A.P. also has inherent legal capabilities built into it. It preserves provenance, can act as a custodian of evidence, and is not only compliant with today’s regulations, but can be adapted to more sophisticated legislation in future.

Blockdraw is going to be controversial A lot of people in the blockchain community will criticize our technology. They will tell us that you have to be open source, that this is the only way to achieve verifiability and trustless operations. They are wrong. Groundbreaking ideas are always controversial. Christopher Columbus battled his crew. We will take our message to the community with the same zeal. Open source has many advantages, but its biggest strengths are in community development. At the same time, 95% of business blockchain ideas are internal development projects that can’t use this open source advantage. The other so-called advantage of transparency is also its greatest weakness, leaving a business open to hacks and security vulnerabilities. So, what remains is verifiability. It turns out that you don’t need to reveal the code at all to provide absolute verifiability. Using automata theory and providing some information on our algorithms’ mechanics, we can provide definitive black-box verification so that not only is it impossible for us to change, view or alter a game, but the moment anything untoward happens everyone will know about it! That’s far more useful to a user than access to code that many won’t even understand. Our systems were designed to satisfy the needs of all parties and bring the benefits of blockchain to online gambling. Any developer knows that when you have a maturing product with multiple people tweaking the code, mistakes or poor coding are not only likely, they are inevitable. In gambling or finance structures this is unacceptable. This makes current state-channel solutions extremely insecure. Instead, we use private blockchains that are linked to the public blockchain by notary stamps. This design means that our smart contracts are more secure but have the same verifiability and trustless operation as open-source state channels, with the added advantage of business-class security. :: CGi


Darin has over 30 years of experience in finance working in senior institutional sales and trading roles with UBS, Bear Stearns, Drexel Burnham Lambert, and Société Générale in Paris, Tokyo, and Chicago. He has founded his own SEC/FINRA regulated Broker Dealer in Boston. In 2009, his firm (led by Fairhaven Capital and later North Bridge Venture Partners) took over the 2000 stock automated marketing business from the failed BMLS. From 2012-2015, he was Deputy Director of Licensing at the Alderney Gambling and Control Commission ("AGCC") where he oversaw licensing and investigations of a significant number of offshore regulated gaming companies.





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Profile for Casino & Gaming International

Casino & Gaming International: Issue 35  

Casino & Gaming International: Issue 35