August Column | Above The Game

Column By:

Ismail Vali, Chief Product & Marketing Officer for A GAME

Strange Places

Across regulated markets, the conversation we are having as an industry with government, media, the public and regulator - collectively, the betting and gaming industry stakeholders - has become, at best, strained.

Coronavirus is now a part of that dialogue, but we were already engaged in a complex conversation that has taken us, collectively, to some strange places.

-Stake caps: Calls for stake limits on various game types - most notably, slots - exist across many European markets

-Coronavirus caps: Several countries introduced “emergency measures” to curb online play, via advertising, deposit and bonus restrictions, despite nearly all countries discovering after the quarantine measures were introduced that there was no actual rise in gambling, let alone problem gambling, across the period. There was a substitution across gambling, obviously, given the lack of professional sports, but…that’s not the same thing as “a rise in gambling”, period

-Shirt sponsorship: Several European countries are calling for a ban on shirt sponsorships for soccer and other sports. Despite most sports teams calling foul over their rights to sell one of their most valuable sponsorship assets to the highest bidder

-Player protection: Measures to detect, prevent and provide for problem play, and caring for the most vulnerable, concerning betting and gaming products, are on the rise, and rightly so

-Wholesale gambling law reviews: We began regulating omnichannel betting and gaming from 2005 with the UK’s liberalising Gambling Act. Even this piece of law, much followed by regulators initially, until recently, is about to be thoroughly reviewed and revised by the current British government

Nearly all of these discussions share one factor in common: player protection.

Nearly all of these discussions have ended where we are today, in strange places, because we’re all ignoring one fundamental: the black market.

Darkness Calls

The shadow of the black market looms large. The more that markets regulate, adapt and experiment with aspects of the business like bonusing, staking, activity and deposit caps, ID verification, KYC, AML, and further, the more that shadow comes to tempt players back to the “gambling they knew and loved” and can still get, offshore, from unlicensed, illicit operators. No CRM and retention bonuses at licensed Swedish sites? No problem. Just hit Google and search for bonus bets or bonus casino and you will find dozens, if not hundreds, of options. None are licensed. None protect their players. None pay any taxes or adjust their operations, advertising, even their HR policies, to be and remain compliant. But, then, that’s the point with the black market.

The more conditions placed upon the licensed, legal, regulated business, and the more we continue to play the strange game of blame, name, fine and shame with regulators only punishing the licensed, but never the unlicensed, the more risk we bring to players, of all types, and the less we consolidate and safeguard an industry that, from its inception, needed controls and oversight which we accepted, adapted to and welcomed.

If the industry did not accept this, why would so many of us be licensed, today? Why would we fund gambling cessation, prevention and gambling-related harm charities and research? Why would we voluntarily propose whistle-to-whistle advertising bans across sports TV or other initiatives to market ourselves in increasingly responsible ways?

The Storm and The Fury

Alun Bowden, a senior consultant for Eilers & Krejcik Gaming, wrote in March 2020 (Eilers & Krejcik Gaming: Euro 2025 Outlook) about six factors creating a gathering storm for betting and gaming:

  • Revenue: Slowing growth

  • Regulation: Higher barriers to entry

  • Scale: Being redefined

  • “The Death of Fun”: Forgetting the player

  • Regulation: Country by country fragmentation

  • Audience: Changing tastes

When even the regulators are being dismissed as “unfit for purpose” as the Gambling Commission (UKGC) recently was - unfairly, by many accounts - by the All-Party Parliamentary Group, a body of 50 MPs researching the industry, we need to recognise that the “gathering storm” Eilers and Krejcik’s Alun Bowden referred to is, perhaps, no longer some weather forecast. On the strength of recent news and constant negative press for our industry, without the acknowledgement and insight across the real issue of the black market, perhaps we need to accept the storm is real and here, right now.

None of this is any fault of regulators, to be clear. They pursue the licensed estate and regulate it within the law, because that is their job, by law. Where they lack teeth, which they most definitely do across monitoring, policing and enforcing against the black market across iGaming, that is the fault of current law and present political focus.

We have not had the problems we face in iGaming regulation across land-based gaming regulation for many years – since, I’d suggest, the widespread removal of the black market and associated criminality from the late 1970s onwards, concurrent with the rise of the modern casino resort, a development much focused upon by politicians, law enforcement, industry and regulators, internationally, acting together at that time, for the benefit and protection of society.

What we have today is a conversation now confused by politics, where betting and gaming, the industry, has become something of a political punch-bag, and easy to attack for populist point-scoring.

Seed of Destruction

We need to adapt, as an industry, and most urgently towards the conversation we are currently having. The dialogue is descending into destructive notions of prohibition which, across the many learnings he made in his lifetime, Mark Twain had one salient observation worth sharing:

“It is the prohibition that makes anything precious”

The more we “play” with the mechanics of this licensed, regulated, tax-paying responsible industry, and continue to engage in conversations that do not reflect the realities of the modern business, audience and customer experience, the more we will sow the harvest for the new black market, on a by country and by state basis, unlike anything we have witnessed before.

We need to change the conversation, across stakeholders, and to the benefit of society, customers and players. That last group being the (often ignored) fundamental that matter, for the viability and sustainability of a licensed, responsible, tax and good causes-funding business, now and for the future.

You can learn more about protecting the licensed marketplace for betting and gaming at


#onlinegambling #eiindustrynews #gamingmarket #igamingcolumn #abovethegame