PRETZELS & CIRCLES
“THE LAW IS SOME TRICKY SHIT!”
THELMA (GEENA DAVIS) IN THELMA & LOUISE
You said it, Thelma. It’s nowhere trickier than in the murky, evolutionary field of prediction markets, which are now encroaching upon licensed, regulated, legal sports betting. For extensive exposition, I direct you to the excellent study in this issue, by Marc Zwillinger and Ben McLean. They provide a superb primer on “event contracts” on how they became a runaway form of sports wagering.
It didn’t happen in a vacuum. Contributing factors include activist judges, a supine regulatory body and unscrupulous prediction-contract firms. Zwillinger and MacLean beautifully untwine the pretzel logic and circular reasoning whereby what was “gaming” eight months ago is suddenly, somehow a “commodity” today.
This is literally true. When Kalshi, the worst offender, wanted to take bets on the 2024 election, it drew a convenient distinction between predicting “events,” which is narrowly OK under U.S. law, and “gaming,” which is not, at least not across state lines. Fast-forward to the 2025 Super Bowl and, suddenly, making wagers on the tilt is magically no longer “gaming” but ‘predicting an event.’ Little did I know that, had I made a garden-variety wager with the nearest legit bookie that I was merely dealing in commodities and “predicting” the outcome of the game.
In such sophistry as this, Kalshi and others hope to smuggle the camel of sports betting through the needle’s eye of legality. In this they’ve been enabled
RIGHT: David McKee, Editor in Chief, Sports Betting Operator
by a handful of state and federal judges, making up the law as they go along. How else does one explain the judicial handwaving of the Federal Wire Act or the Unlawful Internet Gaming Enforcement Act?
Don’t hope for intervention by the Commodities Futures Trading Commission. The CFTC has become a bought-and-paid-for subsidiary of the prediction markets, headed by Kalshi creature Brian Quintenz. The cheerfully clueless Quintenz, in recent U.S. Senate testimony, set the cat well and truly amongst the pigeons. When queried about Native American tribes’ understandable fear that their nascent sports betting ambitions would be preempted by the Kalshis of the world, Quintenz had a blithe answer at the ready: Tribes could just get into the prediction markets themselves.
Grinning, toothy and with Aryan fratboy good looks that seem ready-made for a Fox News appearance, Quintenz is the ethically vacant poster boy for the chaos being unleashed upon the U.S. sports betting ecosystem. By the time, Kalshi starts taking proposition bets on Aaron Judge’s next at-bat, the prediction markets will be awash in semantically justified sports wagers and the CTFC will be hopelessly in over its peroxided head.
In its uninformed blundering, the Trump administration has set off crisis in gaming. It’s a challenge that requires something more than just another pretty face.
CONTENTS
VOLUME 007 - ISSUE 017
CONTACTS
Publisher – Peter White peter@outsourcedigitalmedia.com
Editor in Chief – David McKee dmckee314@gmail.com
Editor EMEA – Damien Connelly damien@outsourcedigitalmedia.com
Las Vegas Correspondent – Ryan Slattery ryanslats@gmail.com
Associate Editor EMEA – Andrew Behan a.behan@librasgroup.com
Designer – Stewart Hyde www.de5ign.co.uk
Tel: 44 (0) 1892 740869 W: www.sportsbettingoperator.com
Editorial Policy: The views and opinions expressed in Sports Betting Operator remain principally the views of contributors and do not necessarily reflect those of the editor or publishers.
The publishers wish to avoid inaccuracies and, whilst every precaution has been taken to ensure that information contained in this publication is accurate, no liability is accepted by the editor or publishers for errors or omissions, however caused.
Unless otherwise stated, articles appearing in this publication remain the copyright of the publishers and may not be reproduced in any form without the publisher’s written consent.
Printed in the UK by Stephens & George Print Group
Sports betting comes to a New Mexico tribal casino chain. By David McKee
Balancing state and federal regulation for event contracts. By Marc Zwillinger & Ben MacLean
Why the soul of sports betting still depends on a human heart.
An
of
regulation and its unintended consequences.
An interview with Jean-François Reymond, education ambassador for IBIA.
2 - 3 JULY 2025
CUBAN RHAPSODY
Sports betting comes to a New Mexico tribal casino chain. By David McKee
If you’re on the road to Albuquerque, New Mexico, as you ease on down southeast toward Cuba (New Mexico, that is), you’d pass the Apache Nugget Travel Center & Casino. You might even break your journey there. If you do, you’ll find 80 slot machines at your beck and call, along with an entire wall’s worth of electronic table games. And soon, very soon, the now-idle sports book will go live.
The book is being incepted in partnership with ISI Race & Sports, a mainstay of tribal and Caribbean casinos. To find out more about Apache Nugget Corp., the Jicarilla Apache Nation and about ISI, we sat down with Apache Nugget CEO Tony J. Amormino. Our conversation has been lightly edited for clarity.
When will your new sports book debut?
When we signed the contract we were slated to debut August 16. However, we have a big fight coming up August 2. So the guys at ISI and I are actually trying to streamline it pretty quickly, to see if we can get August 1. That way we’re up and running.
For those unfamiliar with your casino, where is it, how large is it and what is your gaming inventory like?
Right now we are in Cuba, New Mexico. From the heart of Cuba we’re about 15 minutes to the north and west, along U.S. 550. We’re halfway between Albuquerque and Farmington, so on your way into the Four Corners this is a perfect stopping point. We have slot machines, electronic tables, soon-to-
be sports book, and Class II iGaming would be coming to the facility. We’ve got some of the biggest names, from Aristocrat and Light & Wonder, in our facility. Right now, Huff N’ Even More Puff and some of the big names from Aristocrat are in. We’ve got some of the old classics – Buffalo, Timberwolf – and some video poker as well.
What are your major feeder markets?
Looking at our player development and our tracking system, we have players coming from Phoenix, Salt Lake City, Denver and El Paso. That’s kind of our immediate circle, where we’re drawing regular customers from, but we’ve had players from as far away as Seattle and Miami. So we’ve stretched the entire continent and a lot of people, even when I was at SBC, know about us and come to our facility.
How many other casinos in New Mexico does Apache Nugget operate, other than the one near Cuba?
The company had three. Covid shut it
down, so this is our first property. We just finished our feasibility study for a resort property that we’re hoping to have a shovel in the ground by the end of summer, at least opening in fall 2026. That is the internal goal for us. It will be in Chama, New Mexico, about a halfhour from Pagosa Springs and Durango. There’s a lot of big-game hunting and fishing up in that area, and we have a lot of major things that we are already starting to put into our pipeline for major events, once that officially comes on board.
How widespread is sports betting in New Mexico?
Sports betting is extremely big. A lot of people have asked for it. I’ve been in the state now for almost 10 months. The first thing that I did when I said I was opening multiple casinos, they go, ‘Well, what about a sports book?’ People are itching for it. Obviously right now it’s tied to reservations but there is a major appetite for it across the entire state, should that ever open up off reservation land.
Are you losing customers by not having offered it so far?
We were losing some, probably about 10 to 15 percent of our players. They’d come in and look to see the sports book. We had the sports book built. We just didn’t have the machines for it. So people were frustrated. I had talked with some of our regulars and they were saying that it was a big draw for them to get that sports book on site.
Was a compact amendment necessary in order to offer sports wagering?
No, our compact was ready for that. Now, there are pieces of our compact that will we will have to go back and tweak, should we choose, if we wanted to do Class III iGaming. But now our compact was already up to date with that and a few other pieces that we are looking to add here in the next 18 months.
What will be on offer at the sports book?
You’re going to hit all your major sports: NFL, NBA, baseball, hockey, European soccer leagues. It’s going to be a wide array. When we created what we wanted to do with the sports book, I included everything down to NCAA baseball and softball. I don’t think we’ll have those right away. I wanted to make sure if you wanted to place a bet, a big professional or collegiate event, you would have that ability. Now with us here in New Mexico, we can’t bet on the Lobos or the Aggies. But you can bet on anything else in the area.
Will there be live walk-up windows or is it kiosk-based?
That’s exactly what we already have in place. Our TVs, when we designed this property, were already designed with the sports book in mind. We could have as many as eight different games on TV for you to watch and everything
ABOVE:
Apache Nugget
CEO Tony J. Amormino
is programmable for us to make sure everyone can watch their favorite game. That being said, we will have live stations, terminal stations, a little bit for everyone. Some of the older clientele, we’ve got the window. The younger clientele who want to get in and place the bet, and watch the game, we’ll have that for them as well.
What can you tell us about ISI Race & Sports?
We’re excited. We did a very comprehensive evaluation of nine different sports book partners. ISI’s flexibility, their deep market experience – especially in the tribal market – was big for us. Their commitment to tribal sovereignty was a huge tipping point for us, deciding on who we wanted to go with.
How many other sports books does ISI operate?
ISI does quite a few in the Caribbean and a good number overall. I don’t want to say because I’m going to undershoot it but I want to say they have 75 different sports-book partners.
Will the sports book near Cuba be retail-only?
To start, it will. But our full intention is to have that sports book mobilized by summer 2026. We will have our mobile, Class II iGaming mobile by the end of Q3 of ’25, so that will kind of work out the kinks for us as we get the sports book up and running.
For our readers, could you explain how Class II iGaming works, as opposed to Class III?
Class II is … anyone who’s seen a bingo
card on one of the corners of your slot machine, it all looks the same. Payouts are converted a little differently because of your pay lines. But it’s the same games as we offer to all of our guests and, as we transition into a Class III mobile-online integration, it’s going to bring the same pieces that you see on any gaming floor right to the palm of your hand.
How significant of a revenue stream do you expect from the sports book?
I expect a much broader vision. As we open, it’s a much smaller one, before our resort, I am looking at such a major integration with this. It’s going to get all of our customers acclimated to the offering that we have. Then, when we tie in the Class II iGaming and the mobilized sports book, that’s where we’re going to make money hand over fist in the long run. I do see a significant boost, especially when you parlay it with some of the other amenities that we are starting to add into the facility, tying it into the sports book, and partner it with some major professional and collegiate events in the area. I think the sports book’s going to be a big hit and could become number one or number two in the state of New Mexico by the turn of the decade.
What tax rate do you pay in New Mexico?
Right now, for the sports book, we are getting taxed the same as every other corporation inside the state [5.9 percent]. I would always like to see the number come down. I don’t like to speak too much to specifics on the number that I would ideally like to see. As a tribe we’ve talked about where we want to be. We’ve got 11 years before our compact is up. I know the tax rate might be a thing of contention when we get ready to talk about adding some other pieces to our puzzle.
How difficult is it for smaller operators like ISI to penetrate the stateside marketplace?
You’ve got the three-headed monster [DraftKings, FanDuel and BetMGM]. The big thing with ISI is their ability to work with a lot of smaller entities and tribes gives them the ability to broaden their reach. People know their product. You go into Oklahoma, down to Kansas, Washington or Oregon and they’ve got the ISI product. People who go on a cruise, they’re going to see ISI in there. That ability – for them to spread rapidly across the country, as opposed to hitting the major population areas – only helps drive their potential as they continue to grow.
How many new jobs will the addition of sports betting support?
As we get our sports book fully acclimated, we’re looking to add a team of 12. Then, when we add our Chama property, it’s probably going to triple from there, close to
50 people when things are said and done.
What are your aspirations for the future of Apache Nugget?
Hosting collegiate basketball events, soccer, professional golf. These are all things that we’re looking to bring into the area. I’ve even started to talking with a few people about potentially bringing in a professional exhibition match to our facilities up in Chama. But those are very preliminary discussions. From a gaming perspective, we’re always trying to be an innovator. That’s the big thing with the Jicarilla Apache: They were always innovative in things they were doing, even before gaming came into play for them. I want to make sure we are following that same protocol as we look to be innovators with virtual gaming, virtual reality, iGaming. I want to be somebody who’s not reactive. I want to be proactive with our approach.
A LEVEL PLAYING FIELD
Balancing federal and state regulation for event contracts.
By Marc Zwillinger & Ben MacLean
Event contracts are understood as a type of commodity. Although commodities are traditionally known as tools to hedge economic risk over agricultural futures like soybeans or cotton, financial innovation (and litigation resulting from such innovation) has helped spread these tools to new areas, including sports. As of today, designated contract markets (DCMs) can provide sportsevent contracts to consumers in all 50 states.
This position is both unsettled and controversial with states attempting to push back on this development both demanding that operators cease
and desist operations in their states, and pleading with the Commodity Futures Trading Commission (CFTC) to disallow event contracts that too closely resemble sports betting. These efforts are based in no small part on the reasoning that DCMs do not operate within the same regulatory regime followed by sports book operators to protect the integrity of sporting events, guarantee payments to bettors and seek to mitigate effects on those susceptible to the addictiveness of gambling or gambling-like conduct. But courts, for now, seem to be siding with DCMs … at least until the CFTC, if ever, makes clear whether it views sports-event contracts as permissible on its markets.
In April 2025, federal courts in Nevada and New Jersey granted a DCM named Kalshi a preliminary injunction against those states’ respective gaming regulators, enjoining them from enforcing state gaming laws against Kalshi’s CFTC-regulated event contracts. The courts found that the Commodity Exchange Act (CEA) preempts state attempts to regulate contracts traded on a CFTC-designated exchange. They also ruled that Kalshi had shown a likelihood of success on the merits, irreparable harm, and that the balance of hardships and public interest favored injunctive relief. As the courts noted, “Because the CFTC has approved (or at least not yet disapproved) Kalshi’s sports-related contracts, the defendants cannot pursue civil or criminal liability against Kalshi for offering those contracts.”
Nationally, the current administration has generally embraced deregulation policies. But sports-event contracts are a complicated topic that demand a more nuanced approach. Despite the purported hedging, economic, and informational value of these contracts, open questions remain on both legal and policy fronts. For example, does purchasing a sportsevent contract implicate prohibitions on gambling under federal or state law? Does the federal agency responsible for commodities have exclusive jurisdiction over sportsevent contracts? Are there consumer protection principles that should be at play here?
The CFTC recently canceled its planned roundtable to explore these issues and the future remains uncertain. Below, we discuss the legal and policy considerations surrounding sports-event contracts.
FEATURE: PREDICTION MARKETS
What Are Event Contracts?
Event contracts are a type of derivative contract whose payoff is based on a specified event, value or occurrence (known as an “underlying”) that is “(1) beyond the control of the parties to the relevant contract ... and (2) associated with a financial, commercial, or economic consequence.”2 Event contracts function as binary yes/no options with fixed payouts and are traded on DCMs subject to oversight by the CFTC, an independent federal agency responsible for protecting the U.S. derivatives market.
The subject of an event contract can vary widely. For example, a DCM can list contracts such as, “Will the price of eggs go up this month?” or “Who will win the men’s NCAA March Madness tournament?” The price of each contract generally demonstrates the market’s determination of whether an event will occur, and contracts generally settle at $1 each. So if the price of a “yes” contract was $0.60, that would show (a) that the likelihood of the answer being “yes” is around 60%, and (b) that you would be paid $0.40 on top of your $0.60 investment if you are right (minus whatever fee the DCM charges, of course).
What Laws Impact SportsEvent Contracts?
This is a question that is constantly evolving. Most DCMs take the position that the CEA provides the CFTC with exclusive jurisdiction over event contracts, regardless of their underlying. However, this is disputed by a number of tribes, state regulators and other interested parties. Below, we discuss various legal authorities in addition to the CEA that may impact sports event contracts.
i. The Commodity Exchange Act
The CEA, as amended by the Dodd-
Frank Wall Street Reform & Consumer Protection Act of 2010, provides a “comprehensive regulatory structure” for commodity and futures trading.3
Under the CEA, DCMs can self-certify that an event contract meets all applicable CEA and CFTC rules and promptly list the contract for trading.
A section of the CEA known as the “Special Rule” gives the CFTC discretion to review and prohibit event contracts that it determines are “contrary to the public interest.”4
Contracts are contrary to the public interest if they involve “activity that is unlawful under any Federal or State law,” “terrorism,” “assassination,” “war,” “gaming” or “other similar activity determined ... by rule or regulation to be contrary to the public interest.”5
After a DCM self-certifies a contract, the CFTC can initiate a 90-day window to determine whether it is contrary to the public interest. “Gaming” under the Special Rule was previously interpreted to encompass a broad range of activities, giving the CFTC considerable authority to prevent contracts that appeared to be contrary to public interest.
For instance, in 2012, the CFTC ordered the North American Derivatives Exchange, a DCM, to stop allowing users to purchase political
LEFT: Ben MacLean is a fellow at ZwillGen PLLC
event contracts based on whether there would be a Democratic/ Republican majority in the U.S. House of Representatives or Senate. Looking to the Special Rule, the CFTC ruled that because “several state statutes, on their face, link the terms gaming or gambling ... to betting on elections, and state gambling definitions of ‘wager’ and ‘bet’ are analogous to the act of taking a position in the Political Event Contracts,” the contracts involve “gaming” under the Special Rule and are contrary to public interest.
In 2021, the CFTC similarly proposed an order for DCM ErisX to stop listing event contracts involving the money line, point spread and total points on NFL football games. The order, which was not published due to ErisX’s voluntary withdrawal of the contracts, would have found that the contracts involved gaming and were contrary to the public interest. However, then-commissioner Brian Quintenz issued a lengthy statement explaining that he would have dissented, due to concerns about the Special Rule’s constitutionality.7 Quintenz wrote that there are significant differences between betting and derivatives speculation: Whereas there is no economic utility in games of chance, derivatives market speculators participate in “nonchance driven outcomes that have price-forming impacts upon which legitimate businesses can hedge their activities and cash flows.” Quintenz also opined that the Special Rule is unconstitutional due to the grant of discretion to the CFTC to effectively ban any contract through arbitrary public-interest determinations.
Following Quintenz’s tenure as commissioner at the CFTC, he served as an advisory council member at Crypto.com, a board member at Kalshi and the head of policy at venture
capital firm Andreessen Horowitz. In 2024, the CFTC sought to enforce the Special Rule against Kalshi. The latter offered event contracts based on the outcome of U.S. congressional elections, which the CFTC alleged was “gaming” or unlawful under states’ laws and therefore contrary to the public interest. Kalshi sued the CFTC, challenging its decision on the grounds that it was arbitrary, capricious and not in accordance with the Administrative Procedure Act.8 In that suit, Kalshi acknowledged that “gaming” involved sporting events but not elections.
The U.S. District Court for the District of Columbia ruled in Kalshi’s favor and agreed that elections were not subject to the Special Rule as they were not illegal activities or gaming. The district court held that “gaming requires a game,” such as sports or games for stakes, like poker. A contract “involves” an activity contrary to public interest if the underlying relates to that activity – to consider all event contracts “gaming” when based on an undetermined event would inundate the Special Rule’s structure because all event contracts would be affected.
The CFTC initially appealed this decision to the U.S. Court of Appeals for the District of Columbia Circuit, but later moved to voluntarily dismiss it following Donald Trump Jr.’s appointment as a “strategic advisor” to Kalshi and Quintenz’s nomination to lead the CFTC as its chairman. Kalshi, for its part, now takes the position that while sporting events may be within the definition of “gaming” for purposes of the Special Rule, the CFTC’s failure to initiate a review means that the contracts are valid under the CEA.9
ii. The Interstate Wire Act
The Interstate Wire Act of 1961 (Wire Act)10 is the principal applicable federal law restricting sports
betting. The Wire Act prohibits those in the “business of betting and wagering” from knowingly using a “wire communication facility” for transmitting interstate or foreign bets or wagers or information assisting the placing of bets or wagers on sporting events or contests. While other federal laws, such as the Unlawful Internet Gambling Enforcement Act of 2006,11 contain an explicit exception for activities regulated by the CEA, the Wire Act has no such exception.
iii. The Wire Act does not directly define what “bet” or “wager” entails, but courts interpreting the statute have enforced it in scenarios that could potentially apply to sports-event contracts.12 It is uncertain where a court might draw the line if it were asked to make this determination, however, and state laws make this area even murkier. On one hand, DCMs are providing users the means to stake money on the outcome of a sports event. On the other, there is real utility in hedging risk on events with legitimate economic impact, and courts could view all contracts traded on a CFTC-regulated exchange as categorically non-gambling.
ABOVE: Marc Zwillinger, founder and managing member of ZwillGen PLLC
“WE NEED TO CALL AN OFFICIALS’ TIMEOUT, GO TO THE REPLAY BOOTH, RESET THE CLOCK AND ENSURE THAT THE GAME IS BEING PLAYED ACCORDING TO THE RULES OF THE CONSTITUTION. THAT WOULD
TRULY
BE ‘IN THE PUBLIC INTEREST.’”
FORMER CFTC COMMISSIONER BRIAN QUINTENZ, MARCH 25, 2021
State Laws
Sports betting – and broadly, gambling – is a topic primarily left to the states as part of their police power to regulate for the public welfare. Since the Supreme Court struck down the Professional & Amateur Sports Protection Act (PASPA) in 2018 on 10th Amendment grounds, sports betting is now legal in 38 states. Each state that has legalized sports betting has strict requirements for operators to comply with applicable consumer-protection and licensing requirements. Failure to comply can result not only in civil penalties but even in jail time. Under state law, wagering or gambling is commonly defined as risking a sum of money on chance or a future contingent event. When the CFTC recently announced its intent to hold a roundtable on prediction markets and sports-event contracts, numerous industry associations, tribes, and interested parties wrote to express their concern about the impact on states’ roles as regulators. For example, the American Gaming Association explained that to allow sports event contracts to operate in all 50 states would “circumvent[] the important regulatory protections implemented by states, ... [and] raise the prospect of considerable consumer and marketplace harms.”13 Among the common protections that these commentators cited are age verification, anti-money laundering,
integrity monitoring and self-exclusion measures, among others. States also stand to benefit from protecting tax revenues from regulated sports betting. In 2023 alone, states collected nearly $2 billion in sports betting tax revenues.14
States are beginning to take the potential encroachment on their ability to control the sports betting market and the resulting potential loss in tax revenue seriously. At the time of this writing, seven states have publicly announced regulatory investigations, with more rumored to be on the way. From states’ perspectives, sports event contracts run afoul of state licensing requirements and related sports betting regulations. Nevada and New Jersey were the first two states to send cease and desists to Kalshi, which subsequently sued in late March seeking injunctive relief. On April 9, the Nevada District Court granted Kalshi’s motions for a temporary restraining order and preliminary injunction, ruling that the company is exclusively subject to federal CFTC regulation as a CFTCdesignated DCM. On April 28, the New Jersey District Court ruled the same way, pulling heavily from the Nevada District Court’s reasoning. It’s possible that future decisions on the matter will reach the same conclusion, but the defeats in Nevada and New Jersey have led to states attempting to assert that Congress’s passage of federal gaming laws (the Wire Act, the Indian
Gaming Regulatory Act and PASPA) show that the CEA was not intended to preempt state gaming laws.
What Lies Ahead for Sports-Event Contracts?
It is critical that the correct balance of regulation is struck that protects consumers while allowing businesses to mitigate risk. It is a distinct possibility that event contracts are completely outside the scope of state regulation, but there are some potential downsides to this outcome. The CFTC may have exclusive jurisdiction over commodities, regardless of their underlying. But if the CFTC doesn’t make a distinction between contracts with significant economic impact (e.g., winner of Super Bowl, World Series, etc.) and those without (e.g. winner of individual games, individual player performance), it runs the risk of turning event contracts into a substitute for sports betting but without the protections that states have endeavored to create. It is easy to see how high-stakes sporting events like the Super Bowl could have an economic impact on a city.15 However, it is more challenging to see a significant economic impact from run-of-the-mill individual games or player performances. These lowerstakes offerings, combined with a lack
of regulation, could undermine the effort to keep sports events contracts under the CFTC’s jurisdiction.
States commonly legislate requirements that involve protections for problem gamblers, gameintegrity assurances, marketing and advertising restrictions, and more. The CFTC has not addressed these requirements in the past, yet these are important concerns that must be accounted for. A number of state regulators, including those from Illinois, Tennessee, Maryland, Michigan and Pennsylvania submitted letters to the CFTC objecting to the operation of sports event contracts within their jurisdictions. In particular, the Tennessee letter argued that contracts offered by CFTC-regulated platforms are indistinguishable from unlicensed sports betting. The letter also details how such offerings sidestep age verification, AML rules and responsible-gambling protections – stating bluntly that these contracts are “being offered in violation of Tennessee law and regulations” and that CFTC-regulated entities are “not compliant with these protections (or many others) mandated by the Tennessee Legislature.”16
DCMs often emphasize that consumers are merely “predicting” rather than “betting” on sports events, yet studies have increasingly observed
a link between problem gambling and online trading products.17 Should the CFTC fail to act here, it is easy to foresee the consumer and market harms that may occur. The National Council on Problem Gambling perhaps said it best in its letter to the CFTC:
State and tribal regulators are experienced in regulating sports gambling. They are constantly updating their regulations and guidance to include best practices and work to balance the benefits of gambling revenue with the costs of gambling-related harm. Given this, the CFTC should either acknowledge state and tribal prerogatives or create a regulatory framework that also prioritizes players’ health. If the CFTC determines that it does not have the authority to require truly robust responsible-gambling measures and problem-gambling safeguards on par with state and tribal regulators, it should not allow these markets.18
By striking a balance between consumer protection and innovation through clear guidelines that prioritize consumer protection, the CFTC can ensure sustainable growth in this market for years to come.
Conclusion
The CFTC must establish clear rules on what is acceptable for sports-event contracts and develop a regulatory framework that addresses both business-hedging interests and the consumer-protection measures that states have created. Collaboration with state regulators can ensure that the market remains fair, transparent and safe for all without stifling innovation..
Marc Zwillinger is the founder and managing member of ZwillGen PLLC, where he counsels clients on issues related to the laws governing Internet practices, data privacy, information
1 Order Granting Kalshi’s Motion for Preliminary Injunction, KalshiEX LLC v. Hendrick et al., No. 2:25-cv-00575-APG-BNW at *6 (D. Nev. Apr. 9, 2025); See Opinion Granting Kalshi’s Motion for Preliminary Injunction, KalshiEx LLC v.Flaherty et al., No. 25-cv-02152-ESK-MJS at *10 (D.N.J. Apr. 28, 2025).
2 7 U.S.C. § 1a(19)(iv).
3 Merrill Lynch, Pierce, Fenner & Smith v. Curran, 456 U.S. 353, 356 (1982); See 7 U.S.C. § 2(a)(1)(A).
4 7 U.S.C. § 7a-2(c)(5)(C)(i).
5 Id.
6 In the Matter of the Self-Certification by North American Derivatives Exchange, Inc., of Political Event Derivatives Contracts and Related Rule Amendments under Part 40 of the Regulations of the Commodity Futures Trading Commission (Apr. 2, 2012).
7 Any Given Sunday in the Futures Market, Statement of Commissioner Brian D. Quintenz on ErisX RSBIX NFL Contracts and Certain Event Contracts (Mar. 25, 2021), https://www.cftc.gov/PressRoom/SpeechesTestimony/ quintenzstatement032521.
8 KalshiEX LLC v. Commodity Futures Trading Comm’n, No. CV 23-3257 (JMC), 2024 WL 4164694 (D.D.C. Sept. 12, 2024).
9 See Plaintiff’s Motion and Memorandum of Points and Authorities in Support of an Immediate Temporary Restraining Order and Preliminary Injunction, KalshiEx LLC v. Hendrick, et al., Docket No. 2:25-cv-00575 *10(D. Nev. Mar. 28, 2025); See Plaintiff’s Motion and Memorandum of Authorities in Support of a Temporary Restraining Order and Preliminary Injunction, KalshiEx LLC v. Flaherty, et al., Docket No. 25-cv-2152 *20 (D.N,J. Mar. 29, 2025).
10 18 U.S.C. §§ 1081–1084.
11 31 U.S.C. §§ 5361–5367.
12 See e.g., U.S. v. Cohen, 260 F.3d 68 (2d Cir. 2001); U.S. v. Kelley, 395 F.2d 717 (2d Cir. 1968).
13 Letter Re: Prediction Markets Roundtable, American Gaming Association (Feb. 20, 2025), https://www.cftc.gov/media/11791/ AmericanGamingAssociation022025/download.
14 Adam Hoffer, Bets on Legal Sports Markets Pay Off Big for States, Sportsbooks, and Consumers, Tax Foundation (Dec. 10, 2024), https:// taxfoundation.org/research/all/state/sports-betting-tax-revenue/.
15 How the Super Bowl Creates Economic Impact Across the Country, U.S. Chamber of Commerce (Feb. 6, 2025), https://www.uschamber.com/economy/ how-the-super-bowl-creates-economic-impact-across-the-country (“The final estimated local economic impact of last year’s Super Bowl in Las Vegas was $1 billion – fueled by direct spending by visitors and residents, indirect spending at local businesses, employment, and tax revenue.”).
16 Letter from Mary Beth Thomas, Executive Director, Tennessee Sports Wagering Council, to CFTC Acting Chair Caroline Pham (Apr. 14, 2025).
17 M. Mosenhauer, P.W.S. Newall, L. Walasek, The stock market as a casino: Associations between stock market trading frequency and problem gambling, J Behav Addict 10(3) (2021) http://dx.doi.org/10.1556/2006.2021.00058; A. Oksanen, E. Mantere, I. Vuorinen, I. Savolainen, Gambling and online trading: emerging risks of real-time stock and cryptocurrency trading platforms, Public Health 205 (2022) https://doi.org/10.1016/j.puhe.2022.01.027; U. Lee, L.E. Lewis, D.J. Mills, Association between gambling and financial trading: A systemic review F1000Research (2023) https://doi.org/10.12688/f1000research.129754.1.
18 Letter Re: Prediction Markets Roundtable, National Council on Problem Gambling (Mar. 10, 2025), https://www.cftc.gov/media/11956/ NationalCouncilonProblemGambling031025/download.
security, third-party data demands, content moderation, collection and use of alternative data, deployment of AI, and fantasy-sports and Internet gambling. He can be reached at marc@zwillgen.com.
Ben MacLean is a fellow at ZwillGen PLLC. He can be reached at ben.maclean@zwillgen.com.
THE WORLD AT YOUR FINGERTIPS
Why 1xPartners is a leader in the mobile gambling segment
Digital technologies are rapidly developing.
The availability of a convenient, mobile app from a bookmaker is becoming an important factor in attracting players. Users seek freedom and maximum comfort when accessing their favorite platform. Modern technological solutions from 1xBet fully meet these needs.
The popularity of mobile gambling gives partners an excellent opportunity to expand their reach and geography by attracting new clients through mobile advertising networks, instant messengers, and social media. Experts predict that, in the near future, up to 70 percent of all revenues in the gambling
industry will come from the mobile segment. Partners should pay special attention to it.
1xPartners App: Mobile Business in Your Pocket
When developing the 1xPartners app, a team of experienced specialists considered all partners’ preferences, providing them with a fast and convenient tool for stable earnings. The app allows you to easily manage your business from anywhere worldwide and receive up-todate information online, including the number of attracted users, their activity, and earned income. It enables you to monitor the effectiveness of advertising campaigns and adjust your strategy with just a few clicks, maximizing profit.
In turn, the 1xBet app offers the best user experience for players due to its intuitive interface and high reliability. Many customers use it as their main betting platform, which provides unlimited income opportunities for participants in the 1xPartners program. The 1xPartners and 1xBet mobile apps ensure complete privacy thanks to modern encryption protocols, while an experienced support service with a personal manager is always ready to help and answer any questions. Thanks to this approach, a significant number of players register and deposit on the 1xBet platform using mobile devices. The company not only adapts to market trends but also sets new standards for mobile gambling. The 1xPartners affiliate program is the undisputed market leader and its app is a fantastic tool for conducting business.
Professionals Acknowledge 1xBet as the Best
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Great Prospects with 1xPartners
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1xBet actively explores new niches and works hard to expand its presence. The company provides 1xPartners members with a vast selection of ready-made content adapted to each region, considering the preferences of the local audience. It allows partners to extend their reach and significantly boost the number of attracted clients.
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MAN VS. MODEL
Why the soul of sports betting still depends on a human
heart.
By Mark McGuinness
Our trading rooms are evolving into hightech replicas of City trading floors, powered by algorithms and the promise of quantum computing. We celebrate this march towards transactional perfection. But in our race to manage risk like a financial asset, are we forgetting that, for most punters, a bet is an act of hope not a mathematical equation? Ignoring the human element isn’t just a missed opportunity; it’s a long-term commercial mistake.
I come at this as a third-generation bookmaker from a family of bookies up in Scotland. For my grandfather, dad and my uncles, the job was a craft. They were called turf-accountants back in the day. They loved pricing up events, laying a book not just on cold numbers but on what we knew our punters wanted. Be that the thrill, the local pride, the Saturday afternoon ritual. That personal connection feels a world away now.
We’re Lost
Somewhere along the line, we have lost it. Walk into a modern sports book’s trading room today and you’ll see what I mean. It looks less like a bookmaker’s office and more like a trading floor in Canary Wharf, a digital, artificial and sometimes sterile world. Our senses are overwhelmed by screens and alerts, by tickers that hypnotize you with the constant flicker of profit and loss outcomes. The evolution towards automated risk management and AIdriven pricing feels not only inevitable but necessary.
But as we build these magnificent, frictionless engines of transactional efficiency, I have a nagging question that won’t go away: Have we forgotten what we’re selling?
For a small, sophisticated segment of the customer base, sports betting is indeed a purely financial transaction. They are the sharp bettors, the arbitrage hunters, the players who think in models and expected value. For them, our algorithmic arms race
makes perfect sense. We need these tools to manage the transactional risk associated with professional sports betting players. It’s a defense mechanism, a way to avoid being picked apart in a digital Wild West where speed and data are king. Not having this technology is like turning up to a gunfight with a water pistol.
The problem is that we’ve become so obsessed with defending against this one percent that we’re starting to build our entire customer and product experience around them. We are optimizing our product for the shark, the match-bettor. Meanwhile many of our customers, the recreational punters who are the lifeblood of our industry – are fish. And they don’t want to be treated like sharks.
Impending Danger
Let’s be honest about who the average sports bettor is. It’s the fan who puts a tenner on their team to win, not because the odds represent good value but because it’s their team. It’s the group of mates whose weekend ritual is built around a wildly optimistic accumulator or bet-builder, fueling their conversation in the pub. Their stake isn’t an investment; it’s the price of admission for having skin in the game. It’s an emotional purchase designed to enhance their enjoyment of the sport they love.
So, what happens when this emotional, recreational player interacts with a product built with the cold, extractive logic of a financial trading platform? Their experience becomes sterile. The bets they want to place are restricted, not because they are sharp but because a rigid algorithm flags their pattern of behavior as vaguely unusual. The odds feel clinical and uninspired, mathematically perfect but devoid of any narrative or fun. The promotions they receive are generic,
data-driven carrots dangled by a marketing machine for a temporary surge in bonus funds that does nothing to foster genuine loyalty.
This is where the real danger lies. By treating betting as a purely transactional business, we risk creating a revolving door of customers. We spend a fortune on acquisition to get them in, offer them a sterile and impersonal experience that makes them feel more like a risk to be managed than a fan to be entertained, and then watch them leave when a competitor offers a slightly better signup bonus. Why? Because we haven’t given them a single human reason to stay. We are playing with fire, risking the erosion of our customer base in pursuit of short-term, model-driven perfection.
The Human Factor
This is where the human trader, far from being a relic of a bygone era, becomes our most critical competitive advantage. An algorithm can process historical data with incredible speed. It can calculate the probability of a home win based on thousands of previous matches, player stats and market movements. But can it understand context? Can it feel the mood?
A human trader knows that the star striker just had a very public row with the manager. They know the pitch is waterlogged after a week of rain, which neutralizes the home team’s slick passing game. They see the crowd is on the verge of turning against the players after three poor performances. This is the rich, messy, unpredictable context of sport that models struggle to quantify. It’s intuition. It’s a feel for the game. An algorithm sees data points; a human sees a story unfolding.
This human understanding should inform everything we do, from risk management to product creation. Instead of just offering mathematically
precise odds, a human-led trading team can curate markets that are genuinely engaging. They can create narrative-driven bets, craft promotions that tap into the excitement of a local derby, and offer prices that feel generous and exciting – even if they deviate slightly from the “perfect over-round” line dictated by a model. They can act as a crucial check and balance, overriding a rigid algorithm that is about to give a loyal, recreational customer a poor experience for no good reason.
Think of it this way: The algorithm is the autopilot. It’s brilliant for cruising at 30,000 feet, maintaining efficiency and stability. But for the tricky parts, such as take-off, landing and navigating unexpected turbulence –you need a skilled pilot in the cockpit with their hands on the controls. Our industry is becoming obsessed with flying on autopilot all the time.
Bodies and Soul
So, what is the solution? It’s not to smash the machines and go back to the old days. That would
be commercial suicide. The future is hybrid. It’s about building teams in which quantitative analysts and data scientists work side by side with experienced, empathetic sports traders.
The quants build the engine. They provide powerful models that handle the bulk of the transactional flow, manage the sharp money and protect the business from obvious vulnerabilities. But the human traders are the soul. They are the curators of the customer experience. They utilize their sporting knowledge and market intuition to refine the product, craft engaging narratives, and ensure that the machine’s logic is always tempered with an understanding of the fan.
Ultimately, we have to decide what business we’re in. Are we a lowmargin, high-volume, financial-services company processing transactions with maximum efficiency? Or are we in the entertainment business?
I firmly believe it’s the latter. The long-term winners in this incredibly competitive market won’t be the operators with the most powerful algorithms alone. They will be the ones who successfully combined cuttingedge technology with a genuine
Mark McGuinness is a global marketing executive with 20-plus years’ experience in Web3, iGaming, and crypto. As CMO of Devilfish.com, he pioneers community-led growth, integrating NFTs and decentralized tech to reshape social poker through digital avatars, co-creation, and microtransactions for the next generation of free-to-play players.
human understanding of why people bet on sports in the first place. It’s a radical thought, I know.
They will be the ones who remember that behind every bet slip, there isn’t just a risk profile. There’s a fan, full of hope, looking for a bit of fun. Serving that fan is a job that still requires a human heart and that’s entertainment, folks!
RIGHT: Mark McGuinness
THE GREAT GAMBLE
An overview of gambling regulation and its unintended consequences.
By Edwin Ford
During my years working in the gaming industry, it has been both fascinating and humbling to witness its remarkable evolution. I have always been a strong supporter of regulation, appreciating its importance in promoting responsible gaming and safeguarding consumers. What once lingered on the fringe of society has matured into a globally recognized sector, spanning traditional casinos, online sports betting and dynamic iGaming platforms. Alongside this growth, regulatory frameworks have expanded, shaped by shifting political, economic and cultural landscapes. Across different markets, I’ve quietly observed the unique challenges and opportunities faced by industry stakeholders, particularly as they navigate increasing regulatory complexity. These developments,
while rooted in good intentions, often lead to unanticipated consequences for operators, suppliers and even consumers themselves.
A Global Snapshot of Gambling Regulation
United States: Fragmentation by design Since the repeal of PASPA in 2018, the U.S. has seen individual states implement their own sports-betting laws, leading to a patchwork of regulations, tax structures and operational models. For companies operating across state lines, this fragmented approach demands significant investment in compliance and localized technology. American football (NFL) dominates betting markets in the U.S., followed by basketball, baseball, and college sports, each driving seasonal spikes in activity and marketing.
Europe: A shift toward restriction
Europe has long been a model for structured gambling regulation, with countries like the UK pioneering responsible gaming initiatives and licensing regimes. However, recent changes reflect a tightening stance, such as increased affordability checks in the UK and limitations under Germany’s Interstate Treaty, both of which are adding friction to regulated markets. In most European jurisdictions, football (soccer) is the overwhelming favorite among bettors, while tennis and basketball also maintain solid followings across online platforms.
Brazil: Wagering meets complex reform
Brazil’s move to legalize online gambling, including sports betting, was met with optimism following the passage of Bill 3626 in 2023. The law introduced a 12 percent GGR tax, alongside requirements for local presences and updated supervisory frameworks. Yet the swift layering of regulations, combined with proposals to increase selective consumption taxes, has left many operators navigating a highly complex landscape. Unsurprisingly, football stands at the center of Brazil’s betting culture. With passionate support across all demographics, it accounts for most wagers placed in the country.
Africa: Innovation at the margins
Markets like Kenya, Nigeria, and South Africa have emerged as mobile-first powerhouses in the sports betting space, largely due to smartphone penetration and digital payments. Regulatory environments remain uneven, with licensing delays, taxation inconsistencies and occasional reversals impacting stability. Across much of the continent, football is
by far the most bet-upon sport. Its ubiquity, from European leagues to local competitions, makes it a cultural cornerstone of sports wagering. Basketball is gaining ground as well, particularly with increased exposure to the NBA and prominent African players on the global stage.
Asia-Pacific: Demand meets disparity Asia-Pacific remains one of the most promising yet regulatory-challenged regions. The Philippines has developed a legal and monitored framework through PAGCOR, while other large markets like India and China maintain unclear or restrictive rules that limit formal participation. Football remains a leading sport in betting activity across the region, followed by basketball, horse racing and cricket, particularly in countries like India, where cricket drives massive audience engagement.
Oceania: A mature market under review
Australia, with its established regulatory system, has long stood as a benchmark for legal sports betting. However, growing concerns around gambling harm have prompted stricter advertising rules, stake limits and tighter-responsible gambling
measures. Sports betting in Australia centers on Australian rules football, rugby league and cricket. These sports not only drive significant betting volumes but also shape advertising and sponsorship landscapes within the region.
A Rising Tide of Compliance and Costs
From the standpoint of those within the industry, adapting to ever-changing regulations across jurisdictions has become both a logistical and a financial challenge:
• Platforms often need to operate across 10-plus different regulatory environments simultaneously.
• New rules can require expensive platform redesigns, updates to data handling or fresh certification processes.
• Many markets require local infrastructure, such as offices, banking relationships and customer support, in turn raising the barrier to entry.
• In regions with rapid regulatory turnover, investments can take years to recover, making entry less attractive.
Recent about-turn changes to gaming taxes illustrate this point:
• Brazil’s proposed increase in selective consumption taxes could push total tax burdens near 40 percent.
• Colombia’s 19 percent VAT on deposits has coincided with a drop in user activity.
• Positively, Peru temporarily reduced its turnover tax from one percent to 0.3 percent in response to market pressure.
• The UK, while debating further tax adjustments, has yet to impose new online duties.
• Lithuania raised its gambling tax from 20 percent to 22 percent in 2025 and increased the gambling age to 21.
Though these measures are often implemented to enhance regulation and generate fiscal returns, they may unintentionally increase operational uncertainty, particularly for small and mid-sized operators.
Regulation and its Role in Economic Recovery
In today’s broader economic climate, industries that can provide employment, investment and tax revenue are often vital to recovery strategies. The gambling sector, when properly regulated, contributes meaningfully to these areas. However, sudden policy shifts, elevated taxes or inconsistent oversight can dilute its ability to deliver those benefits effectively. Finding equilibrium between regulatory control and economic potential remains a subtle but essential task for lawmakers and stakeholders alike.
Final Reflections
Having quietly observed the gambling sector’s development over the years,
it’s clear to me that it has grown into a sophisticated, data-driven and globally relevant industry. With appropriate regulatory frameworks in place, it has proved so many times that it can offer not only entertainment but also jobs, innovation and responsible contributions to local economies.
However, as regulations become increasingly fragmented and as tax burdens climb, the sector risks becoming harder to operate within its legal bounds. This could inadvertently shift activity to less-regulated or illegal markets, undermining the very protections these policies aim to secure. These types of regulatory constraints, however well-intentioned, can sometimes hinder more than they help. Without measured, considered approaches, the industry could find itself confronting old challenges in new forms.
Ultimately, we are all aware that regulation is necessary and as a
collective, we value it. However, as seen across multiple regions, prevention, when taken too far, may not always be the cure. Instead, it becomes a detour and slows down an industry that has worked hard to be part of the mainstream economy, and has and will continue to do so responsibly.
FRAMEWORKS AND LOOPHOLES
Eastern Europe’s legal gambling landscape. By
Gambling in Eastern Europe is a multibillion-dollar industry with profound socioeconomic implications. From traditional betting houses to sophisticated online-gambling websites, the region is undergoing explosive change in the gaming industry. What makes this change so fascinating is the diversity of legal regimes, enforcement and regulatory loopholes that allow the industry to flourish in frequently unforeseen directions.
This article analyzes the jurisdictions which form the backdrop of gambling within the various Eastern European countries, reviews key trends, and exposes the exploitation of loopholes by operators and occasionally even by state-owned companies. Policymakers, investors and citizens alike need to
Marko Mitevski
understand this complex environment. Eastern Europe is not homogeneous in its gambling regulation. Politically governed philosophies, religious feelings, economic ambitions and EU legislation vary by country. There are, however, some trends apparent when examining the region as a whole.
Liberal Markets
Countries like the Czech Republic, Romania and Bulgaria have adopted relatively liberal gambling policies. These countries have licensed markets that allow both domestic and foreign operators to run sports books, casinos and online gambling platforms. Such systems are intended to generate tax revenues and attract foreign investment. Romania legalized online gambling in 2015 and has since become a base for European operators. Bulgaria, too, liberalized its market in the early
2010s, with both online and land gambling controlled by the National Revenue Agency. The Czech Republic implemented new legislation in 2017 that introduced strict AML and licensing regulations but had an open market.
Restrictive or Monopolistic Models
In the other political corner are countries like Poland, Slovakia and Hungary, whose administrations have opted for more restrictive approaches. Poland has one of the most strictly regulated gambling markets in the EU. Online gambling is authorized only through state operators for all games except for few types.
Hungary has a quasi-monopoly, awarding licenses to a limited number of companies only, which questions the fair competition. Slovakia has moved towards liberalization but still maintains significant regulatory influence.
Gray and Black Markets
In Serbia, Belarus and Ukraine, regulatory uncertainty has encouraged the development of gray or even black markets. Ukraine banned gambling in 2009 but legalized it in 2020 on strictly regulated conditions. Enforcement remains soft, however, and the majority of illegal sites still thrive.
Belarus legalized online gambling as of 2019 but corruption and loose regulation have allowed unlicensed sites to run rampant. Serbia issues licenses but has been faulted for the transparency of regulation and enforcement effectiveness.
EU Influence and Compliance Challenges
For EU member states in Eastern Europe, aligning national gambling laws with EU principles – especially the free
movement of services and competition law – has proven challenging. The European Union does not have a unified gambling policy, leaving regulation to individual member states. However, it does intervene when national laws restrict the internal market. The European Commission has initiated infringement procedures against several Eastern European countries for discriminatory gambling laws, particularly when foreign operators are unfairly excluded.
Several nations have struggled with compliance. Hungary faced pressure to revise its licensing procedures to ensure fair access for EU-based operators. Poland was warned over its monopolistic online gambling stance. The Czech Republic’s high taxation and AML requirements, while compliant on paper, have discouraged some operators from entering the market.
The Rise of Online Gambling and Cross-Border Loopholes
Perhaps the most dynamic part of the gambling sector in Eastern Europe is the online domain. Mobile apps, digital casinos and cryptocurrency-enabled platforms are proliferating at a rapid pace. One major loophole arises from the cross-border nature of online gambling. Despite local laws, many residents of restrictive countries access international gambling websites via VPNs or mirror sites.
Polish citizens, for instance, often gamble on foreign sites that operate outside of Poland’s national licensing system. Ukrainian players use offshore platforms that circumvent newly imposed local regulations. Even in relatively regulated environments like Romania, operators based in Malta or Gibraltar serve local players without fully complying with national tax obligations.
For more information please visit sbcevents.com or scan the QR code
Payment Processing and Cryptocurrencies
Another hole is payment processing. Where online gaming is prohibited, operators prefer using third-party payment gateways or cryptocurrencies to evade banking controls.
Both Ethereum and Bitcoin are utilized by players and operators in countries like Belarus and Serbia. Payment service providers registered in weakly regulated jurisdictions act as middlemen, effectively hiding gambling transactions.
Regulatory Loopholes and Their Exploitation
The operators are not alone in the gray areas they occupy – governments themselves also take advantage of or endure loopholes in regulation to enjoy increased tax collections or political acceptability. In Slovakia and Hungary, allegations of cronyism and unclear licensing procedures have arisen. Politically connected companies get the licenses, which undermines the peopless trust and EU competition law.
Operators may register in tax havens like Malta, Isle of Man or Curaçao but operate Eastern European markets. The operators pay little or no local taxes and have weak regulatory oversight abroad.
Legal Gray Zones
Some national laws fail to define key terms, such as “online gambling” or “games of skill.” This vagueness provides operators with an opportunity to design products that fall technically outside of regulatory definitions.
For example, fantasy sports and esports betting are in legal limbo in most countries. Loot boxes in video games that mimic gambling mechanics remain largely unregulated across the region.
The patchwork regulatory system likewise has real-world consequences. While gambling yields tax revenues and employment, it also exacts significant social costs. Weak regulatory oversight and anonymity of online transactions provide opportunities for money laundering, tax evasion, and organized crime. Scandals in Bulgaria, Ukraine and Serbia have implicated gambling operators in illegal financial activities.
The Road Ahead
There is movement towards reform despite the hurdles. Some countries are reconsidering existing legislation and searching for EU-harmonized regulatory structures.
Ukraine is working on comprehensive law to fight against illegal operators and promote greater transparency. Romania and the Czech Republic have attempted to simplify licensing and tax regimes in an attempt to attract cautious operators.
There are also arguments in the EU for a uniform regulatory framework or even harmonized guidelines in the member states. But the role calls for significant political will, international cooperation, and investment in technology to close loopholes and protect consumers.
SAFEGUARDING SPORTS THROUGH ATHLETE EDUCATION
An interview with Jean-François Reymond, education ambassador, IBIA
Sports Betting Operator recently sat down with Jean-François Reymond, education ambassador at the International Betting Integrity Association (IBIA), to discuss how trust, education, and international collaboration are reshaping the fight against match manipulation in Canadian and global sports.
What role does education play in IBIA’s anti-match-fixing strategy?
IBIA’s anti-match-fixing model combines prevention, detection and enforcement – all aligned to protect the integrity of sport, as well as the interests of consumers and legitimate betting operators.
Sports-integrity education is a core pillar of IBIA’s prevention strategy. The unfortunate truth is that to corrupt a sporting event – and financially benefit from defrauding betting markets – an athlete or official who can affect in-game events needs to be involved. Targeting athletes, coaches, and officials – especially those from regions lacking robust integrity structures – helps to raise awareness, build resilience against corrupters and promote safe reporting practices. IBIA also actively collaborates with governments, regulators, and sports federations to promote evidencebased regulations and good governance.
ABOVE: Jean-François Reymond, education ambassador, IBIA
When prevention fails, however, IBIA operates the world’s largest integritymonitoring network, analyzing over $300 billion in globally regulated betting transactions annually. The system covers more than 650,000 sporting events and functions as an early warning system for suspicious activity. It directly supports the detection, investigation and prosecution of criminal match-fixers.
Education appears to be a central pillar. Why is that?
Because you can’t legislate a mindset. Many athletes operate in countries where they’ve never encountered integrity policies or whistleblower protections. Some don’t even know corruption is an issue. We want to raise awareness and provide clear, accessible ways to report wrongdoing. But education alone isn’t enough. Leagues need proper rules and sanctions, too.
Jean-François, what makes IBIA’s approach to sports integrity education stand out?
Unlike traditional approaches, we focus on speaking directly to athletes where they train – in familiar, noncompetitive settings. That personal interaction builds trust, which is essential. If a player doesn’t feel safe or comfortable coming forward, the best reporting system in the world won’t help. We consider that the face-to-face element of an education campaign is often the missing piece of existing programs.
Additionally, IBIA’s bespoke programs are designed to suit the needs of our partners in each new jurisdiction. While the foundations, including IBIA’s three Rs model (Rules, Responsibility and Reporting) for recognizing and resisting corruption remain consistent, the key to creating something that is relevant and easily understandable for the athletes concerned.
We count on trusted partners like PFA Canada to help us deliver the education program. Their role and regular access to players – including access to locker rooms at multiple points during the season – means they are trusted, and can deliver our education in a way that resonates. PFA Canada also benefits from IBIA’s expertise. We’ve implemented a trainthe-trainer system, so they can use our content effectively and consistently.
Canada has emerged as a focus for IBIA’s most recent educational efforts. How has this been structured?
It’s important to emphasize that, over the last 15 years, IBIA’s global education campaigns have reached over 36,000 athletes across 13 countries and 10 sports, and that we’re ready to work with sports federations and franchises around the world.
Currently IBIA is doing a lot of work in Canada, partially as a response to the recent development of a regulated sports betting market in Ontario. In 2023, IBIA – supported by its members Bet365, Betway and FanDuel – announced CA$300,000 to fund player education over a three-year cycle. The project provided training for nearly 200 athletes in the Canadian Premier League in 2024.
What’s next for IBIA in Canada? We’re actively looking for more partners. Several federations are already in talks with us and the program is funded, so there’s no cost barrier. We just need organizations to commit to better education.
IBIA is known for its global collaborations. What do those partnerships involve?
As a not-for-profit sports-integrity monitor, building stakeholder alliances and mutually beneficial partnerships is at the heart of our approach. IBIA is unique in working collaboratively with so many partners across the wider sportsbetting ecosystem, nurturing and developing relationships to deliver practical, real-world solutions. We are all on the same team in the fight against sports betting-related fraud: Collaboration is key to protecting sports athletes and fans against match-fixing.
Collaboration between regulators, law enforcement, sporting bodies, and monitoring entities must be formalized and proactive. We have formal data-sharing agreements with organizations like FIFA, UEFA, the IOC and ITIA. IBIA also works closely with law enforcement agencies, including INTERPOL. That allows us to act quickly and efficiently when suspicious activity arises. Beyond that, we help shape international policy through high-level forums, sharing best practices and advocating for national match-fixing platforms.
Let’s talk misconceptions. What are the biggest myths around matchfixing?
That some sports are immune. They’re not. If working conditions are poor, any athlete could be vulnerable. Another myth is that removing regulated betting will stop match-fixing. In reality, unregulated markets pose the biggest threat. They lack oversight, don’t share data and are often linked to organized crime.
Also, many cases that have
nothing to do with betting and sporting-focused manipulation, such as ensuring a team avoids relegation or secures promotion, are surprisingly common. An EUfunded study, coordinated by the University of Ghent, reported in 2021 that almost 70 percent of those approached to fix a match were approached for sporting-related purposes only.
Final thoughts for the industry?
Preserving integrity isn’t just the right thing to do – it’s essential to the business of sport. If fans or sponsors lose trust, the entire system suffers. Integrity has to be built into strategic planning. The good news is, when regulators, operators, leagues and education providers work together, we see real results.
A SIGNAL HONOR
GamCare Trustee Dominic Harrison is awarded an MBE for services to gambling-harm prevention
GamCare welcomed the news that Trustee Dominic Harrison has been awarded an MBE in the King’s Birthday Honors, for his services to gamblingharm prevention and support.
The company’s chair, Margot Daly, reacted thusly, “I am delighted that Dominic has been recognized in this way. Throughout his many years with GamCare, and as chair of our Audit Committee since 2023, Dominic has brought compassion and common sense to the charity’s vital work. During this time, Dominic has seen the charity scale to help tens of thousands of people every year who need our support.
“This news also pays tribute to GamCare’s frontline staff who fulfill the organization’s mission every day,” Daly said, “providing free, confidential support services for
those experiencing gambling harms. I am thrilled for both Dominic and the recognition of GamCare’s essential work supporting those who need it most.”
Harrison has held senior positions in finance, marketing and operations with Grand Metropolitan, Bass and Hilton Group. He spent a decade in the gambling sector in leadership roles with Ladbrokes and Gala Coral. Since 2012, he has held a number of CEO roles in fast-growing, people-based, regulated businesses both in the UK and internationally.
He is a qualified executive coach, currently working with clients across a variety of sectors. In addition to his coaching work, he is an operating partner of Innervation Capital Partners – a specialist investor in education businesses, focusing on the early years sector. He is chair of the Audit, Risk & Development Committee.
