
31 minute read
Sports Betting
from SBC Leaders Issue 20
by SBC Global
ON THE MOVE: BETTING AND GAMING’S MOVERS AND SHAKERS
WITH COMINGS AND GOINGS commonplace across the betting and gaming industry, we take a look at some of the movers and shakers over the last few months.
Parimatch Tech
Parimatch Tech carried out a restructure of its senior leadership, which has seen Maksym Liashko become the company's CEO.
Roman Syrotian will be focusing 100% of his time on the Supervisory Board activities and Anna Motruk, former Chief Finance Officer, will become Deputy CEO. Evgen Belousov, ex-Chief Revenue Officer at Parimatch Tech, has also been appointed as Deputy CEO.
Maksym Liashko, CEO at Parimatch Tech, said: “In times of war, the structure and development procedures within the company had to be reviewed and adapted to the new reality. With Roman refocusing all his attention and skills toward the Supervisory Board activities, I am certain that Parimatch Tech will withstand these difficult times and continue to be a successful global business.”
Anna Motruk, Deputy CEO at Parimatch Tech, added: “The war showed us that going beyond our formal responsibilities and being open-minded is key to ensuring the company’s success and stability. That’s why building cross-functional teams within the company will be an important element of our business going forward. Flexibility and resourcefulness are crucial elements of overcoming any challenges, and I am certain that the future holds a lot more victories.”
San Manuel Band of Mission Indians
Daniel D’Arrigo was named the Chief Financial Officer for The San Manuel Band of Mission Indians.
Having previously served as Executive Vice President, Chief Financial Officer and Treasurer of MGM Resorts International in Las Vegas, D’Arrigo oversaw domestic and international financial functions, including corporate finance, treasury, shared services, internal audit, and investor relations
Laurens Vosloo, Chief Executive Officer for the San Manuel Band of Mission Indians, said: “As Chief Financial Officer, Dan will play a critical role in leading the tribe’s fiscal strategy, growth and development.
“One of Dan’s greatest strengths is his credibility with the investment community and capital markets. We are very pleased that Dan is joining our team at a time when the tribe

is experiencing tremendous growth and has such great potential for new opportunities.”
Entain
Entain hired Brian Lancey to serve as Chief Marketing Officer of its Unikrn esports brand that will be re-launched later this year.
An expert in enterprise marketing and brand development for new ventures, Lancey joins Unikrn’s leadership team from Mastercard, where he previously served as Global VP of Sponsorships and Consumer Marketing.
Lancey commented: “I am excited to share that I joined Entain’s esport team, Unikrn, as the Chief Marketing Officer.
“Entain, a global leader in betting, gaming and interactive entertainment, is paving the way for the future of the industry. I look forward to building the esports business with the incredible team and inspiring leadership.”
PA Betting Services
Eugene Delaney became the Managing Director of PA Betting Services after leaving Spotlight Sports Group in March.
Delaney joined Spotlight Sports Group back in 2014 where he oversaw the Racing post’s B2B division.
“After a really enjoyable seven years at Spotlight Sports Group, I have taken over the reins at PA Betting Services,” Delaney wrote on LinkedIn.
“We’re in the process of expanding the team as we plan to build and grow the fantastic business that has served bookmakers for over 40 years (hat tip to Jim Donnelley) along with our key partners of Racecourse Media Group Arena Racing Company, PMU, XB Net Global Wagering Solutions and Sportradar.” •
TECHNAMIN: ADDING A SPORTSBOOK PLATFORM JUST ‘MAKES SENSE’ FOR CASINO OPERATORS
CASINO OPERATORS can extend the reach of their content to new audiences by adding a sportsbook platform to their portfolio according to Technamin CEO Suren Khatchatryan
BY ERIN GALLAGHER
Speaking to SBC Leaders, Khatchatryan began by discussing some of the standout features available on the Technamin platform, and how its sportsbook can be fully customised “to each partner’s liking”.
He said: “Technamin always strives to create products that cater to as many needs as possible, and our sportsbook is no different. We offer a variety of features, such as flexible limit systems, odds, professional client and risk management, 24/7 customer support and a large number of bonus options.
“Our sportsbook covers more than 80 sports, including popular esports. Despite the fact that we cover various local and global events, we also offer a wide range of markets which gives an exceptional opportunity to our customers in making decisions that best suit their needs. Moreover, they are able to follow the development of their favourite matches through our streaming.”
By taking an individual approach to partnerships, rather than deploying a ‘one-size-fits-all’ solution, the Technamin CEO explained that the range of features on its sportsbook platform means that its clients can create a more interactive experience for players while also ensuring that safer gambling remains a top priority.
Khatchatryan continued: “We approach each of our clients as individuals, making sure to understand their specific needs correctly and not only catering to those needs, but also providing information and consultation along the way. Another feature that is a hit with our clients is the fact that Technamin’s sportsbook can be fully customised to each partner’s liking.
“This includes skinning, design, payment methods and much more. Our main goal is to create the balance between interactive experience and safe betting. Therefore, we offer a vast number of free bets and other bonuses, meanwhile maintaining all the tools for responsible gaming.”
So how can adding a sportsbook platform benefit online casino operators, you might ask. For the CEO, the addition of a sports betting vertical can support operators’ endeavours to expand and diversify their audiences.
He warned, however, that companies must carefully consider the differences


between sports betting audiences and online casino bettors before they make the decision to integrate a sportsbook into their offering.
“Adding a sportsbook to your online casino website is a great way to expand and diversify your audience. Sports betting has been popular since ancient Greece, so it makes sense to leverage it for your business!
“Additionally, let’s not forget about esports that are exclusively built for the online marketplace. They are now as popular as traditional sports, and adding them to your sportsbook means, again, new customers and in turn, more revenue. Igaming is all about offering high levels of variety to customers who would otherwise be limited in terms of their options outside of the online sphere.
“It’s worth noting that unlike casino games, sports betting requires the bettor to engage their personal opinions and analytical skills in order to make predictions on local and global events. This serves to add human intelligence to luck and allows the operator to engage on a different level with a wider demographic of people through its marketing.”
To meet the growing demand for sportsbook products from operators, Technamin provides a consulting service to make sure that it remains in constant communication with its partners. This, Khatchatryan believes, helps the company to better understand the wants and needs of its clients.
He continued: “At Technamin, we do not simply offer our sportsbook as a product. It’s important for us that our sportsbook’s operation is smooth and balanced, which is why we provide consulting and open discussions with all of our partners.
“Through keeping constant communication, we are able to understand their needs and expand our sportsbook accordingly. After all, the operators we work with are reflective of the industry and the demands that come with it, which provides us with feedback as to what features need to be added to our sportsbook.”
“We also try to have a large collection of sports in our sportsbook that bettors can choose from. This also includes esports and fantasy sports, making our sportsbook much more flexible and therefore more attractive to customers.
“We make sure that a bettor’s journey through our sportsbook is a memorable one. The abundant number
of sports, matches and markets meet everyone’s expectations.”
The overall structure of Technamin, Khatchatryan said, also means that its sportsbook platform can be integrated into a casino operator’s offering relatively easily, with “almost zero downtime”.
“Aside from catering to the bettors’ needs, we also cater to operator needs by allowing our sportsbook to be fully customisable to each operator’s specifications,” he explained. “This gives them a unique look and therefore a competitive advantage in the market they operate in.
“These, combined with more than 40,000 matches and more than 35,000 pre-match matches we cover in up to 1,500 markets make our sportsbook attractive to both operators and bettors. We’ve also received positive feedback regarding our flexible bonus system, special live trading tools and 24/7 support.
“Because of how Technamin is structured, our sportsbook can be integrated super fast and with almost zero downtime, which is a feature that operators highly appreciate and prefer in the fast-paced world of igaming where everyone is trying to catch up.”
Talk soon turned towards the upcoming World Cup in Qatar and, unsurprisingly, Technamin predicted that there will be an increase in demand for sports betting products.
But when pressed on what new features we might expect from the firm in the run up to the tournament, Khatchatryan was keeping his cards very close to his chest.
He shared: “I can only imagine the excitement that is brewing for this year’s World Cup, and I expect that the Technamin team will be quite busy when the season arrives. Of course, we are preparing ahead of time and have come up with features to keep the World Cup season as interactive as possible.
“However, in an effort to not spoil any of the surprises, we are keeping our cards close to the chest on this one. Needless to say, we’ve got exciting things planned. So follow Technamin on our social media platforms to get snippets of what we are preparing.”
Rounding off the discussion, the Technamin CEO believes that it may be slightly too soon to make any solid predictions on who we might see lifting the Jules Rimet Trophy.
Khatchatryan concluded: “As there is still a long way to go until we reach the actual World Cup, it’s still pretty early to make any solid predictions about the games. We are, however, already working on providing a welldeveloped platform where bettors can easily access a wide range of markets.
“I can also say that our further predictions will be performed in the form of odds. Nevertheless, it’s great to see the excitement bubbling for an event as long-awaited as the World Cup and we are buckling up for the ride.” •


CRUCIAL COMPLIANCE: NO SILVER BULLET TO GAMBLING HARM, BUT TECH CAN ONLY BE POSITIVE
PAUL FOSTER, CEO OF CRUCIAL COMPLIANCE, assesses the different use of technology in implementing a safer gambling strategy and whether a ‘human touch’ is still needed to identify high-risk players
BY TED ORME-CLAYE
Addressing gambling related harm has become a key focus of the betting and gaming industry as we’re seeing more markets open up, and more mature markets undergo a regulatory review. This is particularly apparent in the UK which is awaiting the findings of the 2005 Gambling Act Review.
Technology has an increasingly important role to play in upholding safer gambling standards, and according to Crucial Compliance CEO Paul Foster, this can bring numerous benefits for betting operators - particularly in areas such as affordability modelling.
For large-scale operators, technology can be essential in identifying the first signs of gambling harm. This, however, must be followed by a human-led interaction.
“I think they both have a place,” he explained. “Within every market, you have to look at what publicly available information you can get and then what you have to do is model that in relation to player protection - use it at the core of an algorithm or as a model for actually spotting it. In that way, it can be used very successfully.
“The issue we've got is that there's an expectation that this is going to be the silver bullet and, unfortunately, there's very few countries in the world where you can get the level of financial data that will give you an accurate affordability figure.”
As with any developments in the betting and gaming industry, particularly with regards to player protection, there are challenges and hurdles.
Notably, Foster maintained that companies cannot completely
disregard the ‘human touch’ when it comes to creating an effective harm minimisation strategy, adding that technology should complement the human decision making process.
He explained: “Technology has to be tuned into your business and once that has happened, it has to flag high risk cases which need human intervention. This is because the only way to effectively look at reducing gambling-related harm is to track it in the form of behavioural change.
“Identification is only the first element. Whilst the system and AI will notice behavioural change, it can't interpret what that information might mean. For example, it cannot comprehend why you might deposit three times as much on a Tuesday night - whereas the human eye might notice a casino win the day before which has just been deposited, or that the player has just reached payday and is making a long-term deposit.
“Safer gambling is always going to need human intervention to review on a case by case basis, especially in relation to high risk and very high risk cases. You initially need technology to identify behavioural change but you cannot rely on technology all the way through.”
Discussions soon moved towards the introduction of more stringent affordability checks. Many across the industry have voiced concerns over whether enhanced checks could “have negative impacts on the customer”.
Although Foster also noted that the same could be said of an overreliance on technology should a “sledgehammer approach” be adopted.
This, he asserted, was the case when affordability checks were first implemented as the industry was and is still learning. He added that this remains an issue with technological development on player protection.
He continued: “The problem with any change in regulation and any new technology is that until we really understand it we will over rely on the initial solution to keep compliant, which impacts operator effectiveness and the customer.
“What we are doing often is implementing change to match regulation with the technology available and without understanding. This means a lot of these changes initially can have negative impacts on the customer rather than positively impacting them until we manage to train the technology.”
It is particularly important for betting firms to review the technology they have available as it is a ‘constant battle to keep it up to date’, especially methods such as Artificial Intelligence (AI).
With AI being the ‘big word’ in player protection, Foster focused heavily on the importance of understanding how technology needs to be interpreted and trained so that it can be used effectively.
“AI models are ultimately only as good as the person writing them,” he advised. “And the major problem facing the gambling industry right now with regards to their adoption is that AI is still in its infancy.
“As we look forward and we increase the level of high quality investment in this area then what we will see is better and better AI intervention. But it is very difficult to take an AI model used elsewhere in the gambling industry or outside and convert it into a player protection tool.”
He added: “All I would say is don't buy something that is shiny or new when what you need is old fashioned advanced algorithms.”
Providing industry stakeholders with a snapshot of what to expect from the review, the UK’s Gambling Minister Chris Philp has repeatedly stated that he would like to see greater use of technology and data as tools for counteracting and minimising gambling-related harm.
Foster agreed that this approach

could not be more important for both operators and the UK Gambling Commission, as he noted that the UK’s approach to data has lagged behind many of its European counterparts - although “nobody has yet got it right”.
“Some are a lot better at getting data. If you look at ARM in Italy, it tracks all the data you need, so you can put a player protection system in via a regulator,” he commented.
“In Spain and France, their regulatory returns highlight data where you could set the data across the market for player protection - as is the case in the Netherlands and even Sweden. What they have is a framework that they haven't yet extrapolated to player protection, but they can.
“In the UK, we have the opposite. We have poor data collection, we have a poor single view of customers across the industry. It is a mess and as a result, the UK is going to struggle to catch up to the rest of Europe when it comes to data, not when it comes to regulation.”
With regards to the actions of the gambling companies themselves, the CEO argued that firms should put their primary focus on data before making any decisions with regards to technological implementation.
“Operators need to look at their data first, and build a technology solution based on that available data,” he stated. “Every operator has different data, every operator stores it in a different way, and therefore the operator has to understand what their data is before they can even consider a technological solution.
“It is only data that can drive a true customer protection strategy, and it's how you manipulate and use that data which makes the difference. Gambling companies have been brilliant for years at using that data for customer acquisition, retention, bonuses and promotions. But it is that same data that can be used to help player protection.”
In order to effectively leverage this data and develop a strong technological basis for player protection, operators must also deploy a strong recruitment strategy in this area, both internally and externally.
“When it comes to hiring, what's really important is that you pick the people either within your business or outside who are interested in player protection, who want to learn about it, who have passion for it, and are willing to adapt their skills and their qualifications to player protection data analysis rather than just general data analysis.”
Ultimately, however, there is ‘no silver bullet’ to player protection and problem gambling, and further investment is needed - in time, money and people - for greater development in this area.
“Compliance isn’t a profit centre but it is a cost centre,” Foster concluded. “If you look at the financial services industry, the insurance industry, pharmaceutical industry, they invest heavily in compliance for this reason, compared to gaming companies. The industry must invest now if we are to manage effective change.” •

ESPORTS BETTING SHOULD PROVIDE A TAILORED EXPERIENCE FOR LOCAL MARKETS
BAYES ESPORTS AND
PINNACLE took time out with SBC Leaders to reflect on the continuous growth of the esports sector, discussing how it is transforming the betting demographic and what steps operators should take to capitalise on these trends
Susanne Ardisson, Head of Strategic Comms at Bayes Esports
BY VIKTOR KAYED
The 21st century saw video games exploding in popularity. With a global revenue projected to exceed US $200bn by the end of 2023, video gaming has long surpassed the days when it existed cheek by jowl with the movie and music industries. It is the most valued form of entertainment today.

Parallel to that, the competitive gaming space is also reaching new levels of maturity since its infancy back in the 1970s.
Having experienced a complete transformation from what might be perceived as a pastime for youths, esports has now managed to establish itself on par with professional sports. With investor interest rising and revenue doubling every two years, the sector harbours enormous potential to accommodate its own betting infrastructure.
However, Susanne Ardisson, Head of Strategic Comms at Bayes Esports, believes that innovations in the esports betting sector should come with a hefty dose of awareness due to the predominantly young audience.
“To be honest, it is very difficult to say how the esports betting demographic has changed, since esports betting in general has only recently been established,” she said.
“We can, however, assume that going forward not just the esports betting demographic, but also the betting demographic in general, will get younger. With betting companies and casinos being so regularly seen on the shirts of football players, we can expect there to be a continuing growth of the betting industry that will invite younger audiences to bet.
“Additionally, esports fans are on average younger than those of traditional sports, so the continuous development of esports betting options will also lead to the betting demographic getting younger.
“We need to create a healthy and legal ecosystem that is not built upon the exploitation of those that are most vulnerable, otherwise everyone loses.”
On the other hand, Pinnacle noted that esports itself has an omnipresence across several different platforms, each with a different prevalence to the other.
That’s also an important aspect to factor in when operators look to move into the esports space, as betting experiences should be tailored differently for each type of device, according to Stuart Bridges, the firm’s Global Esports Partnerships Manager.
“Elsewhere, mobile gaming has certainly come to the fore in recent years,” he noted. “Where highperformance PCs are out of reach financially of the average gamer, mobile esports have stepped in, and to huge success, particularly across LatAm and in various Asian markets.
“Titles like ‘Call Of Duty Mobile’ and ‘Free Fire’ may just be clones of their console and PC versions, but they’ve been able to attract a younger, mobile-first audience.
“As a betting industry, we have to keep up with these rapid, dynamic changes. Mobile esports will continue to grow its share of users and tournament prize money, and it’s imperative that we give those users the betting experiences that work with the environments they engage with and the devices they use.”

And while the esports industry can be looked at as a single enormous wave sweeping the entire globe, each region has its own specificities and market developments that betting operators should thoroughly investigate before launching their esports sportsbook.
With Bridges painting esports fans as “wiser” than their sports betting counterparts, taking a deep dive to understand local preferences, and creating a product that meets those specific expectations seems like an inevitable task when it comes to betting operators succeeding in the esports industry.
“Esports operators have traditionally looked to market globally, making the biggest, broadest splash across the most-followed media channels that the esports community engages with worldwide,” he pointed out.
Stuart Bridges, Global Esports Partnerships Manage at Pinnacle
“This is a good starting point, but with the esports industry maturing at such a rapid pace, and seeing exponentially regional differences, we have to look more and more at specific markets to understand how they engage and the titles they prefer.
“Operators going in and telling a specific community that they’re the best doesn’t build trust or authenticity, which is absolutely vital - as

sportsbooks have been treated with scepticism by esports fans in the past. Esports fans are more engaged and arguably wiser than their traditional sports betting counterparts, and so you have to be able to offer them something that can build that trust over time.”
All in all, Bridges summarised that without investing into an “authentic content creation and a tone of voice that resonates with the local audience”, operators might be disappointed in the returns they see.
In terms of how the nascent esports
betting space stacks next to the more established forms of betting on sports like football, for example, Bayes warned that esports data tends to change more often, directly affecting bet decisioning.
According to Ardisson, one of the biggest differences from a data perspective between esports and more traditional sports is the existence of patches. She explained: “Game titles in esports stay fresh and interesting because they are constantly balanced and updated. Each new patch can bring minor changes, such as increasing or decreasing the cost of a weapon or item, as well as major changes, such as the introduction of a brand-new character to play as or map to play on.
“This also means that your entire research you have done and all the data you have accumulated and used will be invalidated, as you are essentially dealing with an entirely new game when a big patch hits the servers. In these cases, it is often extremely difficult to predict which teams should be considered favourites, as even the players themselves typically need a couple of weeks to fully adjust to the changes.”
Unlike the start of a new football season, where the game and teams have stayed mostly the same, rules change almost daily when it comes to esports tournaments, requiring everyone involved to be more “quick and agile” with their choices, Ardisson added.
And finally, esports betting represents a fresh way of getting into the industry. According to both Bayes and Pinnacle, such expansion of content is precisely what the sector needs to elevate itself to the next chapter.
Said Bridges: “The last few years have seen product standards rise from a betting point of view, to match the demand from the expectant esports community. Fans want more, and we have to meet them at these higher standards.
“That’s not to say we’ve nailed it; we’ve got a long way to go, and what comes next has many unknowns. What we do know is that content is key.”
Echoing his words, Ardisson concluded: “In order for this to happen, for esports to become more established in the mainstream, we need to keep working hard and we need to keep raising the bar for what people can expect from esports - ranging from the overall level of play, over the professionalism of broadcasts, to esports coverage in general.” •
ESPORTS FANS ARE MORE ENGAGED AND ARGUABLY WISER THAN THEIR TRADITIONAL SPORTS BETTING COUNTERPARTS WE NEED TO KEEP RAISING THE BAR FOR WHAT PEOPLE CAN EXPECT FROM ESPORTS
60 SECONDS WITH… FSB’S CHRIS GRAHAM
IN THE FIRST OF A ‘60 SECONDS WITH…’ series, we sat down with FSB’s Global Head of Marketing Chris Graham who tells us about a Blur-ry night at university and why Danny Boyle’s Trainspotting tops his list of favourite films
SBC: What is your favourite film? And why?
CG: Being Scottish it’s probably not a massive surprise to hear me nominate Trainspotting. The perfect blend of black humour and dark despair. It came out at a time (early 1996) when there was a real vibrancy about British popular culture. This film captured this confidence well and shone a light on a city close to my heart, Edinburgh.
SBC: What is your favourite album? And why?
CG: The 2002 debut album from The Coral. A mad, selection box of sounds travelling through Russian cossack music, sea shanties, Merseybeat doo wop pop and North African reggae. A breathless ride through 11 incredible songs. I played it for 18 months non-stop much to the chagrin of my flatmates.
SBC: What car do you drive now? And what is your dream car?
CG: I’ve never been a car man, to be honest and (whisper it) have yet to pass my test. Don’t you just love a walk and public transport?
SBC: Your favourite holiday.
CG: I did a tour round Australia in 2015 which included the Melbourne Cup, Byron Bay and watching Tame Impala outside the Sydney Opera House. Magical memories.
SBC: What has been your most extravagant purchase?
CG: I’m just a modest working-class bloke with shallow pockets. I did spend £500 to watch Blur play in a smelly student union a few years ago. Worth every penny.
SBC: If you could pick anyone to go into business with, who would it be?
CG: In the context of people I admire in the business world I’ll stay within our industry and nominate Kenny Alexander. The way he grew GVC into an organisation that was big enough to acquire the traditional institutional giants of Ladbrokes and Coral was quite something. I worked with him at Sportingbet, a man who walked the shop floor, his passion for Kilmarnock FC was as fierce as for the business he worked for.
SBC: Knowing what you know now, what career advice would you give to your younger self?
CG: Believe in yourself more. Back yourself.






PETER-PAUL DE GOEIJ: THE DUTCH MARKET IS ‘NOT FOR THE FAINT OF HEART’
THE MANAGING DIRECTOR of the Netherlands Online Gambling Association talks SBC Leaders through the trials and tribulations experienced by operators in the recently launched Dutch online gaming market
BY JOE STREETER
Since its opening last October, the Dutch online gambling market has been confronted with numerous obstacles and backlash aplenty from the public outcry and Parliamentary demands, while also facing a generally disagreeable media presence.
That being said, the newly introduced regulations have already led to a significant decrease in the number of players engaging with the black market - an encouraging sign given that legal online gaming in the Netherlands is still in its infancy.
But as the framework for marketing regulation takes shape and the number of licensees increases, the next few months for Dutch gaming could well prove pivotal in the market’s growth and development.
Peter-Paul de Goeij reflected
on the regulatory process and just how challenging it has been, highlighting that from 1 April 2022, the Kansspelautoriteit will be assessing the last eight years of an applicant’s activities to ascertain their “squeaky clean” credentials.
It’s indicative of the regulatory challenges that betting and gaming companies will face, even as the market matures - with de Goeij emphasising that entry into the Netherlands “is not for the faint of heart”.
He pointed out that the country will continue to present challenges
even for incumbents that are more accustomed to the strictness of the Dutch regulators.
Alluding to the political influence wielded by MPs and the ongoing calls for even stricter regulations, he suggested that the regulatory framework will only become tighter as scrutiny of the sector increases.
He said: “In the field of advertising, the regulators are seriously clamping down when it comes to opportunities to allow the marketing of the regulated offer. We came from a situation where before October last year, there was no marketing at all for online gambling, which was very different from other European markets.
“For instance, if you compare it to the situation in Sweden, where prior to regulating the online gambling market there was already a significant amount of advertising for online gambling, including on TV.
“This meant that well before legalisation, Swedes were used to online gambling advertising even though online gambling was still illegal at the time. In Sweden, unlicensed online gambling companies got away with advertising on Swedish TV.
“That, however, did not happen in the Netherlands, so the KSA essentially shut down all TV marketing related to unlicensed online gambling from 2013 or so, with the expectation that the regulated market would open up imminently. Yet we all know how long this process was; it meant that consumers became used to having no online gambling advertising on their screens.
“They were used to lottery advertising and some land based casino advertising on their screens, but not for online casino and sports betting.”
The staggered opening of the market and the hesitancy in awarding licences also played a key factor in the problems that the region currently faces, having provided predominantly the incumbent operators with an opportunity to flood the advertising market.
This subsequently led to a public outcry and MPs responding to these complaints and concerns asking the Government to intervene.
Consequently, the backlash led to various MPs backing two motions for change - with the most prominent of these submissions calling on the Government to outlaw ‘untargeted advertising’ for online gambling.
The law, however, remains silent on what untargeted advertising actually

is, said de Goeij, and it may prove difficult to determine and define what this is.
In the past, legal scholars and commentators have argued that an advertising ban may well be difficult to justify because it infringes upon the freedom of speech, while evidence suggesting that this ban is absolutely necessary and justified has not yet been produced.
Pinpointing a potential solution, de Goeij revealed that NOGA has cited the importance of ‘advertising volume control’. To make it happen, however, requires collaboration from all parties,

which in itself presents significant challenges.
Recounting the efforts that have been made so far, de Goeij said that since 2019 there have been calls for all the gambling parties to sit around the table, including the lotteries and the media. But having voiced interest to participate, a meaningful gathering has failed to come to fruition.
The net result was that the advertising code in the region wasn’t agreed until after the regulated market had opened and was formed in the absence of a collaborative approach involving all relevant parties.
The move towards a blanket ban
on advertising is something that de Goeij warned will hurt channelisation and skew the market, thus creating a significantly unlevel playing field for legal operators compared to the many illegal online operators in the region.
He continued by mapping out the role of marketing when it comes to channelisation, advising that it will play a crucial role in combating potential growth in the unregulated market which would bring with it a social responsibility nightmare for the region.
“Gambling advertising plays an important and intricate role in channelisation,” he said. “Because online we have tens of thousands of illegal operators that have no interest in consumer protection, anti-money laundering, or retaining the integrity of sports, these operators are competing unrestrained, with the legal operators.
“Therefore, to smack the sword and shield from the licensed operators by imposing an advertising ban is the most stupid thing we could do. Fortunately, the ministry will work on the advertising ban, but in a proper way, through a formal act of Parliament - expediting the process as much as they can.
“In the meantime, things are also being worked on in lower regulations in the decree, such as the use of role models in gambling advertisements.
“This also brought us together with the trade association to analyse what we could do - which is where we came up with the stricter list of measures that we sent to the ministry and that they subsequently forwarded to parliament. We now have to implement these changes in the online advertising code and implement them.”
Prior to signing off, de Goeij outlined his optimism for the market, detailing his belief that it can get to a place where the needs and priorities of the consumer always come first.
He added that this also means the regulators must ensure privateers and fortune-seekers are kept out of the market because they exist solely to make as much money as possible in the shortest period of time.
“Gambling should not be about short-term profit, you should be in there for the long haul, and if you have no interest in the wellbeing of your customers, then you have no role to play in the gambling industry,” concluded de Goeij. •









