Issuu

SPORTS BETTING OPERATOR

OPINIONS

•

F E AT U R E S

•

VOLUME 008 ISSUE 024

sportsbettingoperator.com

EVENTS

•

INTERVIEWS

THE FUTURE OF GAMING STARTS HERE G2E brings the global gaming community together in Las Vegas—the undisputed capital of the industry—to showcase innovation, foster meaningful connections, and explore the trends, pressures, and opportunities redefining the gaming landscape.

SEPTEMBER 28–OCTOBER 1, 2026 THE VENETIAN EXPO, LAS VEGAS

EDITOR’S LETTER

WHAT THE PRODUCT ACTUALLY DOES

he first 48-team World Cup is settled. The harder contest has only begun, as courts, regulators and legislators stop reading the policy document and start examining the product itself. For a decade, a sportsbook could answer scrutiny with paperwork: a policy, a set of terms, a licence. This issue suggests that era is closing. Holland & Knight’s Katherine Baker, Johnny ElHachem and Samantha Ahearn map four litigation fronts open against US operators, from claims that treat the app itself as a defective product to privacy suits built on tracking pixels. Their conclusion is blunt. Future cases will turn on how the promotion, VIP programme or tracking code actually worked for the customer. ZwillGen’s Whitney Fore and Melanie laCour reach the same point by another route. Historical horse racing rests on pari-mutuel law, yet Louisiana’s Supreme Court and Arizona’s Attorney General have both looked past the mechanics to the slotlike screen. Legal classification, they argue, is now part of product design. Our credit card feature follows the same logic. A dozen US jurisdictions now block credit-funded deposits, Illinois among the latest, and Ohio is consulting on the same step. The principle is old: bet with money you already have. Regulators now expect to see it enforced at the deposit screen. My own piece examines synthetic audiences; the AI tool sold as a way to know players before paying to reach Volume 8: Issue 024

RIGHT: Mark McGuinness, Editor in Chief, Sports Betting Operator

them. It earns a place as a scouting tool for unfamiliar markets. It does not replace real behavioural data, and every output belongs in the decision trail. IBIA’s Q2 Integrity Report makes the constructive case. Ontario’s online sports betting channelisation rose from 5% in 2022 to above 90%, moving activity to where suspicious betting can be seen and reported. Visibility works in the industry’s favour when it is designed in. Elsewhere, Marko Mitevski draws the betting lessons of the World Cup, Eman Pulis previews SiGMA World in Rome, Nick Harding brings sports betting to the London Gaming Show, and B90’s leadership explains its AIdriven growth. The operators that prosper over the next three years will be those able to show their workings. I look forward to seeing many of you in Lisbon at the SBC Summit. Mark McGuinness Editor in Chief Sports Betting Operator 3

CONTENTS 3 EDITOR’S LETTER: WHAT THE PRODUCT ACTUALLY DOES Courts and regulators have stopped reading the policy and started examining the product. By Mark McGuinness 6 WHAT THE WORLD CUP TAUGHT BETTORS Marko Mitevski on the betting lessons of the first 48-team tournament

VOLUME 008 - ISSUE 024 CONTACTS Publisher – Peter White peter@outsourcedigitalmedia.com Guest Editor – Mark McGuinness mark@outsourcedigitalmedia.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 Pensord Press.

15 BETTING ON BORROWED MONEY Why a growing number of US states are removing credit cards as a way to fund sports wagering accounts. By Sam Porter 24 ALL BETS ARE OFF Katherine A. Baker, Johnny P. ElHachem and Samantha Ahearn of Holland & Knight map the four litigation fronts now facing US sportsbooks 31 THE CASINO FLOOR TEACHES THE SPORTSBOOK Synthetic audiences promise to know the player in advance. The casino floor and the regulated market got there first. By Mark McGuinness 34 THE CHANGING RULES OF PARI-MUTUEL Whitney Fore and Melanie laCour of ZwillGen on the legal contest over historical horse racing and pari-mutuel-backed games 43 BEYOND THE NUMBERS SiGMA founder Eman Pulis on why SiGMA World in Rome will be judged by the quality of its connections. By Peter White 49 EXPANDING THE INDUSTRY MIX Nick Harding on broadening industry representation at the London Gaming Show at ExCeL in January 2027 54 SCALING SMARTER B90’s Ronny Breivik and Marcel Noordeloos on the AI-driven platform behind the group’s return to profit. By Peter White 58 FROM DEALMAKER TO STRATEGIC PARTNER Boomerang Partners on the affiliate manager’s changing role 61 FROM ALERTS TO ACTION IBIA’s Q2 2026 Integrity Report and the case for scale in monitoring, regulation and athlete education sportsbettingoperator.com

FEATURE: MARKO MITEVSKI

THE WORLD CUP CHANGED BETTING FOREVER

What the 2026 World Cup taught us about betting on international football. By Marko Mitevski

he 2026 FIFA World Cup

has definitely changed football internationally. It not only expanded to 48 teams but also hosted the matches across Canada, Mexico and United States spread out over 104 matches, making it the biggest World Cup so far. The tournament was also one of the most enlighten ones for everyone who wanted to learn more about football betting. Spain finally lifted the world cup trophy after beating Argentina in a tense 1-0 final, England and France rounded off the podium of the four finalists. The championship was also marked by underdog stories, unexpected tactical surprises, unexpected 6

collapses from strong teams and plenty of last-second dramatic situations demonstrating why global soccer still presents a major challenge for accurately forecasting match outcomes. It doesn’t imply that betting odds or markets weren’t a good representation of real expectations. Quite the contrary, one of the main things that the tournament taught was how betting houses and exchanges made it very hard to beat the price by collecting a massive amount of information. The betting market in total, was very hard to outsmart. The major take for the bettors is this way not mostly to find out who won and who lost a game. Rather, it is about getting to the bottom of what sportsbettingoperator.com

FEATURE: MARKO MITEVSKI made some pre-match assumptions right, why others didn’t work out, and also to see what peculiarities of international football that one should take into account that will help in the evaluation of matches. The 2026 World Cup provided several answers.

The Favorite Is Not the Same Thing as a Good Bet Before competition the expectation was that Spain would be the favorite. In June, published outright markets had Spain at around 4/1, France at 9/2, England at 13/2, Brazil at 9/1 with Argentina and Portugal at approximately 10/1. In Spain’s case though, the eventual win may have come to seem like evidence that the only sensible betting strategy was to back the favorite. That is not entirely correct. This difference between predicting the outcome and finding value is central to football betting. A team can be the most likely winner in a tournament but a betting proposition at a specific price. While an outsider might be unlikely to win but be a good value if the market underestimates its chance. Spain’s win showed that it’s possible for markets to recognize a good team without having to make all of the prices in the market equally enticing. Someone who laid Spain at 4/1 before the tournament was betting very differently from someone who laid Spain at a lower price after the group stage, or someone who laid Spain in knockout matches. This much-debated lesson for the peacetime game may be even more relevant in major tournaments, where the vast proportions of the crowds, the media and the general public pack everything into the one single simple, question: “Who will win?” Volume 8: Issue 024

Professional betting has a different question. Does this price imply a probability lower or higher than my estimate of the team’s true probability? These are not the same. The fact of Spain winning the World Cup does not prove that every bet on Spain was profitable. The fact of Argentina reaching the World Cup final does not prove that Argentina was undervalued at every stage. The fact of England reaching the World Cup semifinal does not prove that every bet on England was a good idea. It’s just the last piece of the puzzle. Price counts.

Spain Showed Why Team Quality Has to Be Evaluated Beyond Reputation One of the strongest points made during 2026 was to separate 7

FEATURE: MARKO MITEVSKI reputation from performance. Spain had come to the competition with a very deep squad, and a clear tactical identity. People knew the team would be affected a bit by a possible injury by Rodri, and the debut of players like Lamine Yamal marked the third generation of Spain’s golden generation. Football on the international stage is way more than an exercise of calling up famous names. This is the reason why the world’s best national teams work their hardest to build a harmonious machine out of players, that for most of the year, are playing for different clubs, coached by different people, and exposed to different footballing philosophies. It is the glue, and the team is the canvas. An international team of players that are slightly less recognizable can on occasion still outclass a team of worldclass stars, provided that the coach gives crystal clear tactics and the players are fully aware of their roles. Spain’s World Cup illustrated to a greater extent that one shouldn’t

should benefit the punters, who are able to understand how a national team actually functions instead of those who rely on how good a player is individually.

just be focusing on adding individual reputations of the players but rather one has to evaluate the player collectively within the team. The match also reminded bettors that they shouldn’t automatically assume that a player’s performance at club level translates to the international level as well. Just a club player with huge influence in one team would not necessarily produce the same level of performance while playing for his country. The football tactics are different. The teammates are different as well. Training time varies. The expectations change. Because of this, international betting

established powers and emerging national sides was not always as large as pre-tournament rankings suggested. Ghana and Cape Verde were among the most prominent examples. Both entered the competition ranked outside the world’s elite yet progressed beyond the group stage, producing results that challenged simplistic assumptions about ranking differences. That matters because betting markets often incorporate rankings and reputation very quickly. A bettor who sees a top-ranked European or South American side facing a lower-ranked opponent can easily assume that the favorite should dominate. But international football is

The 48-Team Format Made the Group Stage Harder to Read The expansion to 48 teams was one of the defining characteristics of the 2026 tournament. FIFA’s new format created a 104-match competition, substantially increasing the number of fixtures and introducing a much broader range of team quality. For bettors, that had important consequences. The traditional World Cup model encouraged relatively simple group-stage calculations. Four teams competed in each group, and every match could have enormous consequences. The expanded tournament produced more opportunities for mismatches, but it also created more uncertainty. Several lower-ranked teams demonstrated that the gap between

sportsbettingoperator.com

FEATURE: MARKO MITEVSKI increasingly globalized. Players from smaller nations are now competing at major European clubs, while national teams have access to increasingly sophisticated coaching, analysis and preparation. The result is a world in which a ranking gap can still be meaningful without being decisive.

Rankings Are Useful, but They Are Not Predictions The 2026 championship reminded us once again that the rankings act as an insight and not a guarantee. This ranking of FIFA bettors gives them a clue from a team’s historical and recent competitive performance. It does not tell them precisely how two teams are going to match up on that particular day. Understanding this difference is the basis for playing international football. For example, a top rank team might struggle against an opposition that plays deeply and attacks via transitions or a second favorite might be exposed by a quick press. On one side, it’s a team of brilliant individual offensive players vs the other of a very tight defense. That’s the reason how each team is put into the opposition is a factor. In international football, this situation gets mostly emphasized because the teams aren’t in the league system on a weekly basis to adjust their tactics for weakness. This means an advantage is given to those who understand what is at hand, i.e. betting against the favorites who are not going to match the rankings.

Underdogs Deserve More Respect Already in the initial phases of the 2026 World Cup, a number of evidences emerged that the competitive middle of international Volume 8: Issue 024

football has become richer: Cape Verde, Ghana and other less-fancied nations, showed that an underdog should not immediately be understood as one with no real shot. That doesn’t mean bettors should so begin backing every long shot. That would be merely replacing a simple strategy with another. The lesson here is that underdog prices merit a second look. A team can be considered the underdog because it has weaker players on average, this does not imply that. A team can be at least five times worse in the outcome of a certain game. An organized defensive unit with good set pieces and a fast counterattack can be a nightmare for a favorite team. This is even more evident in international competitions, since knockout and group-stage games tend to promote cautiousness. Possibly the talent may even become bigger. The underdog may have the best game plan for the particular set of circumstances. Those are two different things. 9

FEATURE: MARKO MITEVSKI previous ones is that it took place in three massive countries and there were lots of logistical and environmental issues.

Weather and Travel Were Not Just Background Details

The main takeaway from 2026 appears to be that bettors cannot merely follow the home team strategy at national league when they bet on international tournaments. League football is all about repetition. Teams play against each other several times. Tactical approaches become a habit. Patterns in home and away fixtures appear. Squad strength can be evaluated over a season. Injuries and suspensions have

The 2026 World Cup took place in North America, with matches held at venues in three countries: Canada, Mexico, and the United States. The weather and the playing conditions became the focus points of the tournament and were brought up again and again. While it is tempting to brush aside factors like weather and climate, they should not be considered trivial if you want to make a successful betting decision. It can be different on different days if you consider the weather factor and you can make a different choice about your playing strategy, for example. Like that, the length of the journey that a team makes will influence their ability to do their preparations and their recovery, mostly when they are going from one very big country to another. Actually, the point is not to

a compounding effect. In contrast, the World Cup condenses all of that. A national side could play seven games throughout the duration of a little over a month. Each game becomes extremely important both from the viewpoint that it is a major mental strain and a factor that determines the level of the rivalry. Coaches are unable to explore various options due to the limited time. Players have to recover in short periods. Weather and travel can have a bearing on a team’s preparedness. Even a single disciplinary action, a penalty kick, or a deflection can led a team to change their entire path in a tournament. One reason the 2026 World Cup was quite different from

emphasize all the factors too much. It is a frequent error in sport betting to get a piece of news which might sound impressive at first glance and immediately decide to put all the eggs in that betting basket. Weather is just a component among many that you need to consider. It only gets meaning when it gets linked with other details like tactics and fitness level. In that case, for example, it is much more likely that a high pressing team will be affected in hot weather conditions whereas a team playing a low block in defense will probably handle the situation better. So, it is not the temperature per se that we are interested in, but rather

Tournament Football Is Different from League Football

sportsbettingoperator.com

FEATURE: MARKO MITEVSKI the question is: ‘Which of the two teams will probably be affected more by the conditions because of the way they play, tactically speaking, and also taking into account how fit they are, etc.? That is a much better and refined way of betting.

Late-Game Football Can Destroy a Good-Looking Prediction The knockout phase gave us a clear illustration of how a game could be drastically altered within a very short time. England’s semifinal game against Argentina was a prime example. England scored first but Argentina managed to get two goals in the dying moments of the game to win 2-1 and get through to the final. Lionel Messi was the man behind two of the late Argentine goals, whereas England’s gradually more defensive approach became the main topic in the match recap. Taking the bettor’s lens, this just confirms one really painful truth. Even when a team is on the right track, leads the match, their chances can go down the drain very quickly. Result on the scoreboard is only one of those features, how the game unfolded behind is much more important. Live in-play betting so revolves around separating the scoreboard figure from the game dynamics. A 1-0 advantage means a great deal if the team in front continues to have control over their attacking moves with lots of possession. But it might be not so valuable once the other side takes control of the field, opens up chances with their attacking moves, and keeps the opponent out of the game. Volume 8: Issue 024

The match between England and Argentina showed us that changing of the momentum in the battle on the field was something of major significance in the knock-out rounds of the tournament. At the same time, the match demonstrates another thing as to why in-play betting mainly can be quite risky to the bettors who are just starting. A sudden huge change in the bookmakers’ odds may give a feeling that there is a good opportunity, but it could be only the bookmakers correctly revaluing the result of the match.

The Market Can Process Information Faster Than a Human Bettor One of the most fascinating pieces of a post event analysis was forecasting artificial intelligence in predicting the 104 matches of 2026 World Cup. A study where they pitted various leading machine learning models against the pre-match betting market using a Brier score comparison showed none of the models could surpass the 11

FEATURE: MARKO MITEVSKI Prediction Accuracy and Profit Are Not the Same

market. The analysis also revealed that a basic approach of simply betting for the market odds favorite could generate profits better than an AI agent. It was also uncovered that there were vast discrepancies between the accuracy of predictions and actual betting return. These results are really not only limited to artificial intelligence but also have very important implications. It shows how challenging it is to surpass a betting market which gathers and processes massive volumes of information. While an individual bettor can spend hours analyzing and researching different aspects like injured players, a team’s tactics, their position in the rankings, the history of the matches and statistics of the players, at the same time, the market is incorporating information from bookmakers, seasoned bettors’ analysts statistical models and even casual players. So, even the market can go wrong and you can’t blame the market for not being perfect all the time. It means that to succeed, you have to rely only on your knowledge about football. You have to find the cases when a market’s price is wrong in a very small number of situations. The problem is such cases are really hard to come across. 12

The artificial intelligence research also pointed out a fundamental difference. A bettor may predict correctly more times than their rival bettor yet they may not have made any money from it. Suppose one analyst is right with eight of ten matches but always goes for heavy favorites. Another one has made seven right calls and found one winner at a high price. Later on, the second analyst might win a larger amount for a given capital. That is one reason why percent correct is an insufficient indicator of a bettor’s ability. In fact, an efficient and profitable betting system should incorporate aspects such as probability price stake, and variance. Exactly the same rule works with World Cup betting. Anyone predicting that Spain would beat Argentina in the final was right only when a match between them hadn’t happened yet. Whether it was a good bet to make, or not really depends on how the bookmakers priced this event. Even after the match has drawn a close, the price alone still cannot make a losing bet a winning bet. No matter whether an individual just casually gives his opinion on a football match or actually analyzes all aspects of a bet, this concept is among the most significant ones.

Penalties Are a Major Source of Betting Variance Penalty shootouts are extremely hard to fit in ordinary match forecast systems. They are not completely random but there is a good degree of randomness involved. The quality of the goalkeeper, the skill in penalty taking, pressure management, and the composition or sportsbettingoperator.com

FEATURE: MARKO MITEVSKI selection decision are all important factors. Yet, compared to the outcome of the regular 90-minute match, the degree of uncertainty is still very huge. This poses a challenge for bettors who are trying to predict the result of knockout fixtures. One team could be only a bit stronger but the odds of losing that particular game to a Penalty Kicks showdown could be quite high. Because of this, backing the team with less strength does not make sense at all. Instead, such a bettor needs to get familiar with the actual market pricing. Soccer tournaments very often give examples where the gap between the “best team” and “team that would most probably progress” is less than what people normally expect.

state will tell more about the team’s potential than just thinking that the team “looks dangerous”. The England-Argentina semifinal showed that the state of the game could change very fast and was a difficult challenge to determine the correct movement of the team.

Technology Is Changing the Information Environment

The World Cup can really get the attention for bettors as all the matches are played to the biggest fan following worldwide. Still, just because you watch the match doesn’t mean that you have the

Along with showcasing how tech is still a big part of football, the 2026 World Cup probably pointed toward a few big technological changes in the world of ball sports. VAR with sensor tech was at it again, as it changed some decisive moments which totally altered game outcomes, and it stirred up the controversy once more. At the same time, the data gathering was so much more refined that it produced even more granular insight on player or team performances. Bettors can now fill their informational bucket with less gaps. Professional gamblers can get a read on new starting eleven lineups,

edge. A bettor might get the feeling that they can “see” the change. Occasionally they are right. At other times they are just having a moment of euphoria for the team’s goal in the last minute. A side can be in total control of the ball yet fail to produce shots on goal. The other could be relatively unaggressive but making up for it in the quality of their opportunities. That means, the best in-play analysis is the one which is based on measurable indicators rather than the impression of the emotions at a moment. Statistics like shot quality, the player’s position, tactical shifts, substitutions as well as the game

the new strategy and the changes made in the games themselves, in about the time it takes to light up and take the first puff of a cigarette. Yet, the presence of technology does not in any way simplify the process of betting. Rather, it usually results in a more transparent market where you are less likely to be fooled or deceived. The modern bettor can now literally find out everything about their potential bets whereas at the same time he is getting beaten up by other highly knowledgeable bettors who are after the same information. This situation is a major part of the paradox that exists in today’s betting world.

In-Play Betting Requires Even More Discipline

Volume 8: Issue 024

18 - 20 JANUARY 2027 FIRA BARCELONA GRAN VIA

YOUR NEXT

MOVE STARTS HERE.

MAKE YOUR MOVE AT ICE 2027

WWW.ICEGAMING.COM | #ICE27

FEATURE: BETTING ON BORROWED MONEY

BETTING ON BORROWED MONEY

Why States are eliminating credit cards from sports wagering

he rapid expansion of legalized sports betting across the United States has triggered an increasingly important debate among regulators: should consumers be allowed to place sports wagers using borrowed money? Increasingly, state gaming regulators are concluding the answer is no. Over the past several years, regulators and lawmakers in multiple jurisdictions have moved to prohibit the use of credit cards to fund sports wagering accounts, citing concerns about compulsive gambling, consumer debt, and financial harm. What initially appeared to be a relatively minor payment-processing issue has evolved Volume 8: Issue 024

into one of the most significant responsible gaming developments in the modern sports betting industry. When online sports betting first expanded following the Supreme Court’s 2018 decision in Murphy v. NCAA, many states focused primarily on licensing operators, establishing tax frameworks, and launching legal wagering markets. Payment methods received comparatively little attention during those early years. That narrative has since changed. Today, regulators are taking a closer look at how consumers fund wagering accounts, particularly when those funds originate from revolving lines of credit. Consumer advocates, treatment providers, and public health experts 15

FEATURE: BETTING ON BORROWED MONEY

have increasingly raised concerns that borrowed money allows individuals to continue gambling beyond their financial means and can accelerate harmful gambling behavior by separating wagering decisions from immediate financial consequences. The Illinois Gaming Board recently adopted proposed rules banning the use of credit cards to fund sports wagering accounts, describing the measure as an “impactful advancement” in responsible gambling policy. Similarly, in May 2026, the Ohio Casino Control Commission announced a proposed amendment to Ohio Administrative Code 3775-16-03 that would remove credit cards as a permissible funding source for depositenabled sports wagering accounts. The proposal was opened for stakeholder comment and received support from responsible gaming organizations. The Problem Gambling Network of Ohio publicly endorsed the proposed change, stating: “These policy shifts reinforce a core low-risk gambling practice: only gambling with money you already have available. Restricting the use of credit cards helps reduce the risk of 16

individuals wagering with borrowed funds, which can contribute to financial instability and gambling-related harm.” The organization further noted: “As sports gambling continues to expand in Ohio, it is critical that safeguards evolve alongside accessibility. By requiring players to use existing funds rather than borrowed money, this policy change promotes safer play behaviors and encourages individuals to better understand and manage their spending.” If finalized, Ohio would join a growing list of states that have concluded the risks associated with credit-funded wagering outweigh the convenience such payment methods may offer consumers.

The History of Payment Restrictions in Gambling Regulation Although the current debate has emerged alongside the rise of online sports betting, concerns about gambling with borrowed money are not new. Historically, gaming regulation has generally distinguished between gambling conducted with available funds and gambling financed through debt. While certain casino patrons have long had access to credit instruments such as casino markers, most gambling activities traditionally required payment with cash or immediately available funds. The underlying principle was straightforward: gambling should generally occur with money a person already possesses rather than funds borrowed from third parties. The growth of internet gaming and mobile sports wagering fundamentally changed the way consumers interact with gambling products. Modern sportsbettingoperator.com

FEATURE: BETTING ON BORROWED MONEY payment systems allow bettors to fund accounts instantly using debit cards, bank transfers, digital wallets, prepaid payment products, and credit cards. These technologies helped fuel explosive growth in online wagering by making account funding faster and more convenient than ever before. As legal sports betting expanded nationwide after Murphy v. NCAA, states understandably focused their initial regulatory efforts on licensing, compliance, taxation, integrity monitoring, and market development. Payment restrictions largely remained an afterthought. However, as markets matured and regulators accumulated more data regarding player behavior, responsible gaming outcomes, and consumer debt concerns, payment methods became an increasingly important area of scrutiny. Many regulators began questioning whether permitting consumers to gamble using revolving debt was consistent with modern responsible gaming objectives. The result has been a growing movement toward restricting or eliminating credit cards as a funding source for sports wagering accounts.

The Public Policy Rationale Behind Credit Card Bans The primary rationale behind credit card restrictions is consumer protection. Unlike debit cards or direct bank transfers, credit card transactions involve borrowing money. When consumers lose funds wagered through a credit card, those losses may be compounded by interest charges, late payment fees, and other borrowing costs. A gambling loss therefore can become substantially more expensive than its original amount. Volume 8: Issue 024

ABOVE: Sam Porter, Author and Partner at Ice Miller LLP who specializes in gaming law

Regulators and policymakers also have expressed concern that credit cards create psychological distance between wagering decisions and financial consequences. Because repayment occurs at a later date, consumers may not immediately experience the impact of gambling losses in the same manner as when using cash or existing account balances. This concern is particularly significant in the online sports betting environment, where deposits can be made instantly and wagers can be placed within seconds. The combination of mobile accessibility, continuous wagering opportunities, and easy access to borrowed funds creates conditions that some regulators view as increasing the potential for harmful gambling behavior. 17

FEATURE: BETTING ON BORROWED MONEY Credit card restrictions therefore advance a core responsible gaming principle: consumers should gamble only with discretionary funds they can afford to lose. Many policymakers also view these restrictions as a practical means of preventing gambling losses from contributing to broader consumer debt problems. Excessive debt can have consequences that extend well beyond gambling itself, affecting family finances, housing stability, employment, and overall financial well-being. Importantly, proponents generally characterize credit card bans as preventative rather than punitive measures. The purpose is not to prohibit sports wagering but rather to encourage participation in a manner that reduces financial risk and promotes sustainable recreational gambling.

The List of States Continues to Grow A growing number of jurisdictions have already prohibited credit card deposits for sports wagering through statutes, regulations, or operator policies. These jurisdictions include: • Colorado • Connecticut (through operator policy) • Illinois • Iowa • Maine • Massachusetts • New Hampshire • Oregon • Rhode Island • Tennessee • Vermont • Virginia Illinois has recently joined this group through regulatory action, while Ohio is actively considering a similar amendment. 18

Meanwhile, lawmakers and regulators in several major sports betting markets, including New York, New Jersey, and Maryland, have considered legislative or regulatory measures designed to reduce or eliminate the use of borrowed funds for sports wagering purposes. Although there is no uniform national framework, the overall direction appears increasingly clear. States continue to evaluate the risks associated with credit-funded gambling, and many have determined that the potential consumer protection benefits justify additional restrictions.

State-by-State Differences in Regulatory Approaches Despite the growing trend, states have adopted different approaches to regulating payment methods. Some jurisdictions prohibit credit card deposits through express statutory language enacted by the legislature. Others rely on gaming commissions or regulatory agencies to impose restrictions through administrative rulemaking. In a handful of jurisdictions, operators have voluntarily chosen not to accept credit cards even in the absence of a specific legal requirement. States also differ in the broader responsible gaming framework accompanying these restrictions. For example, some jurisdictions combine payment restrictions with deposit limits, self-exclusion programs, responsible gaming messaging requirements, advertising controls, and enhanced consumer education initiatives. Other states maintain a lighter-touch approach that relies more heavily on operatorprovided responsible gaming tools. These differences reflect the decentralized nature of gaming regulation in the United States. States frequently serve as policy laboratories, experimenting with various regulatory approaches before reforms gain broader acceptance nationwide. sportsbettingoperator.com

FEATURE: BETTING ON BORROWED MONEY As additional data becomes available, regulators will likely continue evaluating whether credit card prohibitions meaningfully reduce gambling related harm and whether other complementary consumer protection measures should accompany such restrictions.

Responsible Gaming Is Driving Policy The movement away from creditfunded wagering reflects a broader evolution in gaming regulation. When sports betting first became legal in many jurisdictions, policymakers understandably emphasized market creation and economic development. Today, responsible gaming has become an increasingly central component of regulatory oversight. Deposit limits, advertising restrictions, self-exclusion programs, time-based wagering controls, affordability initiatives, and enhanced player protections have all become common subjects of regulatory discussion. Credit card restrictions fit squarely within that broader trend because they address a relatively straightforward policy concern: permitting consumers to gamble with money they do not currently possess. The concept has attracted support from a diverse coalition of stakeholders. Regulators view the restrictions as a practical consumer protection measure. Public health advocates see them as a harm reduction strategy. Treatment providers view them as a mechanism for limiting financial exposure among vulnerable individuals. The policy rationale also resonates across political and ideological lines because it focuses on financial responsibility rather than opposition to gambling itself. Volume 8: Issue 024

Responsible Gaming Research and Consumer Protection Concerns Research relating to problem gambling has further fueled support for payment restrictions. Problem gambling experts have long identified debt accumulation as both a risk factor and a consequence of gambling-related harm. Individuals experiencing gambling disorders frequently report borrowing money, utilizing credit products, or seeking alternative sources of financing to continue gambling after experiencing losses. Behavioral economics research likewise suggests that consumers often spend money differently depending on the payment method used. Cash transactions tend to create greater awareness of expenditures because consumers immediately experience the reduction of available funds. By contrast, credit based transactions can reduce the perceived immediacy of spending decisions. 19

Meet Global Gaming Leaders Get Into Casino Life & Sports Betting Operator TV

Gain exclusive insights from Presidents, CEOs, Owners, and Senior Management at the world’s leading resort casino and sportsbook operators.

FEATURE: BETTING ON BORROWED MONEY In the mobile sports wagering context, regulators have become particularly focused on how frictionless payment systems may affect player behavior. Instant deposits, immediate wagering opportunities, and constant access to gambling products can accelerate spending patterns when combined with access to borrowed funds. Consumer advocates also point to the potential for a harmful cycle in which gambling losses generate debt, debt creates financial stress, and financial stress encourages additional gambling in an effort to recover losses. Restricting access to credit funded wagering is viewed as one measure that may help interrupt that cycle before it develops. Although no single responsible gaming measure can eliminate gambling related harm, many policymakers have concluded that reducing reliance on borrowed funds represents a reasonable and relatively targeted safeguard.

Potential Industry and Operator Impacts

wallets. These options generally provide the same convenience without requiring consumers to incur revolving debt. Credit card prohibitions may also simplify compliance efforts for operators active in multiple jurisdictions. As more states move toward common standards regarding payment methods, operators may benefit from increased uniformity across markets. There is also a reputational consideration. The long-term

For operators, the elimination of credit card deposits presents both challenges and opportunities. In the short term, certain operators may experience modest reductions in deposit volume as customers adjust to alternative funding methods. Credit cards offer convenience, familiarity, and rapid transaction processing, all of which can contribute to user engagement. At the same time, the practical impact may be less significant than it would have been several years ago. Consumers increasingly rely on alternative payment methods such as debit cards, automated clearing house (ACH) transfers, online banking applications, prepaid cards, and digital

success of legal sports betting depends in part on public confidence that the industry operates responsibly. Operators that support consumer protection initiatives may strengthen relationships with regulators, lawmakers, and the public while reinforcing the legitimacy of regulated wagering markets. Many industry participants increasingly recognize that sustainable growth is closely tied to responsible gaming outcomes. Maintaining healthy customer engagement over the long term may ultimately prove more valuable than maximizing short-term wagering activity fueled by borrowed funds.

Volume 8: Issue 024

FEATURE: BETTING ON BORROWED MONEY Finally, technological innovation may naturally reduce reliance on credit card funding. Real time bank transfers, digital wallets, and instant payment systems continue to improve, providing convenient alternatives that do not require consumers to assume additional debt. For these reasons, credit card prohibitions may ultimately become the industry standard rather than the exception.

Looking Ahead

The movement away from creditfunded sports wagering appears likely to continue. First, responsible gaming has become a permanent and increasingly important component of modern gaming regulation. State regulators continue devoting significant resources to studying player behavior and identifying measures designed to reduce gambling-related harm. Second, gaming regulators

The debate surrounding credit cardfunded sports wagering reflects the broader maturation of the legal sports betting industry. What began as a discussion focused primarily on licensing and revenue generation has evolved into a more comprehensive examination of consumer protection and responsible gaming. Regulators today are asking not only whether sports betting should be legal, but also how it should operate in a manner that minimizes harm while preserving consumer choice. The growing movement away from credit funded wagering suggests that

frequently monitor developments in neighboring jurisdictions. When one state’s policies are perceived as successful, similar reforms often appear elsewhere. The growing number of states restricting credit card deposits may therefore accelerate adoption in additional jurisdictions. Third, policymakers are increasingly interested in affordability-based consumer protections. Although the United States has generally taken a more measured approach than some international markets, regulators continue examining methods to ensure gambling remains an affordable form of entertainment rather than a source of financial distress.

lawmakers, regulators, operators, and responsible gaming advocates are increasingly reaching a common conclusion: sports betting should be funded with available money, not borrowed money. Whether through legislation, administrative rulemaking, or voluntary operator action, the trend is unmistakable. As Ohio and other jurisdictions continue evaluating their regulatory frameworks, additional restrictions on credit funded wagering may be on the horizon. For regulators and policymakers, the objective remains clear: promote a legal sports betting market that is not only successful and competitive, but also sustainable, responsible, and protective of consumers.

Future Regulatory Trends and Predictions

sportsbettingoperator.com

GRAND 1XREIGN CONTEST WHERE PARTNERS BECOME CHAMPIONS

SCAN TO REGISTER

FEATURE: HOLLAND & KNIGHT

ALL BETS ARE OFF Holland & Knight LLP, Partner Katherine A. Baker, along with Associates Johnny P. ElHachem and Samantha Ahearn explain the litigation surge reshaping the sports betting industry. An overview of trending legal claims and key compliance considerations

ince the Supreme Court struck down the Professional and Amateur Sports Protection Act (PASPA) in 2018, legal sports betting has expanded to thirty-nine states and Washington, D.C. The commercial sports-betting market generated approximately $16.9 billion in revenue in 2025, before tribal sportsbook revenue and Florida mobile sports betting are included. That growth has been accompanied by increasingly sophisticated litigation challenging not only how operators advertise and conduct wagering, but in some cases the design of the platforms themselves. 24

Four litigation fronts now deserve particular attention: (1) duty-of-care and product liability claims tied to gambling addiction; (2) deceptive promotion and advertising claims; (3) loss-recovery actions premised on allegedly unlawful gambling; and (4) privacy claims under the Video Privacy Protection Act (VPPA), California Invasion of Privacy Act (CIPA), and federal and state wiretap statutes. The cases are still developing, and outcomes vary sharply by jurisdiction. But taken together, they show that sportsbook litigation is moving beyond traditional licensing disputes and toward the operator’s product design, marketing architecture, customer data, and historical wagering activity. sportsbettingoperator.com

FEATURE: HOLLAND & KNIGHT 1. Duty of Care and Product Liability: Is the Sportsbook Itself the Product? The most potentially consequential litigation borrows from the mass-tort playbook used in other industries. Plaintiffs allege, for example, that online sportsbooks are designed to encourage compulsive behavior through rapid wagering opportunities, personalized notifications, data-driven promotions, and VIP programs, and that operators failed to warn adequately about those risks. This is no longer a handful of isolated complaints. A growing number of lawsuits focused primarily on productliability theories have been filed across several states. The complaints allege defective design, failure to warn, and deceptive or unfair conduct involving targeted promotions, notifications, personalization and VIP programs. Traditional negligence theories have encountered substantial resistance, however. At least one appellate court held with respect to a sports betting customer’s interactions with VIP hosts that the relevant state law did not impose a common-law duty of care on gambling operators to protect problem gamblers. The more novel question is whether plaintiffs can avoid the no-duty problem by characterizing the digital platform itself as a defective product. Courts are split on whether a sports betting operator’s app interface can qualify as a “product” under state product-liability law. The emerging lesson is important. The central issue is no longer simply whether a sports betting operator owes a duty to stop a customer from gambling. Plaintiffs are increasingly attacking product architecture itself, and the viability of that theory may turn on state-specific concepts of what constitutes a “product.” Volume 8: Issue 024

Operator consequence. App design, customer segmentation, VIP outreach, responsible-gaming interventions and the records documenting those systems should be treated as part of the potential litigation file. Product, CRM, responsible-gaming and legal teams should be able to explain not only what the written policies require, but how those systems operate in practice.

2. Deceptive Promotions and Advertising: From “RiskFree” to the Fine Print A second litigation front targets promotional language, particularly “riskfree” bets, “no sweat” offers, deposit matches and sign-up bonuses whose restrictions may be less prominent than the headline offer. The theory is straightforward: the headline communicates one economic proposition, while the wagering, playthrough or withdrawal requirements allegedly deliver another. Recent cases show that courts are willing to examine that gap closely. Recent federal court decisions illustrate the growing judicial willingness to let deceptive-advertising claims against sports betting operators survive the motion to dismiss stage. In multiple cases, courts have found that promotional language such as “risk-free” and “no risk” constitutes actionable factual representations rather than mere puffery. These rulings have allowed a range of theories to proceed, including statutory consumer-protection claims, common-law and equitable fraud, intentional misrepresentation, and unjust enrichment, arising from casino deposit match offers, sportsbook deposit promotions, and similar incentive-based marketing. Notably, courts have drawn a distinction between promotional phrases that imply a concrete factual 25

FEATURE: HOLLAND & KNIGHT

promise and softer marketing language that amounts to nonactionable sales talk. Where operators used terms suggesting the absence of financial risk, courts have been more inclined to find that consumers could reasonably rely on those representations. The trend carries a clear message for the industry: aggressive promotional language is increasingly being treated as a litigation liability

The regulatory framework reinforces that point. Ohio requires promotional rules to be clear and unambiguous and provides that an offer described as “free” or “risk-free” cannot require the patron to incur a loss or risk personal funds to use or withdraw winnings. North Carolina requires sports-wagering advertisements not to target persons under 21, to identify the operator, to include gambling-addiction resources, and not to be misleading to a reasonable person. Connecticut goes further in several respects, including by prohibiting advertising that obscures material facts and barring third-party compensation tied to patron volume, wager volume or amount, or wager outcomes. The American Gaming Association’s responsible marketing standards likewise prohibit “risk-free” terminology. Federal law is a more limited piece of this puzzle than it appeared a year ago. The FTC’s “Free” Guides still require material conditions of a “free” offer to be disclosed clearly and conspicuously at the outset. But the FTC’s broader amendments to

rather than a harmless marketing convention. Operators should carefully evaluate the claims embedded in their promotional materials and ensure that bonus and deposit-match offers are accompanied by clear, conspicuous disclosures of material terms and conditions. Regulators are scrutinizing the same conduct. A state consumer-protection agency recently announced that one operator agreed to provide a significant consumer refund following an investigation into deposit-match and deposit-bonus promotions. The agency emphasized that operators must clearly communicate wagering requirements and other conditions attached to promotional awards.

the Negative Option Rule, commonly called the “click-to-cancel” rule, were vacated by the Eighth Circuit on procedural grounds. In 2026, the FTC conformed its regulations to that decision and reopened the subject through a new rulemaking process. Operators should therefore focus on existing federal deception principles and applicable state requirements rather than treating the vacated rule as current law. Operator consequence. Run promotions from headline through withdrawal. The initial creative, qualifying deposit, bonus-credit mechanics, expiration, playthrough, cash-out restrictions, targeting criteria and affiliate instructions should tell

LEFT: Katherine A. Baker, Partner

sportsbettingoperator.com

FEATURE: HOLLAND & KNIGHT one consistent story, and the approved version should be preserved so the offer can later be reconstructed.

RIGHT: Johnny P. ElHachem, Associate

3. Loss Recovery and Illegal Gambling: Illegality Does Not Automatically Equal Refundability A third category of litigation seeks to recover gambling losses, sometimes on a qui tam basis, by arguing that the underlying activity was unlawful. These suits revive old statutes, including descendants of the English Statute of Anne, and combine them with modern challenges to the legality of daily fantasy sports (“DFS”), sports betting-style and other wagering products, and prediction-based platforms. Gambling loss recovery suits by customers, plaintiff’s firms, and classes against gaming operators have been trending across the country for years. Typically they target unlicensed gaming operators where legality is more unsettled rather than licensed operators, but even licensed sports betting operators are not immune. California remains an important

claims seeking monetary relief, including the Statute of Anne theory, holding that California public policy bars recovery of gambling losses absent express statutory authorization. A separate case involving multiple sportsbook operators illustrates how a legislature can alter the exposure directly. The suit asserted a Statute of Anne claim seeking recovery of sports-betting losses and, in certain circumstances, treble damages. While

flashpoint. In a formal opinion, the state attorney general concluded that paid DFS offered to players physically located in California violate section 337a of the California Penal Code section because they constitute wagering on sports. The opinion expressly reached both pick’em and draft-style DFS and explained that the federal UIGEA fantasy-sports provision does not override state gambling law. The opinion created a jumping off point for plaintiffs in a recent federal case to assert gambling loss recovery claims against a DFS operator on the theory that it was conducting illegal wagering in the state. While other consumer protection claims remained, the court dismissed with prejudice the

the case was pending, the relevant legislature amended the statute to make clear that it does not apply to authorized sports wagering. The court dismissed the complaint with prejudice based on that amendment. An appeal remains pending. State classification therefore matters twice. First, the plaintiff must establish that the wagering product was unlawful. Second, the plaintiff must identify a statute or other recognized cause of action that actually permits recovery of the loss. In particular, qui tam loss recovery claims where plaintiffs attempt to recovery the gambling losses of an unrelated third party face pleading hurdles such as properly identifying the specific circumstances of the loss in the complaint.

Volume 8: Issue 024

FEATURE: HOLLAND & KNIGHT

Operator consequence. Product legality and loss-recovery exposure should be analyzed separately, jurisdiction by jurisdiction. A legal-classification dispute can create regulatory exposure without necessarily creating a private refund remedy, while an old recovery statute can create unusually large claims if its text reaches the conduct at issue.

4. VPPA, CIPA and Wiretap Claims: Follow the Data, Not Just the Bet The fourth litigation front arises from what happens after a customer opens an app, views content or interacts with a webpage. Tracking pixels, Software Development Kits (SDKs), advertising tags, and analytics tools can transmit identifiers, URLs, content information, and behavioral data to third parties, creating potential claims under statutes written long before modern ad-tech systems existed. While these suits have been trending for years against video streaming platforms and media companies, gaming operators had largely avoided them until recently. One recent class action against a sports betting operator asserting VPPA and Federal 28

Wiretap claims related to the use of pixels and tracking technologies ended in settlement. The VPPA can create exposure when a qualifying video provider knowingly discloses personally identifiable information concerning a consumer’s video-viewing activity. But the presence of a video and a pixel is not enough by itself. Provider status, consumer status, what information was transmitted, whether it identifies a particular person and particular video materials, and consent all matter. Potential exposure is high based on recent multimillion-dollar settlements outside the sports betting context where pixel-based disclosure of videoviewing information occurs. CIPA presents a separate and rapidly changing problem. A federal court recently denied dismissal of claims involving common third-party tracking technology. The court later stayed the case while state courts considered whether CIPA’s pen-register provision applies to commonplace internet technologies. The procedural shift underscores the complexity and unsettled nature of the legal landscape in this area. Federal wiretap law adds another layer. Section 2511 of Title 18 of the United State Code supplies the substantive interception prohibition, while Section 2520 authorizes civil remedies for qualifying violations. State statutes can provide additional remedies and may differ materially on consent, party exceptions, interception and statutory damages. Operator consequence. Build and maintain a live data map. Legal and privacy teams should know every pixel, SDK, tag and analytics vendor; which page, video or event triggers it; what fields leave the operator’s environment; who receives them; what consent signal was captured; and how long the data is sportsbettingoperator.com

FEATURE: HOLLAND & KNIGHT retained. Where consent is relied upon, it should be conspicuous, appropriately timed and tied to the actual data flow rather than resting solely on an inconspicuous privacy-policy link. Practical Compliance Priorities Across these four litigation fronts, several operating disciplines recur. Responsible-gaming teams should document self-exclusion, deposit and time limits, cooling-off tools, VIP escalation protocols and employee training. Product and CRM teams should preserve the decision logic behind notifications, promotions, customer segmentation and responsible-gaming interventions. Marketing teams should review offers from headline through withdrawal and maintain the final creative, complete terms, targeting criteria and affiliate instructions together. Product-legality reviews should be refreshed as state statutes, attorney-general opinions and court decisions evolve, especially for DFS and novel wagering products. Privacy teams should maintain a current inventory of third-party tracking technology and test whether the actual implementation matches the consent and disclosures presented to users.

Conclusion The litigation landscape facing sports betting operators in 2026 is becoming more sophisticated. Addiction cases are testing whether a sportsbook interface can itself be treated as a defective product. Promotion cases are moving beyond complaints and into decisions allowing consumerprotection and fraud theories to

RIGHT: Samantha Ahearn, Associate

proceed. Loss-recovery plaintiffs are reviving centuries-old statutes, but courts are also drawing a line between illegal gambling and a legally cognizable right to recover losses. Privacy plaintiffs are applying VPPA, CIPA and wiretap theories to the tracking infrastructure embedded in digital wagering products. The common denominator is operational evidence. The question in the next generation of sportsbook litigation will often be not only what the operator’s written policy said, but how the product, promotion, VIP program or tracking technology actually worked for the customer. Operators that can demonstrate transparent marketing, defensible product design, effective responsible-gaming controls, jurisdiction-specific product review and privacy-by-design will be better positioned in an increasingly litigation-intensive environment.

Disclaimer: This article is provided for informational and educational purposes only and does not constitute legal advice. Discussion of pending litigation reflects allegations that have not been adjudicated on the merits unless otherwise noted. Readers should consult qualified counsel regarding their specific circumstances. The views expressed herein do not necessarily reflect the views of any law firm, attorney, operator or trade association. Volume 8: Issue 024

FEATURE: MARK MCGUINNESS

THE CASINO FLOOR TEACHES THE SPORTSBOOK Synthetic audiences are being sold as the industry’s next gold rush, the holy grail of knowing the player before you pay to reach them. Yet the richest seam in gaming was mined years ago, on the casino floor and under the discipline of the most regulated markets on earth. Sports betting should learn from both before it stakes its claim. By Mark McGuinness

he gambling industry is hunting for the holy grail

again. This time it wears a new name: the synthetic audience. Feed an AI your data, your research and a description of a segment, and it conjures a crowd of artificial bettors who will answer questions, react to a price and, in the boldest version of the claim, tell you what real customers will do before you spend a penny reaching them. The pitch calls it the next gold rush. I would treat that comparison more carefully than the people making it.

A category with a budget line There is real money here, which is why the noise is loud. The synthetic data market was worth roughly 600 million dollars in 2025 and is forecast to pass Volume 8: Issue 024

6.9 billion by 2034, a compound growth rate north of 31 per cent a year, according to Fortune Business Insights. One projection, widely attributed to Gartner, held that by 2024 most of the data used to build AI would be synthetic rather than real. This is not a fad in the sense of being small. It is a fad in the sense of being oversold. Both things can be true at once.

The house struck it first Before sports betting reaches for the shovel, it should look downstairs, at the casino floor. Long before Silicon Valley made data fashionable, land-based casinos ran the most sophisticated customer-analytics operation in any consumer business. The loyalty card did it. Every carded bet, every session, every visit, every comp became a live 31

FEATURE: MARK MCGUINNESS will never fail an affordability check, because it was never real enough to have money. Your customers are.

The honest case

record of real behaviour. Not a survey. Not a stated intention. The thing itself. Harrah’s, under Gary Loveman, turned that card into a science and built a player experience the online world is still trying to copy. Now look at the sportsbook. The behavioural data is there, and in some ways, it is richer: live bet history, inplay decisions, cash-out behaviour. But too much of the industry has spent a decade chasing acquisition and stacking promotions rather than mining the relationship the casino host built patiently over years. The first lesson from the floor is not about technology. It is about attention. The house grew rich by knowing its players. The sportsbook keeps paying to find new ones.

The discipline of the regulated market The second lesson comes from the hardest classroom in gaming, the regulated market. Operating across licensed jurisdictions, the United States state by state, the United Kingdom under affordability and sourceof-funds scrutiny, forces a sportsbook to learn things about its customers that no synthetic set contains. Whether a player can actually afford the stake. Where the money genuinely comes from. What real risk behaviour looks like when a regulator is watching. This is expensive, inconvenient ground truth, and it is exactly the kind a model trained on yesterday’s marketing data does not hold. A synthetic audience 32

None of this means the tool is worthless. There is an honest case, and it is a good one. Your own data only knows the bettors you already have. It says nothing about the ones you have never met. A sportsbook entering a new state, or chasing a younger customer who has never held an account, faces a blank space where the data should be. A synthetic audience, built from adjacent markets and public research, can stress-test a position or a price for that unknown segment in days, not months. As a way to scout territory you have not yet entered, that is genuine value. As a substitute for the real bettor data and regulated-market learning you already hold, it is fool’s gold.

The catch Because a synthetic audience is a mirror. It is built from what people have already done, and a model trained on the past can only ever hand you back the past, dressed as a prediction. Practitioners who use these tools daily now advise treating synthetic findings as hypotheses, not facts. The failure modes are specific. Bias amplification, where the model hardens yesterday’s patterns into tomorrow’s certainty. Sycophancy, where it returns the agreeable answer, it thinks you want. Hallucination, where it invents with total fluency. None of these are edge cases. They are properties of the technology.

The gold rush question Which brings us to the question every board should ask, and few do. If synthetic audiences were the mother lode the vendors describe, sportsbettingoperator.com

FEATURE: MARK MCGUINNESS marketing would be a solved problem, wouldn’t it? Every campaign would convert. Every price would be right. No operator would ever again misjudge a market or launch a promotion that lands flat. That world does not exist. No sportsbook, however good its model, wins every slip, prices every market perfectly or retains every account. The reason nobody converts 100 per cent of anything is the same reason a synthetic audience cannot promise it. Real markets contain competitors you do not control, a result that goes the wrong way, budgets that run out, and human beings who act against their own stated preferences every day. Remember how the actual gold rushes ended. In the Klondike, the overwhelming majority who chased the gold went home with less than they arrived with. The people who reliably got rich sold the shovels.

Follow the money

and the regulated market have already handed you: real behaviour on your own book, and hard-won knowledge of who your customers actually are. Keep a human in the loop who is paid to disagree with the model. And treat every synthetic output as part of your decision trail, because in this industry a regulator may one day ask to see exactly how you decided who to target and how to price.

That is the part worth staring at. Most synthetic-audience tools are sold on consumption. You pay by the query, the token, the audience run. Per-token prices keep falling, yet invoices keep

So, what is my marketing thought?

rising, because a single AI action now triggers dozens of model calls beneath the surface. The vendor’s logic is therefore simple. The more audiences you generate, the more you pay. When the recommendation is always to run another simulation, ask who is selling the shovels.

the stack as a useful scouting and pretesting layer, genuinely helpful for the unknown and quietly overbought for the known. The gold rush is the promise that more simulation equals more certainty. The value is the disciplined operator who augments the tool with real learning from the floor and the regulated market, and never mistakes one for the other. Sports betting does not need to strike it lucky. It needs to do what the best casinos have done for thirty years. Know the real player. Respect the regulated ground beneath its feet. And treat any machine that claims to shortcut both with the scepticism it has earned. Mine your own seam first. It is richer than anything the gold rush is selling.

How to use it well So how should a serious operator use it? Augment, do not replace. Treat synthetic audiences as a scouting tool for the bettors you do not yet have, not an oracle for the ones you do. Let them narrow the field and pre-test the obvious mistakes out of a campaign. Then validate what survives against the two sources of truth the casino floor Volume 8: Issue 024

Synthetic audiences are neither the fad the sceptics claim nor the holy grail the vendors sell. They will settle into

FEATURE: ZWILLGEN

THE CHANGING RULES OF PARI-MUTUEL The Evolving Regulatory Landscape for Historical Horse Racing and Online Pari-Mutuel-Backed Games. By Whitney Fore and Melanie laCour, ZwillGen Similar Foundation, Different Plumbing Historical Horse Racing (“HHR”) machines – sometimes referred to as “instant racing” – and their newer online cousins sometimes described as pari-mutuel-backed games (“PBGs”) have emerged as alternative pathways to offering casino-style gaming experiences in states that do not otherwise permit traditional retail slot machines and/or interactive online gaming (“iGaming”). In some jurisdictions, these products have also provided an additional revenue stream for the pari-mutuel racing industry as wagering on traditional live racing has declined over the past several decades. 34

To the untrained eye, HHR and PBGs may appear, for all intents and purposes, to be casino-style gaming – primarily in the form of slot machines. However, just because it walks like a duck and quacks like a duck does not necessarily make it a duck, at least according to proponents of alternative forms of pari-mutuel wagering. While HHR machines and online PBG platforms can look, move, and reveal results like slots, the central distinction advanced by proponents is that the wagering outcome derives from pari-mutuel horse racing rather than the random number generator (“RNG”) that determines outcomes in traditional slot machines. sportsbettingoperator.com

FEATURE: ZWILLGEN Those who are familiar will recall that we’ve been down a similar road before with video lottery terminals (“VLTs”), which proliferated years ago at racinos and other authorized venues. To the player, a VLT may appear virtually indistinguishable from a slot machine, while the underlying architecture relies on a central lottery system rather than an RNG independently determining the outcome of each play. For HHR and PBGs, pari-mutuel wagering on horse races serves as the engine in place of the RNG. Physical HHR terminals allow patrons to wager on previously run horse races, frequently displaying characteristics typical of traditional slot machines, such as spinning reels, symbols, lights, and sounds. Developers of online PBG products use a different structure in which customer funds are routed through advance deposit wagering (“ADW”) infrastructure into live parimutuel racing pools, with the resulting wagering outcomes displayed through customer-facing interfaces designed to resemble online casino games. In both instances, the player sees a casino-style experience on the front end, while the product is structured around pari-mutuel wagering on the back end. Pari-mutuel wagering is one of the oldest legal forms of gambling in the U.S. and, until recently, remained unchanged in substance. Even the proliferation of ADW changed only where and how customers placed wagers, not the underlying nature of the wager itself: a bet on a live race placed into a commingled pari-mutuel pool. HHR and PBGs represent efforts to adapt that longstanding model for modern gaming formats. Yet compared with other novel gaming products, little attention has been paid to the regulatory implications. Volume 8: Issue 024

The disputes that have emerged around HHR and PBGs tend to bifurcate into two distinct but related questions: 1. Are these products – and HHR in particular, given its use of previously run races to determine win/loss – properly classified as pari-mutuel wagering? 2. Even if the answer is yes, does a slot-like interface or delivery mechanism nevertheless create a new or separately regulated form of gaming that falls outside the existing authorization for parimutuel wagering? Those two questions can, in turn, require separate consideration of whether the wager type and pool are authorized, whether the operator and delivery channel are properly licensed, and whether federal interstatewagering rules, constitutional provisions, or tribal-state compacts impose additional constraints.

The Federal Floor: IHA, Wire Act and UIGEA Before turning to those questions, the PBG model presents an additional federal layer because it relies on interstate ADW infrastructure. That federal framework must also be considered when assessing the product’s legality within the existing U.S. pari-mutuel wagering regime. Unlike physical HHR machines, the PBG model implicates the Interstate Horseracing Act (“IHA”), which governs interstate off-track wagering on horse racing. Broadly, the IHA provides that an interstate off-track wager may be accepted only when the wager falls within the Act and the required consents are obtained from the host racing association, host 35

FEATURE: ZWILLGEN

racing commission, and off-track racing commission. See 15 U.S.C. §§ 3002, 3004. Because the wagers are transmitted interstate via the internet – or “wires” – the Wire Act is also potentially implicated, although a full Wire Act analysis is beyond the scope of this article. The Unlawful Internet Gambling Enforcement Act (“UIGEA”) is likewise relevant, but expressly excludes activity allowed under the IHA from the definition of “unlawful Internet gambling.” See 31 U.S.C. § 5362(10)(D). The question of where an electronic wager is “accepted” for purposes of the IHA was recently addressed in Churchill Downs Technology Initiatives Co. v. Michigan Gaming Control Board, 162 F.4th 631 (6th Cir. 2025). In that case, ADW operator TwinSpires challenged Michigan requirements that conditioned its ability to accept wagers placed by Michigan residents on state licensing tied to an in-state racing relationship. TwinSpires argued that its Oregon wagering hub – not the bettor’s location – was the place where the wager was accepted and therefore the relevant off-track jurisdiction for purposes of the IHA’s consent requirements. In December 2025, the Sixth Circuit affirmed preliminary injunctive relief on TwinSpires’ IHA conflict36

preemption claim, and on January 6, 2026, the district court granted summary judgment and a permanent injunction. The decisions treat the relevant off-track jurisdiction as the ADW hub where the wager is accepted and limit states’ ability to impose additional licensing conditions that conflict with the IHA’s consent structure. However, Churchill does not turn the IHA into a nationwide safe harbor for every product self-characterized as pari-mutuel. It addresses interstate regulation and state licensing conditions imposed on otherwise lawful horse-racing wagers, but it does not answer whether a particular product qualifies as lawful parimutuel wagering in the first place. Notably, even post-Churchill, states continue to regulate online parimutuel wagering. In February 2026, for example, South Dakota enacted H.B. 1058, requiring certain out-ofstate providers offering online parimutuel wagering to South Dakota residents to obtain multi-jurisdictional totalizator-hub licensure.

Question One: Is It PariMutuel Wagering? Regarding the characterization of HHR and PBG games, the first question above is the threshold: does the platform satisfy the governing definition of pari-mutuel wagering? HHR has generated most of the litigation to date because of its use of historical races. Both HHR and PBG, however, can raise questions about whether their pooling mechanics satisfy traditional pari-mutuel requirements, including whether bettors are genuinely wagering against one another in a common pool tied to an authorized wagering event. sportsbettingoperator.com

FEATURE: ZWILLGEN Kentucky: What Makes a Pari-Mutuel Pool? Kentucky provides the clearest example of this threshold fight. In 2010, the Kentucky Horse Racing Commission – now the Kentucky Horse Racing and Gaming Corporation – adopted regulations authorizing HHR. The Family Trust Foundation of Kentucky, Inc. challenged the Commission’s authority to authorize the games, arguing that HHR did not constitute lawful pari-mutuel wagering. In Appalachian Racing, LLC v. Family Trust Foundation of Kentucky, Inc., 423 S.W.3d 726 (Ky. 2014), the Kentucky Supreme Court held that wagering on historical races could fall within the Commission’s authority, but only if the wagering system satisfied the legal requirements of pari-mutuel wagering. The litigation eventually culminated in Family Trust Foundation of Kentucky, Inc. v. Kentucky Horse Racing Commission, 620 S.W.3d 595 (Ky. 2020), where the court determined that the HHR system before it did not satisfy Kentucky’s then-existing pari-mutuel framework. Patrons were not wagering against one another on the same discrete event; different patrons could be wagering on different randomly selected historical races rather than participating in a common pool tied to the same race. The court also concluded that the association-funded initial seed pool impermissibly involved the association in creating a pool that was required to be established by the patrons. The Kentucky Legislature responded in 2021 by enacting S.B. 120, which broadened the statutory definition of pari-mutuel wagering to encompass wagering on live, simulcast, or previously run races; permitted wagers to be placed into one or more wagering pools; and expressly allowed wagers involving different races or sets Volume 8: Issue 024

RIGHT: Whitney Fore is a Legal Director at ZwillGen, a midsize law firm specializing in emerging technology, artificial intelligence, and data-driven legal challenges. Whitney advises interactive gaming, fantasy sports, and sweepstakes operators on the complex web of state and federal regulations that govern online gaming and promotional entertainment. She can be reached at whitney@ zwillgen.com.

of races to be pooled together, directly addressing the concerns underlying the litigation. The Kentucky dispute and subsequent legislative solution illustrate how regulatory approval and a pari-mutuel label do not necessarily foreclose judicial scrutiny of whether the mechanics fit the statutory definition. They also demonstrate that judicial rejection of a particular HHR structure need not be the end of the road if the legislature chooses to broaden what counts as pari-mutuel wagering. Minnesota: The Legislature Answers the Question Directly An example of a state legislature going in the opposite direction occurred in 2024, when the Minnesota Racing Commission approved requests by Running Aces and Canterbury Park to offer HHR at their facilities. The Legislature responded by amending the statutory definition of “pari-mutuel betting” to expressly exclude wagering where bettors are not wagering on the same live or simulcast race or do not share in the total amount wagered. Minn. Stat. § 240.01, subd. 14; the practical result of which was to override the Commission’s approval 37

FEATURE: ZWILLGEN

and establish that HHR does not qualify as lawful pari-mutuel wagering. The Legislature also separately prohibited licensed racetracks from offering HHR in Minn. Stat. § 240.071. Notably, because it uses live racing rather than previously conducted events to determine win/loss, if challenged, the PBG model may present a stronger argument under traditional pari-mutuel definitions where each play is tied to a wager placed into a live-race pool. However, calling a platform an ADW, or describing the underlying transaction as pari-mutuel, does not itself resolve the classification question.

Question Two: Even If the Wager Is Pari-Mutuel, Is the Product Something Else? Even assuming the underlying wager qualifies as pari-mutuel under the applicable state statutory definition, can the interface or overall customerfacing presentation independently constitute a new or separately regulated form of gaming? The cases and regulatory disputes that have emerged suggest that, in some jurisdictions, the answer may be yes. 38

Tribal Exclusivity: A Separate Classification Question Question two – whether HHR and/ or the PBG model constitute a new or separately regulated form of gaming – has drawn scrutiny in tribal gaming states. Under the Indian Gaming Regulatory Act (“IGRA”), both pari-mutuel wagering on horse races and slot-machine gaming fall within the Class III game category, but the scope of tribal gaming exclusivity depends on state law and the terms of the tribal-state gaming compact. As a result, even if the underlying wager is pari-mutuel by definition, the game interface or device may separately qualify as a compactdefined “Gaming Device,” slot machine, electronic facsimile, or other form of gaming exclusively reserved for tribal operators. In Ariz. Att’y Gen. Op. I18-010 (Aug. 23, 2018), the Arizona Attorney General concluded that nontribal HHR would implicate compact exclusivity because HHR was not an authorized form of gaming at the compacts’ relevant 2002 historical baseline. After Arizona amended its compacts in 2021, Ariz. Att’y Gen. Op. I24-003 (Feb. 22, 2024) concluded that the amendments did not change that result. The 2024 opinion further noted that the “appearance, graphics, animation, and sound” of modern HHR terminals are nearly identical to slots, while the principal distinction lies in the pari-mutuel back-end mechanics, and concluded that the terminals fit the amended Compact’s definition of a “Gaming Device.” Minnesota tribes raised a similar concern before the 2024 prohibition discussed above. The Shakopee Mdewakanton Sioux Community argued to the Minnesota Racing Commission that modern HHR devices were “no different from slot machines” sportsbettingoperator.com

FEATURE: ZWILLGEN notwithstanding their use of parimutuel races to determine win/loss. Idaho offers a more historical example of the political implications of authorizing HHR in a tribal gaming state. In 2013, the state legalized HHR pursuant to Idaho Code § 54-2512A. After critics – including Idaho tribes – argued that the terminals were effectively slot machines rather than the pari-mutuel product lawmakers believed they had authorized, the Legislature repealed the HHR authorization in 2015. The Coeur d’Alene Tribe then successfully litigated to require certification of the repeal after the governor’s attempted veto. Coeur d’Alene Tribe v. Denney, 161 Idaho 508, 387 P.3d 761 (2015). Notably, Denney decided the veto issue, not whether HHR constituted a slot machine; however, its significance here is as a case study in the political and legislative consequences that can follow when the implementation of a wagering product is perceived to differ materially from the authorization that produced it. Oregon: An Authorized Product, but a Prohibited Casino? Oregon expressly authorized HHR under Or. Rev. Stat. § 462.155, and HHR operated for several years at Portland Meadows racetrack. However, when an operator sought to install 225 HHR terminals at the Flying Lark adjacent to Grants Pass Downs, Oregon DOJ Opinion OP-2022-1 (Feb. 11, 2022) concluded that the proposed machines were games of chance that afforded no meaningful opportunity to exercise skill and that the proposed 225-machine operation would create a constitutionally prohibited casino. The Oregon Racing Commission expressly disagreed with aspects of that analysis, stating that HHR was pari-mutuel wagering and that the Volume 8: Issue 024

RIGHT: Melanie laCour is a Legal Director at ZwillGen whose practice focuses on advising on a wide range of gaming-related regulatory, licensing, corporate and compliance issues. Melanie draws on her extensive experience in the gaming industry to guide clients through a range of regulatory and transactional matters. She can be reached at melanie@ zwillgen.com

Flying Lark was not a casino, but concluded that it was constrained by the Attorney General’s opinion and denied the application to install the machines. For the newer PBG model, comparable reported judicial or published regulatory disputes have not yet developed. The use of live-race pools may strengthen the pari-mutuel argument relative to HHR, while leaving unresolved whether the consumer-facing product itself triggers separate gaming-law requirements. Louisiana: Pari-Mutuel, but Still a “New Form of Gaming” Louisiana provides the clearest illustration of Question Two for HHR. The Louisiana Constitution requires local voter approval for any “new” form of gaming not previously authorized before a specified cutoff date. In 2021, Act 437 defined HHR as pari-mutuel wagering and authorized it through Louisiana’s existing racing framework. In Fremin v. Boyd Racing, LLC, 403 So. 3d 546 (La. 2025), however, the Louisiana Supreme Court held that HHR constituted a new form of gaming requiring local voter approval. 39

FEATURE: ZWILLGEN

In doing so, the court emphasized that HHR used “slot machine-like gaming terminals,” that historical race results were used to generate the underlying betting algorithm, and that the wagering bore “little, if any, relation” to wagering on a live horse race. The significance of Fremin lies in the court’s rejection of the argument that simply placing HHR within the pari-mutuel framework resolves the separate constitutional question of whether the product constitutes a new form of gaming. California: Approval of the Wager vs. Approval of the Product Most recently, in January 2026, California Department of Justice law-enforcement personnel seized twenty-six “Racing on Demand” terminals from Santa Anita Park. The terminals were a form of HHR offering a version of a “3x3” pari-mutuel wager using previously concluded races. Los Angeles Turf Club subsequently filed suit in Los Angeles Superior Court, seeking return of the machines and a declaration concerning the legality of the wagering. Los Angeles Turf Club’s position is that the underlying 3x3 wager had previously been approved by the 40

California Horse Racing Board in 2024 and that Racing on Demand used that format with randomly selected races that had already concluded. The state’s position is that approval of the 3x3 wager for contemporaneous live races did not authorize that implementation. This pending dispute asks how far an operator may extend an approved wager before the resulting product becomes materially different from what the regulator authorized and requires separate approval. As of this writing, the litigation remains pending, but its resolution could illuminate the distinction between approval of a wager and approval of the product through which it is delivered. Are Looks Everything? None of the foregoing means that a casino-style interface, standing alone, converts an otherwise lawful pari-mutuel wager into an illegal slot machine. But experience in other gaming verticals suggests that regulators, law enforcement, and courts may also be unwilling to treat the user interface as legally irrelevant. For purposes of analogy, one need only look to the recent proliferation and subsequent crackdown on online dual-currency sweepstakes casinos. On August 19, 2026, for example, the Florida Attorney General filed two lawsuits against operators of online sweepstakes casinos and their payment processors, alleging that their sweepstakes structures disguised unlawful real-money gambling. He summarized the state’s position as: “If it looks like a casino, takes real money like a casino, and pays out like a casino, it is a casino.” While the complaints do not rest on appearance alone, the Attorney General’s statement reflects a willingness to look beyond the asserted legal mechanics to the product delivered to the player. sportsbettingoperator.com

FEATURE: ZWILLGEN Pennsylvania’s recent physical “skill game” litigation provides another helpful example. In June 2026, in the consolidated In re Three Pennsylvania Skill Amusement Devices and POM of Pennsylvania appeals, the Pennsylvania Supreme Court held that the devices at issue were subject to the Gaming Act and Crimes Code and that the POM device satisfied the statutory definition of a slot machine. Although the court observed that the devices “outwardly resemble[d]” modern electronic slot machines, the holding turned on Pennsylvania’s statutory definition of “slot machine,” which encompasses machines involving skill or a combination of skill and chance. The broader point being that substituting a different mechanism for one traditional feature of slot gaming does not necessarily remove a product from an independently applicable statutory gaming classification.

appointed on July 30. As of September 3, 2026, the HHR issue remained unresolved. The contrasting approaches nevertheless illustrate how the categorization of these games can come down to a legislative policy choice.

Conclusion

It will come as no surprise that legislatures are now increasingly confronting both questions. In New York, pending S.6969 and A.11432

HHR and the PBG model sit at an unusual intersection of old law and new technology in a rapidly evolving, highly scrutinized gaming space. Their legal foundation rests on an old and heavily regulated form of gambling, while their consumer-facing presentation

would expressly authorize HHR through specified racing and off-track betting entities and place the product within the state’s pari-mutuel wagering framework. Massachusetts illustrates the same classification debate in legislative form. In July 2026, the Massachusetts House passed H.5576 with provisions that would treat wagers on certified HHR terminals as pari-mutuel wagering and permit eligible licensees to accept HHR wagers both at authorized facilities and through account wagering. The Senate subsequently passed a substitute version, reflected in S.3228, that omitted the House HHR provisions. The House nonconcurred, and a conference committee was

increasingly resembles newer, more tightly regulated casino gaming products. Whether these platforms qualify as pari-mutuel wagering – and, even if they do, whether their interfaces or other product features independently trigger another gaming classification – remains a jurisdiction- and productspecific question. For operators developing the next generation of pari-mutuel-backed games, legal classification is therefore becoming part of product architecture itself. The relevant question is no longer simply what determines the result. Increasingly, courts, regulators, legislatures, and tribal stakeholders are also asking: what product is being offered to the player?

Looking Ahead

Volume 8: Issue 024

SPORTS BETTING OPERATOR Sports Betting Operator provides technology features, news and new product information, keeping online gambling companies up to date with the fastest growing gambling sector in the world

A highly regarded team of Internationally experienced journalists, all of whom have a wealth of knowledge in online and land-based gaming involving, legislation, e-commerce, responsible gambling along with the latest online operating systems and solutions. www.sportsbettingoperator.com

@OperatorSports

FEATURE: SIGMA ROME

BEYOND THE NUMBERS Eman Pulis on why the real measure of a successful SiGMA show is the quality of connections made – not simply the number of people through the doors. By Peter White

SiGMA founder Eman Pulis tells Sports Betting Operator why meaningful conversations, international connections and partnerships are the metrics that matter when measuring the true value of an event. Eman, SiGMA has grown from a Malta-based iGaming exhibition into a genuinely global events business. When you look at the 2026 calendar, with events across Europe, Asia, Africa and the Americas, does it still feel like the same company you founded, and what has changed most fundamentally? At its core, absolutely. The mission Volume 8: Issue 024

has always been about bringing people together, creating the right environment for conversations to happen and giving the industry a place where business can actually get done. That has not changed. What has changed is the scale and the ambition. When we started, the idea of taking SiGMA around the world was already there, but you could not have predicted how quickly the industry would globalise. Today, we have a presence across multiple continents, and we are seeing increasingly strong connections between markets that, a few years ago, were operating much more independently. 43

FEATURE: SIGMA ROME Mexico is a good example. We saw a market with enormous potential, a sophisticated land-based sector, a growing digital conversation and strong links with the wider Latin American market. Africa presents a different opportunity. It is incredibly diverse, with significant potential across multiple jurisdictions. For us, the question is always whether SiGMA can add value. If we believe we can connect people who need to meet, bring international expertise into the conversation and give local businesses a global platform, then we start looking seriously at the market. The biggest change is probably that SiGMA is no longer simply an exhibition brand. It has become an ecosystem of events, media, networking, awards, startups, philanthropy and business intelligence. The challenge now is to keep that original entrepreneurial spirit while operating at a much larger scale. You have significantly expanded SiGMA’s geographical footprint.

Rome is a very different proposition from Malta. What makes Fiera Roma and the Italian capital the right home for SiGMA World, and what role do you see Rome playing in connecting the European market with Latin America, Africa, Asia and North America? Rome gives us both scale and connectivity. Fiera Roma gives us the physical space to build the event we have in

What is driving the decision to enter markets such as Africa and Mexico, and how do you determine whether a particular market is ready for a SiGMA event? We look for markets with genuine momentum. That does not necessarily mean the biggest market on paper. We look at regulation, investment, local talent, operator activity, supplier interest and, importantly, whether there is a community that wants to come together. You also have to listen to the market. We do not believe in simply taking a European event and dropping it somewhere else. Every region has its own regulatory environment, business culture and priorities.

mind. This year’s edition covers around 100,000 square metres, with additional conference stages, networking areas and experiences built around the main exhibition. But the venue is only part of the equation. Rome is one of the world’s great international cities. It has the infrastructure, hospitality, and global profile to support an event of this size. Geographically and culturally, Italy also offers an excellent bridge into Europe while being extremely well connected to Latin America, Africa, and other international markets. We want Rome to become a meeting point for different parts of the global industry rather than simply another European trade show.

sportsbettingoperator.com

FEATURE: SIGMA ROME For readers of Sports Betting Operator who are considering attending in November, what would you say are the three things they absolutely should not miss at SiGMA World 2026? First, the conference programme. There are five stages and more than 550 speakers, so there will be conversations covering everything from regulation and sports betting to AI, payments and emerging technology. Second, the networking. I would strongly encourage operators not to spend four days simply walking the exhibition floor. Use the meetings, lounges, dinners, tournaments and the SiGMA Match platform to arrange conversations before you arrive. Third, the Startup Pitch and awards. These are two sides of the same coin. The Startup Pitch gives you a look at what is coming next, while the awards give you a chance to see which companies and individuals are setting the benchmark today. SiGMA is currently promoting more than 30,000 delegates, 1,200plus sponsors and exhibitors, five conference stages and around 550 speakers for Rome. At that scale, how do you make sure the event still feels personal and that the right people actually meet each other? Scale without relevance is not useful. You can put 30,000 people into a venue, but if the right people do not meet, then you have failed. That is why networking is built into the architecture of SiGMA rather than treated as something that happens around the exhibition. We have VIP lounges, dedicated networking areas, dinners, sporting events, the SiGMA Match platform and a programme designed to move people between business and social Volume 8: Issue 024

ABOVE: SiGMA founder Eman Pulis

environments. The objective is to create multiple points of contact. Ultimately, some of the most valuable conversations at SiGMA will never happen on a conference stage. They happen over dinner, at a coffee meeting or after a panel when two people realise they should be speaking to each other. Sports betting is becoming increasingly intertwined with AI, data, payments, cybersecurity and emerging technologies. Which technologies do you think will have the greatest impact on sportsbook operators over the next three to five years? AI will clearly be one of them, but I would caution against viewing it as a standalone product. The real impact will come from how AI connects with data, personalisation, payments, fraud prevention, customer service and risk management. 45

FEATURE: SIGMA ROME under them. There needs to be an ongoing conversation. That does not mean regulators and operators have to agree on everything. In fact, disagreement can be productive if the discussion is informed and constructive. What matters is that both sides understand the practical consequences of regulation. We have always sought to provide regulators with a genuine platform at SiGMA. At World, that becomes even more important because you have jurisdictions at very different stages of regulatory development represented in the same place. Operators will be able to understand customers more effectively and create much more personalised experiences, but that also brings significant responsibility. Payments will continue to be critical, particularly as consumers expect faster, simpler and more secure transactions. Cybersecurity and fraud prevention will become increasingly important as the value of digital ecosystems grows. We will see much more discussion

The sports betting sector is also facing questions around responsible gambling, player protection and integrity in sport. How do you see SiGMA’s role evolving in helping the industry address those issues while still encouraging innovation? The industry cannot separate innovation from responsibility. If we are talking about the future of regulated gaming, then responsible gambling, integrity, transparency and player protection have to be part

around the interface itself. The way people discover, interact with and consume betting products is changing, and operators will need to think beyond the traditional sportsbook interface.

of that future. They cannot be an afterthought. SiGMA’s role is to facilitate the conversation and provide a platform for serious organisations working in these areas. We can bring operators, regulators, technology companies and policymakers together and create an environment where practical solutions can be discussed. Our positioning around advancing regulated gaming reflects that. The goal is not innovation at any cost. Innovation within a framework creates a sustainable industry.

Regulation remains one of the biggest issues for betting operators worldwide. How important is it for SiGMA to bring regulators, governments and operators together in the same room, and do you think the industry is becoming better at having that conversation? It is fundamental. You cannot build a sustainable, regulated industry if the people writing the rules speak separately from the people operating 46

The Startup Pitch has become a major part of the SiGMA proposition. What are you seeing from the latest sportsbettingoperator.com

FEATURE: SIGMA ROME generation of sports betting and gaming startups, and what separates the companies that attract serious industry attention from those that don’t? The best startups are not necessarily the ones with the most complicated technology. They are the ones solving a real problem. We are seeing strong ideas around AI, payments, fraud, compliance, data, player engagement and operational efficiency. But the companies that stand out tend to have three things in common: a clear problem, a credible solution and a realistic route to market. You can have fantastic technology, but if you cannot explain who needs it and why they will pay for it, you will struggle. The Pitch is valuable because it puts founders in front of people who can challenge those assumptions. Sometimes that results in investment. Sometimes it results in a partnership. Sometimes the most valuable outcome is simply the feedback that helps a founder rethink the business. You have also built SiGMA around networking. In an industry where people can communicate instantly online, why do you believe face-toface exhibitions remain so important, perhaps more important than ever? Because trust is still human, you can have hundreds of conversations on LinkedIn, send thousands of emails and have endless video calls. Still, there is something different about sitting across a table from someone. Major partnerships often begin with an informal conversation. You understand someone’s personality, ambition and credibility in a way that is difficult to replicate digitally. Technology has not made physical events less relevant. In many ways, it has made the valuable moments more Volume 8: Issue 024

obvious. People are overwhelmed by digital communication. When they travel to meet in person, the conversation has more intent. The SiGMA Foundation has become an increasingly visible part of the organisation. You have previously said that you now measure wealth by the number of lives impacted rather than by financial success alone. Has your thinking about business and philanthropy changed as SiGMA has grown? It has changed significantly. When you are building a company, particularly in the early years, you naturally focus on growth, revenue and survival. As the business grows, you have a greater responsibility because you have a larger platform and more resources. For me, success is increasingly about impact. How many people can we help? What communities can we support? What opportunities can we create for people who may not otherwise have them? That is why the Foundation is so important. It enables the SiGMA ecosystem’s success to have an impact beyond the industry itself. The charity auctions at SiGMA events have raised money for projects including healthcare and education. What can you tell us about the charitable work that the Foundation is supporting now, and how important are the auctions in generating both funds and awareness? The auctions have become one of the most visible ways our industry can give back. They bring together operators, suppliers, investors and other members of the community around a shared objective. The money raised supports projects in areas including education, healthcare, disaster relief and community development. 47

FEATURE: SIGMA ROME I like the simplicity of that model. You buy your ticket to attend SiGMA, and your participation also has a small positive impact elsewhere in the world. As the number of people attending our events grows, those small contributions become meaningful. It is a good example of how the scale of the business can be used for something beyond commercial growth.

The Foundation’s auctions, partnerships and community programmes raised more than €400,000 in 2025, while its charitable auctions and activities between 2023 and 2024 raised more than €935,000. I argue that awareness is almost as important as the money. When someone bids on a piece of art or another item at an auction, they are not simply donating. They are becoming part of the story and taking that message back into their own network. SiGMA is now giving delegates the opportunity to support a charitable cause through their event tickets as well, with part of the ticket price being donated to a cause of their choice. Do you see this as becoming an increasingly important part of the SiGMA experience? Yes, because it makes giving much more accessible. Not everyone can bid thousands of euros at a charity auction, but almost everyone attending an event can contribute in some way. We currently donate 2% of every ticket purchase to a charitable cause selected by the ticket holder, with no additional fee for the delegate. 48

Finally, Eman, when SiGMA World closes its doors in Rome after four days in November, what would make you personally say: “That was a success”? Is it the size of the show, the deals done, the people in the room, the global reach, or something much harder to measure? It would be all of those things, but none of them individually. Of course, I want the show to be commercially successful. I want exhibitors to generate leads, operators to find partners, startups to secure opportunities and delegates to leave feeling that the trip was worthwhile. But personally, I will judge it by the conversations I see happening. If I walk through Fiera Roma and see people from different markets sitting together, exchanging ideas, challenging each other and making plans, that tells me we have achieved what we set out to do. SiGMA started with a very simple idea: bring the industry together. The fact that we can now do that on a global scale is something I am incredibly proud of. But the objective remains the same. Create the room, bring the right people into it, and let the industry build what comes next. That, for me, is success. sportsbettingoperator.com

FEATURE: LONDON CASINO & GAMING SHOW

EXPANDING THE INDUSTRY MIX Nick Harding outlines plans to bring a broader cross-section of the gaming, betting and leisure industries together. By Peter White

he London Gaming Show is continuing to broaden its industry proposition

as it develops within the EAG360 platform. Nick Harding discusses the show’s evolution and its plans to build greater representation across betting, gaming and the wider leisure industry. Nick, since our last conversation, the event has been rebranded as the London Gaming Show and now sits within the new EAG360 structure. What does the new identity mean in practical terms for the London Gaming Show and, importantly, for sports betting operators and suppliers? We received feedback from visitors which made it clear that the perception was that the London Casino and Gaming show was only Volume 8: Issue 024

aimed at UK and European Casino operators. It was an obvious mistake on our part so we have adjusted the name, reworked the graphics and our sales team are seeking exhibitors who are focussed on the Sports Betting sector. I feel that both Sports Betting and Casino gaming sit comfortably side by side (just look at the Superb Paddy Power operation within the Hippodrome Casino complex in the West End) and I would like to build the sports betting exhibitors and visitors representation at the show You have described EAG360 as being “fit for the future”. What did your research with exhibitors and stakeholders tell you about how the gambling element of the show needed to develop. There is a clear distinction between 49

FEATURE: LONDON CASINO & GAMING SHOW

‘Amusements’, ‘Competitive Socialising’ and Gaming although I would be the first to acknowledge that all three do often coexist comfortably within larger leisure operations. The new branding of the show (EAG360, ‘part of the smile economy’ is aimed at acknowledging that fact. The London Gaming Show has traditionally had a strong casino and land-based gaming identity. Why is now the right time to put sports betting much more firmly at the heart of the event? This is our third year of operation with our three core ‘pillars’ of interest. You evolve or you die, and I’m not quite ready to die. There has historically been relatively little exposure for sports betting at this particular event. What do you think the London Gaming Show can offer the sports betting community that existing betting conferences and exhibitions do not? I realise that this is a pain, but it would be foolish to overcommit while we don’t have a signed up partner for this conference. Perhaps we could have a chat? Responsible gambling is becoming increasingly technology-driven. Will the 2027 conference examine how 50

operators can use technology and data to improve player protection while still delivering a compelling customer experience? Clearly this is very much on everyone’s agenda, and to be fair ( if you listen to some politicians and the Anti-Gambling lobbyists) you wouldn’t believe that it was the industry itself, through the good offices of John Kelly OBE who first launched the Gambling Industry Charitable Trust (GICT) in 2003, more than twenty years ago. I do get very irritated when I hear some of the new entrants to the paid for lobby groups talking as if the industry has completely ignored problem gambling until last week. In fact, and for the record, in 1997 I was the first person to offer commercial support to Gamcare when they were a one man and two part time staff in a tiny office in Westminster. So, yes of course many of our London Gaming Show exhibitors will be demonstrating the most UpToDate, and world beating technology designed to help the tiny proportion of players who do develop Problem Gambling traits. Your emphasis has been on developing a land-based sports betting representation at the show. What opportunities do you see for bookmakers and betting suppliers in the broader land-based entertainment and gaming environment? Since the 1600s horse racing has been a key component of ‘leisure’ in the UK. It is a fantastic industry which supports tens of thousands of employees and pays vast sums to the treasury. Like any successful industry it is constantly evolving it will continue to work with and within the UK leisure industry providing a multilayered gambling business in many locations, both on a stand alone basis but also as a key component of larger leisure offers. sportsbettingoperator.com

FEATURE: LONDON CASINO & GAMING SHOW You previously identified taxation, inflation and unemployment as major challenges. Has anything changed in your assessment of the pressures facing the UK gambling and betting industry as we approach 2027? I listened again today to Gordon Brown (our former Chancellor) suggesting that retail gambling can be taxed so heavily that it will be able to prop up parts of the NHS. Mr Brown has clearly never seen a commercial P&L and it sort of feels that some of these people will not be happy until the entire UK Gambling industry is shut down. I am no longer involved on an operational basis in this industry but some of our CEOs must at times feel like Sisyphus, rolling a huge boulder up the hill each day. The pressure just seems to be mounting and the industry is apparently treated as something ‘dodgy’ to coin a phrase, not something that is licensed, pays huge taxes, employees vast numbers of people and provides huge enjoyment and fun to the general public. For a sports betting operator, why should the wider EAG360 environment matter? Are there commercial opportunities outside the traditional gambling audience? There have been no UK exhibitions aimed specifically at the Sports Betting Operator. There is now, and it will be at Excel in January 2027. What can sports betting operators learn from the casino and amusement sectors represented elsewhere within EAG360, particularly around customer experience, entertainment and creating reasons for people to visit physical venues? I feel that there is so much cross over, more today than ever before, particularly in technology and CRM and of course the obvious link of B3 Volume 8: Issue 024

ABOVE: Nick Harding, London Gaming Show Chairman

gaming machines, which are always well represented at the London Gaming Show. You mentioned AI in our previous interview as one of the technologies likely to have an increasing impact. Where specifically do you expect AI to have the greatest impact on landbased sports betting over the next two or three years? I am sure that AI is close to the top of most operators agendas, particular where they still have a reasonably labour intensive model. Areas that may well benefit could be AI driven SSBTs that become more conversational with the player, AI odds and trading with machine learning continuously assimilating live data, maybe a personalised betting shop with customers presenting themselves at an SSBT (or through their phone account) and AI then presenting them with markets that it has worked out will appeal to them and lastly and probably the most important regulatory application could be ‘Safer Gambling’ with AI spotting unusual betting patterns and facilitating interventions. 51

Outsource Digital Media Powering connections We design and deliver effective digital mareting solutions to the gaming industry

Contact newbusiness@outsourcedigitalmedia.com or call +44 (0) 1892 740869 www.outsourcedigitalmedia.com

FEATURE: LONDON CASINO & GAMING SHOW How important will omnichannel technology be? Do you see the distinction between online and retail sports betting becoming increasingly irrelevant from a customer perspective? I don’t think you will ever replicate the real buzz and excitement provided by live betting in any venue, I think customers will always see betting on a phone, or a pc, or wherever as a poor substitute for the real thing. With the UK gambling regulatory environment continuing to evolve, do you see the London Gaming Show becoming an important forum for the industry to debate the practical consequences of regulatory change? Yes, I do and that is why I am very keen to put together and event, alongside the London Gaming Show, that will pull operators and regulators together to discuss the evolving environment. One of the strongest messages from your 2026 feedback was that exhibitors valued the quality of business conversations. As you bring sports betting into the show, how will you protect that quality rather than simply increasing visitor numbers? From the outset we were clear that there needed to be some form of informal demarcation between the three exhibition areas and research two years ago made it clear that gaming operators valued a quieter area more akin to a casino floor where business conversations could take place without the need to complete with the latest pinball, or ‘dance stage’ or sound system. We have achieved that goal twice and will be aiming to achieve it again in January. What would constitute success for the sports betting element of the 2027 show? Is it exhibitor numbers, Volume 8: Issue 024

operator attendance, conference participation, deals done, or something less easily measured? All the above-mentioned metrics obviously, but as with any new element to the exhibition we are not looking to shoot out the lights on day one but if we feel that we have gained some traction, with positive feedback from exhibitors and visitors then that will be enough to encourage us to continue to drive forwards for future shows. Small acorns, etc etc. The UK Dealer Championships are also evolving for 2027. How important are live experiences such as this to the London Gaming Show’s proposition, and could there eventually be equivalent initiatives aimed specifically at the sports betting community? The Dealer Championships have been hugely popular and we feel honoured to provide this for the Casino industry. In fact in January we will be running the competition over two days instead of one and we are immensely grateful to Mo Salih at the Hippodrome for facilitating this and also congratulate him on his recent promotion at the Hippodrome. 53

FEATURE: B90

SCALING SMARTER Inside B90’s AI-Driven Growth Engine with CEO Ronny Breivik and CFO Marcel Noordeloos with Inside B90’s AI-Driven Growth Engine. By Peter White

90 Holdings plc is a performance marketing and MarTech company focused on customer acquisition for the global

ahead of management expectations, driven by strong performance in its core iGaming business and continued optimisation of its proprietary AI-driven marketing platform. The

iGaming industry. It operates a capital-light, AI-driven platform that uses automation, machine learning and data analytics to optimise digital marketing campaigns on behalf of gaming operators and B2B partners. Rather than operating betting or gaming platforms itself, the business generates revenue by helping clients acquire customers more efficiently. In 2025, B90 delivered a clear stepchange in performance, more than doubling revenue and returning to profitability as its AI-driven marketing platform scaled. That progress carried into 2026. In its August trading update, B90 said first-half revenue was expected to be

Group is also continuing to invest in marketing and technology, particularly AI automation and machine learning, to support the next stage of scale. We sat down with CEO Ronny Breivik and CFO Marcel Noordeloos to unpack what has driven this.

Ronny, “defining year” is strong language. What actually changed? Ronny: What changed is that we moved from proving the model to operating it at scale. We have said consistently that we have built a scalable platform. Now we can finally say more about the capabilities of our platform. In short: we built an AI-driven performance marketing platform, and I would dare sportsbettingoperator.com

FEATURE: B90 say that we have proved its success. Revenue has more than doubled, EBITDA has grown meaningfully, and we’ve returned to profitability. Encouragingly, that momentum has continued, supported by strong performance from our core iGaming business and further optimisation of the platform. This was profitable growth delivered through automation, machine learning, and disciplined capital allocation. The platform is now embedded across our daily operations, actively optimising campaigns, improving how we deploy marketing capital and allowing us to launch agency-quality websites at a fraction of the cost. That is the inflection point that has been achieved. When you say “AI-driven platform,” what does that mean in practical terms? Ronny: AI at B90 is embedded in live production systems. It supports decision-making around campaign optimisation, traffic allocation, conversion analysis, and partner performance. In practice, the system learns from data, adjusting bids, reallocating spend and improving targeting efficiency without manual intervention at every step. Historically, growing performance marketing required proportional increases in headcount. Our model decisively decouples that relationship. We can expand activity without increasing overheads at the same rate. That is what creates operational leverage. Marcel, how visible is that in the financials? Marcel: Very visible, particularly in margins and cash generation. In 2025, revenue more than doubled from €3.5 million to €7.2 million, EBITDA rose to €1.1 million and we returned to profitability. Volume 8: Issue 024

ABOVE: Ronny Breivik, CEO, B90

That positive trajectory continued into the first half of 2026, with revenue increasing 38% to €3.3 million and adjusted EBITDA remaining positive at €0.31 million. Importantly, we generated €0.50 million of cash from operations, taking our cash position to €1.47 million at the half year. That gives us greater flexibility to invest in the next stage of growth. We are continuing to invest in marketing and technology, particularly AI and automation, alongside our people and operational capacity. The underlying financial position is strong, and we remain very confident in our outlook. Ronny, the company describes itself as both a performance marketing and MarTech business. Where does the balance sit today? Ronny: This is not a pivot away from iGaming. The iGaming business continues to provide a profitable and highly cash-generative foundation, while also giving us an environment in which to develop and refine the technology. 55

TIME TO SPORT Sports Marketing & Betting Calendar More info: boomerang-partners.com/sport-calendar-2026

FEATURE: B90 The opportunity beyond iGaming is also starting to develop. We are progressing a number of pilot programmes to evaluate the application of the platform across adjacent sectors. They remain early stage and aren’t expected to contribute materially to revenue this year, but they are an important step in demonstrating the platform’s broader commercial potential. Ronny, iGaming is facing rising acquisition costs and tighter regulation. How does B90 fit into that environment? Ronny: Those pressures actually reinforce demand for what we do. Operators are increasingly focused on efficiency. Customer acquisition is becoming more expensive and more complex, particularly in regulated markets. That increases the value of specialist performance marketing partners who can deliver measurable returns. Our position sits between data, technology, and execution. We help operators acquire customers more efficiently using AI-driven optimisation and scalable marketing systems. So rather than being negatively impacted, we are aligned with the direction of travel in the industry. Looking ahead, what will drive the next stage of growth? Ronny: Three things stand out. First is continued improvement in AI and automation – or infrastructure rollout, if you like – which in turn enhances operational efficiency and revenue potential. Second is expansion of our B2B partner base as operators increasingly seek performance-driven acquisition solutions. Third is the potential to apply the technology across adjacent sectors. Volume 8: Issue 024

ABOVE: Marcel Noordeloos, CFO, B90

We are testing that through earlystage pilot programmes. They are not expected to contribute materially to revenue this year, but they can help us evaluate the platform’s broader commercial potential. But it has to be said, the underlying driver remains the same: disciplined execution of a scalable, technology-led platform. Final question: what would you highlight for an investor? Marcel: Probably the sustainability of the financial model. Some still view performance marketing as purely cyclical or volume-driven. Our model is increasingly structured, data-led and efficiency-focused. Ronny: And I would add the depth of the technology. AI and automation are deeply embedded into how we operate every day. That is what enables growth capacity without proportional cost growth. And we are still early in that journey. B90 has moved decisively beyond turnaround mode. Its core iGaming business provides a profitable and highly cash-generative foundation, while continued investment in AI, automation and machine learning is designed to support further scale and broader MarTech application. The next phase is no longer about proving the model; it is about extending it. 57

FEATURE: BOOMERANG PARTNERS

FROM DEALMAKER TO STRATEGIC PARTNER Boomerang Partners on the affiliate manager’s changing role

ffiliate management in iGaming was traditionally closely tied to sales: finding

partners, negotiating deals, and bringing in traffic. These responsibilities remain part of the job, but they no longer cover its full scope. Boomerang Partners, an affiliate gambling & betting marketing agency sees the role becoming more focused on what happens after the initial deal. Traffic quality, the performance of individual partnerships, and their potential to grow over the long term all influence how those relationships are managed. This puts more emphasis on understanding the partner and its audience, rather than focusing on traffic volume alone. Closing a deal may start the relationship, but developing it requires consistent work on both sides. 58

Helping affiliates grow The affiliate manager’s work does not end once a partner starts delivering traffic. Part of the role is understanding how that traffic performs and where the partner may have room to improve. Conversion insights can help identify weak points, while knowledge of individual markets can inform decisions around content and promotion. Affiliate managers can also help partners navigate market requirements that affect how offers are presented. These insights give affiliates more context for their own decisions, rather than simply telling them what to change. Helping affiliates understand their performance is part of building a stronger working relationship. It gives partners useful context while leaving decisions about their business in their hands. sportsbettingoperator.com

FEATURE: BOOMERANG PARTNERS Speaking the language of data Numbers are becoming a bigger part of the conversations affiliate managers have with partners. Traffic volume remains important, but metrics such as LTV, conversion rates, traffic quality, and fraud-related metrics provide more context when assessing performance. An affiliate manager does not need to be a data analyst, but understanding these metrics matters. It helps managers discuss results in concrete terms, identify issues that need attention, and explain what a partner contributes. Commercial discussions become more specific when both sides can look beyond traffic volumes and talk about what that traffic is actually delivering.

Compliance is part of the relationship Affiliate managers need to understand the compliance requirements that affect their partners and communicate them clearly. This includes requirements around promotional content and disclaimers, as well as practices that may need to be flagged for further review. Compliance is also part of regular communication with the affiliate. Managers can help partners understand what is expected of them and raise potential issues when they appear. Clear expectations are important for trust. Affiliates need to know the rules they are expected to follow and where questions or potential issues should be raised.

What technology changes for affiliate managers AI and automation can already support routine parts of affiliate management, including monitoring and basic optimisation. Volume 8: Issue 024

Understanding what a particular affiliate needs, negotiating terms, dealing with problems, and deciding how a partnership should develop still depend heavily on human judgement. Technology can support the work around a partnership, but the relationship itself is built between people. Looking three to five years ahead, Boomerang Partners expects technology to play a bigger part in the affiliate manager’s work rather than replace the role. Managers will still need to understand the numbers, while spending more of their time on strategy and partner relationships.

The Boomerang Partners approach At Boomerang Partners, affiliate managers work with a long-term view of the partnership. Understanding the affiliate’s business, audience, and results helps managers have more informed discussions about performance and the relationship. For affiliates, this means having a manager who can discuss not only commercial terms, but also performance and how the partnership can develop over time. “The job is becoming less transactional. An affiliate manager may start a relationship by discussing traffic and commercial terms, but keeping that relationship productive requires much more. Managers need to understand who they are working with, ask the right questions, and know when the numbers point to something worth discussing. Technology will change the day-to-day work, but relationships will remain a fundamental part of the profession,” said Martin Černý, CEO at Boomerang Partners. Sales and acquisition remain part of affiliate management. The difference is that more of the job now happens after the deal, as managers work with partners over time and take a closer interest in how those partnerships perform. 59

5 design services in one creative hub We create standout designs that elevate your digital and print marketing needs

BrandDesign

BrochureDesign

DigitalDesign

MagazineDesign

EventDesign

Once your project is ready, we’ll take care of all your printing needs, ensuring the best value for your budget while saving you the hassle of dealing with printers directly.

de5ign T +44 (0) 7476 578 894 E info@de5ign.co.uk W www.de5ign.co.uk

FEATURE: IBIA

FROM ALERTS TO ACTION IBIA’s Q2 2026 Integrity Report shows why integrity needs scale as it points to a complex global betting integrity environment – and underlines how competitive regulation, onshore channelisation and athlete education can turn alerts into action

A quarter defined by detection IBIA’s Q2 2026 Integrity Report captures the scale and complexity of modern sports betting integrity. During the quarter, IBIA reported 76 suspicious betting alerts to the relevant authorities across nine sports, involving events linked to 31 countries.

on football reported during Q2. Esports followed with 16 alerts, with basketball providing 10 alerts, tennis nine, darts five, greyhounds four, cricket and table tennis three each, and volleyball one. Geographically, that involved suspicious betting alerts reported on sporting events played in all six continents, led by

The number is important, but the wider message is broader: integrity systems must be able to detect, assess and escalate activity that can move across sports, markets and borders at speed. The Q2 report underlines IBIA’s wider global footprint that is central to its monitoring operations. The association’s membership represents more than 90 companies and over 200 betting brands around the world. It monitors more than 1.5 million sports events each year across 80plus sports and analyses customer activity across more than US$300bn in global betting turnover annually. That global monitoring activity saw 25 suspicious betting alerts

Europe (24), South America (17) and Africa (11). That spread matters. Betting integrity is no longer a challenge primarily concentrated on one sport or one region. Alerts in Q2 were connected to major global sports, fast-growing digital markets and more localised competitions. For integrity bodies, regulators and operators, the practical implication is clear: monitoring systems need both scale and specificity. They must be broad enough to cover hundreds of thousands of events, but detailed enough to understand unusual individual customer behaviour, market movement and sporting context.

Volume 8: Issue 024

FEATURE: IBIA A global map of integrity risk The geographical distribution of Q2 alerts shows why international cooperation remains central to effective integrity work. While data from a single quarter must be treated with due caution, it adds to a wider set of data that helps to generate both regional and global trends. Analysing that data. For example, adding the six alerts recorded in Africa during Q1 2026 four in football and two in tennis - to the Q2 figures brings the first-half total for that region to 17, showing a broadly consistent integrity position to 2025.

ABOVE: Source: IBIA Q2 2026 Integrity Report

Canada focus: channelisation as an integrity tool

Alert data is, however, often misunderstood. More alerts do not automatically mean more corruption, and fewer alerts do not necessarily mean a safer market. Monitoring bodies also differ in their data, event coverage and reporting thresholds, so raw totals are not a precise like-forlike measure of monitoring capacity.

The Q2 report’s Canada focus provides a clear example of how regulation can strengthen integrity by moving betting activity into visible, monitored channels. Ontario’s online sports betting channelisation rose sharply after the launch of its open, competitive iGaming market, moving from 5% of online sports betting gross gambling revenue in 2022 to 85% in 2023 and stabilising above 90% thereafter. The contrast with the rest of Canada

Alerts are therefore operational signals, not a score of detection capability. The objective is to identify unusual betting promptly, test it against operator intelligence and sporting context, and escalate credible suspicions of match-fixing, event manipulation or misuse of inside information. This is where regulated operators play a critical role. Their customer account data, internal risk controls and market-level knowledge can make the difference between a weak signal and an actionable intelligence report. For IBIA, the strength of its model lies in bringing that operator intelligence together through a global monitoring and alerts platform.

is striking. While Ontario moved rapidly onshore, the rest of Canada has remained largely unchanged at low double-digit channelisation levels. Alberta is forecast to follow a similar trajectory to Ontario as it moves toward an open, competitive market model. The policy point is simple: competitive regulation can give consumers attractive legal options, while bringing betting activity into environments where operators can identify customers, monitor behaviour and report suspicious activity. Positive channelisation increases oversight and is aligned with Ontario’s world-leading betting integrity framework. Operators must work

Why alerts should be read carefully

sportsbettingoperator.com

FEATURE: IBIA

with a registered Independent Integrity Monitor, while commercially conflicted parties, including B2B sportsbooks, are precluded from also acting as the monitor. This combination improves visibility of suspicious activity and strengthens the basis for detection and investigation.

ABOVE: Q2 alerts by geographical location. Source: IBIA Q2 2026 Integrity Report

Education turns systems into culture The Q2 report also highlights IBIA’s athlete education work in Canada, showing that integrity is not only built through monitoring technology or regulatory rules. It is also built by empowering those closest to the field of play. IBIA and its members bet365, Betway and FanDuel have committed CA$300,000 to the programme. It is based on IBIA’s 3Rs approach: Rules, Responsibility and Reporting.

Volume 8: Issue 024

The message is practical: know the rules around betting and your sport, take responsibility for performing at your best, and report any attempted corruption. The programme has educated around 200 Canadian Premier League players with PFA Canada for each of the last three years. This year the programme has also reached all Canadian Football League athletes through an initiative with Genius Sports. IBIA Education Ambassador Jean-François Reymond uses real-world examples to explain betting risks, integrity obligations and reporting routes.

BELOW: An athlete integrity education session in Canada. Image: IBIA Q2 2026 Integrity Report

Scale, cooperation and the next phase IBIA’s scale matters because betting markets are increasingly interconnected. Suspicious activity can involve multiple operators, payment channels and jurisdictions. A strong integrity response therefore requires more than isolated reporting. It requires a network capable of connecting data, expertise and decision-makers quickly. For regulators, the key lesson from Q2 is that 63

FEATURE: IBIA

integrity frameworks should be built into market design from the outset. Formal reporting obligations, recognised monitoring arrangements, clear escalation routes and operator participation all help ensure that betting activity is visible and that suspicious conduct can be addressed before it causes lasting harm.

ABOVE: Source: IBIA Q2 2026 Integrity Report. Data: H2 Gambling Capital

IBIA’s Q2 2026 report therefore tells a broader story than quarterly alert numbers alone. It shows an integrity environment that is becoming ever more global, more data-driven and more dependent on cooperation. The task now is to ensure that regulation, operator monitoring and athlete education scale with the market they are designed to protect.

sportsbettingoperator.com

19–20 January 2027 Fira Barcelona Gran Via Halls 8.0 & 8.1, North Access

Scan here to Register Now barcelona.igbaffiliate.com #iGBA27

Publicise your Brands with our Industry Specific Media

casinolifemagazine.com

SPORTS BETTING OPERATOR sportsbettingoperator.com

newbusiness@outsourcedigitalmedia.com +44 (0) 1892 740869 www.outsourcedigitalmedia.com