speaker-0 (00:00.148)
how this threat looks now of the black market is not how it looked 12 months ago and it's not how it will look in 12 months time. So the idea that these subgroups they might still be super relevant in 12 months but they may need changes they may need flexibility and I think the 12 month timeline allows for that it allows for changes to adjust and evolve with this threat.
speaker-1 (00:25.198)
The illegal gambling task force has made many headlines since it was first conceptualised in the UK budget last November, but one question lingered. What will it actually do? Well, this week we got a glimpse of what the task force's mandate is and what it will get up to. But given that we don't know who will actually be on the task force and that it will meet just twice in a 12-month period, the feeling is that questions still remain. So will the illegal gambling task force be effective?
And how can the industry actually win the fight against the black market? Welcome back to iGaming Daily, supported by Optimove, the creator of positionless marketing and the number one player engagement solution for sports betting and iGaming operators. I'm Charlie Horner and today I'm joined by iGaming expert editor, Joe Streeter and SPC News editor, Ted Orme-Clay. Ted, how's things?
speaker-2 (01:17.688)
Good to be making a trilogy this week, third appearance on the podcast. Good to be back again.
speaker-1 (01:25.614)
Your overtime check is in the post. Thanks a lot. Joel, how are you?
speaker-0 (01:29.782)
Yeah, well good Charlie, playoff season and it's on, enthralled with the EFL, loving the football at the moment and excited for today's discussion as well, a really interesting one. Finally, some developments on this story, so yeah, good to discuss that.
speaker-1 (01:44.012)
Yeah, sure, am slightly disappointed that we're not doing Spygate 2.0 on the podcast today.
speaker-0 (01:49.654)
What a story, what a story that is.
speaker-1 (01:52.148)
We'll that for another time. Ted, we've spoken a lot about the illegal gambling task force and what it might have to do since the budget last year when it was first conceptualised. But DCMS has released a terms of reference this week, just giving us a bit of a glimpse or some detail about what it might and might not get up to. Do you want to just give listeners a bit of an overview of what was in that terms of reference?
speaker-2 (02:20.746)
So they've set out three main objectives. I think we already had an idea that this is what they were going to be working on both from the information that slowly filtered out over the past couple of months since the task force was announced. Yeah, couple of months back.
And also just, guess, just through common sense of what we know about the black market, about the industry, what they'd be working towards. So one of them, and this is probably the most important one, I think the first one is is of clamping down on payments to the to the offshore operators. A lot of them obviously use cryptocurrency as a way of as a way of accepting payment due to being less traceable and so on.
And really, that makes a lot of sense to clamp down on that. If you can prevent people from making the payment to them, it cuts it off at the source, doesn't it?
speaker-0 (03:16.046)
clamped down on the crypto side of payments though, right? But you can still go after the PSPs for some of the transactions. mean, the crypto ones are hard to track, they're hard to get hold of. But you know, it's worth noting I was at the SBC Summit in Malta, what, two weeks ago, a of weeks ago, whenever it was. Lots of discussion around the black market and tackling PSPs constantly cited as a real way to get after the black market and to stop it at source.
speaker-2 (03:43.872)
Yeah, exactly. like your point is to you prevent that from happening. You're cutting off. Yeah, you're cutting off the revenue stream, aren't you? But like you say, the crypto one is more of a that's a much bigger challenge. That's a that's completely other.
fish to fry, isn't it? It's a big one to fry. So yeah, so there's that one, quite an important one, probably, as I've said, the most important one. Secondary to that is the, as we've discussed many times, I think, the marketing angle. We know that obviously DCMS is already consulting on a potential ban on unlicensed companies sponsoring sports clubs, not just in the Premier League and not just in football, but throughout all of British sport.
So that's the other element. And then also the marketing side of things does obviously bring in questions of not just sponsorship, but also on social media and things like that. If anything, that's the bigger one, really.
speaker-0 (04:33.847)
So Ted, so where are we at with the ban on unlicensed sponsors in English football? Well, the Premier League.
speaker-2 (04:40.67)
Where are we? Technically, guess nowhere at the moment. It's a consultation, isn't it? That's the thing.
speaker-0 (04:45.454)
I kind of echo what, and I'm not necessarily super pro the ban on unlicensed operators sponsoring in the Premier League specifically, because I think it's a global product, but if this is seen as a way to kind of thwart the black market and tackle exposure to the black market, why the bureaucracy? It feels like a very easy thing to get done. And the urgency from Stella David this week or last week, very recently she wrote another blog.
last week, right? She put out another blog saying, essentially, she obviously articulated it a little bit better than me, but she said, just do it. Let's just get it done. Like this feels like one of those things that is very easy to box off. it will stop some exposure and just an easy, why are we, we should be on this pod saying that is done rather than we're in a consultation period. It feels needless.
speaker-2 (05:38.954)
feel like the you know in a lot of these conversations we have around regulation in this country.
Not just of gambling but of any industry everything's about a consultation, isn't it? Yeah, it's constant. I guess you could have those reasons for that You want to get every stakeholders opinion? You want to make sure you're not just rushing into decisions without being you know being uninformed Yeah, but yeah, you know at the same time you could argue if we if everyone it seems that most people are in agreement about this Yeah, with the actually I guess say that probably the notable exception of some football clubs who count on this as a revenue stream. Yeah
they'll find someone else. There's plenty of companies out there, whether in the betting industry or not, who want to work with football, who want to get the visibility in there. You mentioned the Premier League as a global... It's probably the most global league, really, isn't it? Yeah, 100%.
I'm sure if we looked at the order having to hand I'm sure if you looked at the audience figures it would dwarf many others for global viewership. There's lots of people who want to get in on that. So yeah, is losing on license sponsored? I'm sure there'll be they'll be a irritated about it first, but they'll find someone else. So yeah, I get your point. It does seem like consultation. It often seems to be kicking the can down the road.
speaker-0 (06:50.158)
It was like unnecessary bureaucracy.
speaker-1 (06:52.978)
I think that's a key criticism of this government in general and by the time this podcast comes out who knows what's going to be happening with the government but it is a government by consultation, government by just process rather than actually getting things done.
speaker-2 (07:13.646)
If I could just interject with it to maybe have a little bit of a defense of it, is that anything new in the UK in general? I mean, if you look at the gambling act review under the previous government, under the conservative government, that took, three years and was delayed God knows how many times. I can't remember how many times actually. I actually had a Google document at one point keeping track of all the different ministers and prime ministers and so on who oversaw it. And I think by the end of it, there must have been about 13 or 14 secretaries of state
at the DCMS during that time, you know, so that's not anything new to the UK. Things take a lot of time here.
speaker-1 (07:50.496)
Let's just bring things back to the illegal gambling task force and what we learned this week. I'm just going to read a couple of bits from the terms of reference and I just want to get both of your thoughts on this. So, the task force will run for 12 months, at which point the remit and membership of the task force will be reviewed and renewed if necessary. The task force will meet at least twice a year and the subgroups will be responsible for determining the frequency of their meetings.
talk about urgency in this in this battle does that sound like you know an urgent mandate we're gonna run for 12 months and we'll kind of meet when we want
speaker-0 (08:36.12)
That's harsh, right? We'll meet when we want. It's kind of harsh, I think. So you've got subgroups, not to be confused with the overall picture. And correct me if I'm wrong here. The subgroups are going to more than likely off of what we know, meet more regularly to then the whole thing coming together. The subgroups will, I think the subgroups are well set up by the way. I kind of echo what Ted said there, the payments group, the enforcement group.
and the advertising group, think those are three really key issues that kind of hit the nail on the head with those issues. They're all gonna be kind of tackling different elements of the threat of the black market. And sometimes that will come together. I do see what you say that the two twice a year thing is a little bit worrying because you wouldn't want silos in these groups. You know, there are elements of what they do that will intertwine.
and wouldn't want to break down communication between the groups. two a year maybe is, yeah, kind of worrying, but let's see, let's give them a chance to run on their own first, I guess, as groups and then, yeah, see.
speaker-1 (09:42.99)
The task force will run for 12 months and then might renew if necessary. Are we going to beat the black market inside 12 months?
speaker-2 (09:53.166)
That's the bit that does sound a little bit falling short of the mark, doesn't it? You'd think that with a task like this, you would want a more long-term approach to it. On the face of it, it does seem like a bit of a non-commitment. guess kind of to build off what Joe said today, you've got to remember that this task force is still relatively new. When was it set? Was it February? I think we initially announced it. So that's not a huge amount of time. You've got to take time to get things ready.
to establish these subgroups that they have to establish your objectives. But yeah, a 12 month timeframe. When you consider some of the data we've got on the size of this market, I think I've jotted some stuff down, but H2 Gambling Capital estimates that the offshore market is 16.6 billion pounds. The BGC have commissioned quite a few studies estimating that it's around, I think, 10 billion annually.
Obviously I know, like we've said many times before, studies and surveys, whether they're commissioned by the industry or commissioned by people calling for more reform of laws or whatever, people always have a bit of an agenda, so that might influence the outcomes of a survey, but we have different stats to suggest how big this is. Gamstop have previously said that around one in 10 of their self-excluded customers, not customers, sorry, self-excluded.
users admit to using offshore platforms that obviously circumvent Gamstop, that advertise themselves as non-Gamstop casinos. So yeah, it's clearly quite a, it's a big problem facing industry and facing British customers, British customers who like a bet. So yeah, I feel like a 12 month timeframe isn't much to deal with that.
speaker-1 (11:43.608)
Here's the second point, sorry Joe, because we're gonna...
speaker-0 (11:47.24)
Can I just defend that really quickly, the 12 month timeframe, because this is a constantly adjusting threat, right? How this threat looks now of the black market is not how it looked 12 months ago, and it's not how it will look in 12 months time. So the idea that these subgroups, might still be super relevant in 12 months, but they may need changes, they may need flexibility. And I think the 12 month timeline allows for that. It allows for changes to adjust and evolve with this threat.
speaker-2 (12:15.392)
maybe allow a bit more flexibility. I see your point there.
speaker-1 (12:18.818)
Just very quickly because we do need to go for a break because we're sort of over time a little bit. But names of specific organisations and individuals that are members will not be published. DCMS's director of sport and gambling will act as co-chair and other stakeholders may be invited. Thoughts on that one? We don't know who's going to be sitting on this task force.
speaker-0 (12:43.758)
Yeah, we discussed this in the office. I don't know. I really don't know how I feel about this. I don't know.
speaker-2 (12:47.19)
Yeah, honestly, I'm not too sure.
speaker-0 (12:51.382)
And bear in mind, you know, a lot of the black market operators are the literal criminal gangs. So maybe there's a safety thing there. It's hard to tell though. We really mulled this one over in the office like before we came on and we weren't sure how we felt about it.
speaker-2 (13:09.87)
It's finding the balance between transparency and security. Tricky question.
speaker-1 (13:14.214)
To be clear, I'm not suggesting that is a bad thing. It was just a point of note that I made. I thought it's quite an interesting line that they weren't willing to...
speaker-0 (13:26.85)
weren't sure when we read the question we weren't sure if you were coming on with a reveal the names agenda. Let us know who you are.
speaker-1 (13:34.046)
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Welcome back to iGaming Daily. Now we've talked about the illegal gambling task force and what that mandate is. Now let's turn the conversation to what we think it will actually take to beat the black market because it's an ongoing conversation. We've spoken about it a lot. It's a conversation that's going to keep rumbling on. It's difficult, right? Ted, you came up with the stats in the first half of the show. This is a huge, huge sector.
They are using like crypto and difficult to trace payment methods. How do we do this? Is it a case of public messaging, player education, things like that?
speaker-2 (14:40.952)
Well, obviously there's multiple different things involved. think firstly, you mentioned the payment stuff. That's where that's a real place to start, as thankfully the task force appears to be. Joe mentioned earlier the importance of working with the payment service providers and reminding them of obligations. I think we'd probably have to make sure that they're regularly updated on who the most active offshore illegal sites are.
and make sure that they're blocking payments to those. Obviously, other thing is Joe mentioned about how regularly the market evolves. So you need to make sure you were really on that. yet identifying who the new illegal players were.
Yeah, making sure payments firms are blocking payments to those and are aware of who they are and are aware of what the repercussions for them might be. I mean, we've seen how banks in particular are getting more involved in addressing gambling harm, you know, with like their payment blocking tools for the regulated sector. So we know they have the capabilities and the willingness to do this. So I think some more cross collaboration there. The other side of things though, on the payment side, you mentioned, crypto.
you know, as we've already established, that's a different kettle of fish. that might require some, know, it's going to be difficult to address that with how it relates to gambling until the UK has a more clear regulatory framework around crypto and digital assets in general.
speaker-0 (16:09.912)
Can I bring it to kind of an element of this discussion that you're missing a little bit, right? This toolbox is fantastic and if we can maximise this toolbox, that's brilliant. But there's a ceiling because right now the black market for many is such an enticing prospect because it's so attractive, like unlicensed operators are so attractive to players that are VIP players that don't want stringent affordability checks.
And I think that's a real key factor in this is, you know, this conversation comes amidst a backdrop of harsher affordability checks in the UK. I think we have to look at how we can retain the safety of the regulated market whilst also enabling it to compete against the black market. The more you kind of the, you stack the scales in the favour of the black market by making
the regulated market so much to compete for, you know, for high risk VIP players, yeah, it's only the toolbox only goes so far and payment blocking only goes so far and you know, all these tools only go a certain way when, you know, you are kind of just weighing down and burdening the regulated market.
speaker-2 (17:30.33)
This is when we then run into a bit of a, we have a bit of a conundrum here, don't we? Because one of the reasons why the regulated industry is now facing tighter regulations and restrictions and higher taxation is because of, I think a lot of it is because of shortcomings around player protection and responsible gaming and safety and so on over recent years. And you know, we talked a lot about, know, the industry has upped its game a lot on that.
But we continue to see, it's fair, we've not seen one for a while, I don't think, but we do continue to see the gambling commission issuing enforcement actions, penalties, fines, and so on against regulated industry for social responsibility failings. And the concerns around the regulated industry, societal impact, is what led to the gambling act review and the new affordability checks and things like that. I think it's a very difficult.
tasks that the industry and the government and the regulator have in finding that balance, in making sure that people are being protected and not betting outside of their means and not being, well, I guess, you know, exploited, whether inadvertently or not, and also making sure that this illegal market is clamped down on. And yeah, part of the problem is that for some people it is more enticing because you can do pretty much whatever.
speaker-0 (18:53.166)
It's frictionless right. Charlie you spoke to Ted, the other Ted on a podcast earlier this week. I listened to a really interesting episode on affordability. One of the things he said is like it shouldn't be as stringent, the same information to get a mortgage as it is to place an accumulator. And I wonder what your thoughts were after that podcast.
speaker-1 (19:13.582)
think there was a great podcast when we did two episodes on affordability earlier this week and I'd implore people to take a listen to that if you haven't already. one of the things I would mention on this note is, and I won't steal ideas without crediting them, so Martin Elliott has suggested that...
speaker-0 (19:33.23)
A man of very few good ideas it must be said. No, I'm only messing, I'm only messing.
speaker-1 (19:37.686)
Well, he suggested that we should be doing maybe some public education campaigns on the black market to ensure that players know that they're betting or gambling with licensed operators. And he suggested a three-pronged approach. One, if you bet with licensed operators, you'll be safer on those platforms. You're less susceptible to not getting withdrawals and things like that. Two, you're not funding organized crime.
which we know some of these illegal operators are linked with. And then if you want to be really political with it, if you bet with licensed operators, those operators will pay taxes on it and then you can fund nurses, schools, firefighters, things like that.
speaker-0 (20:23.65)
There's there's also it's also worth noting adding to that that there's the safety net that you guarantee you're going to get your your money back right, but the education thing is is is super important because a new generation of player now is finding their way onto the black market Not in the same not going through the same Avenue as an older player did They're going through social media their first exposure to gambling is through streamers and
know, various other influencers on Instagram who are using black market sites. So the idea that a player stumbles onto the black market without even knowing that this is not a regulated website is, or a safe website, is actually very feasible now. It's actually a very real risk. yeah, education does become increasingly important and the correct approach to education as well and an effective education.
speaker-1 (21:19.16)
Yeah, the marketing and the influencer side of things is huge on this. I think we might have to do another podcast on that because it's such a complex topic that could take a half an hour of its own. But ultimately, do you think when it comes to the black market, we're losing, we're fighting a losing battle essentially until there is significant multi-organisational collaboration on this?
and significant resources put behind it as well.
speaker-2 (21:50.616)
Yeah.
speaker-1 (21:56.168)
the social media company
speaker-2 (21:59.138)
You need to the front picture. It's old arse, Yeah, that's the trouble, isn't it? There's a lot in there and there's a lot in there and at any given time the government will have various other priorities, as you mentioned earlier. They've got bigger things going on at the moment, I guess, for them immediately.
speaker-1 (22:11.501)
What you doing?
speaker-1 (22:16.554)
Yeah, yeah, we're living in a strange old world, very unstable world. But if you block a domain, another one's going to pop up the very next day. So you need all of these bodies to come together.
speaker-0 (22:32.738)
It's no easy ask Charlie. mean, you, you you had to organize SBC news and I gave an expert together for this podcast and I was challenging enough. Yeah. And we sit next to each other every day. So the idea of getting all these big companies together is, yeah, it's tough. but I think what you can do as I, as I mentioned before, and the reason why we're probably losing this battle right now is because it's, you know, you're stacking the deck so far against the regulated industry.
speaker-1 (22:38.22)
difficult
speaker-0 (22:59.79)
not just through taxation, but the affordability checks is a massive one. And as we have this discussion, even as we've talked about the banning of unlicensed sponsors, that hasn't been pushed through affordability checks. After much time and much deliberation, they have been put through and that makes it even harder for the regulated operators to compete, especially when it comes to the most at risk players, probably.
speaker-1 (23:27.566)
Yeah, certainly. I think we could do another whole podcast on this and we probably will in the next few days. But we'll have to leave it there. So Joe, Ted, thanks ever so much for taking the time and coming on today. Thanks to Optimoo for supporting the show as always and to our audience. Thank you very much for tuning in to today's episode of iGaming Daily and come back tomorrow to keep up to date with all the latest global gambling news.
speaker-2 (23:52.846)
you
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