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CIS: OPPORTUNITIES AND RISKS
CONTENTS
Editor’s Letter 07 Events Calendar
82 Jurisdictions 2014
110 Marketplace
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EVENTS CALENDAR
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July 14 – July 16, 2014 www.GamingDownUnder.com
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operators understand the legal position, So many of the industry’s carefully continue operating in the British market
they then need to ascertain whether or not, considered comments and suggestions, on a transitional basis whilst its
in accordance with their own appetite for flowed through to the Commission during application is processed.
and attitude to risk, it is business they are the consultation, were ignored, and as The Commission had always stated that
willing to continue undertaking. What has such, the cost of compliance has risen the licensing window for continuation
become very clear in recent weeks is that considerably whilst its effectiveness licence applications would open two
the Commission’s stated aim of ensuring remains largely unchanged. months after Royal Assent which, based
that operators that apply for licences are One example of this is the sheer on Royal Assent being 14 May, will be mid
operators of “integrity” and “suitability”, increase in the amount of information July. The industry was also consistently
is likely to be achieved. A number of the Commission requires operators to told that the licensing window would be
operators are closing jurisdictions down or disclose, on an ongoing basis, about their open for one month, then closed for a
assessing the way in which they transact business operations. How much of this week, and then would swiftly be followed
with certain jurisdictions to ensure that information will genuinely be assessed by by full implementation of the amended
they minimise any attendant risk. Not only the regulator as it struggles to cope with legislation. As such, under current
do operators want to ensure that they are the sheer volume of data it has demanded timetable the industry has been looking
capable of following the Commission’s operators supply? Best estimate suggests at a 1 September implementation date.
guidelines in ensuring that they can an additional 150 licensees will apply to However, on the day this article
represent in their business plans the legal the Commission for regulation, and each was written, the Government and the
basis for the business that they undertake, of those requires significant overseeing to Commission each received letters written
operators have taken the opportunity to ensure that the licensing objectives are met. on behalf of the Gibraltar operators.
reflect on their operations to future-proof That said, the LCCP is clear in its These letters before action could lead
them independently of the British licensing requirements and, as such, operators to a judicial review process, with as yet
application process. and suppliers are generally left with no unknown consequences.
illusions as to what is required of them to In the meantime, the licensing process
Compliance and disclosure comply. But it is that compliance with the may well rumble on. By the time you read
It is worth touching on the Licence requirements that will begin to take their this article, the consequences of these
Conditions and Codes of Practice (LCCP), toll in the coming months and, particularly actions may be known. Or, the Statutory
the cornerstone of British gambling when a number of smaller gambling Instrument which will finally confirm
regulation, which sets out the various suppliers obtain licences in the Autumn the timetable may have been published,
conditions that operators need to adhere and Winter (in advance of the 30 January confirming the Government’s intentions.
to and also links to a variety of other 2015 deadline), we may find that a number The industry is currently left in a holding
documentation including the Remote of applicants simply drown under the pattern. Things will become clearer
Technical Standards which set out, in more weight of regulation. eventually and then we will see if John
detail, the technical requirements for a Penrose’s stated ambitions to regulate
remote gambling operation. Why the wait? the industry on a point-of-consumption
The LCCP underwent a consultation At the time of writing this article (mid basis as a means to further protecting
and consequential renovation earlier June), we have yet to receive details of consumers, will become a reality.
this year, which saw many provisions the implementation process and the
updated and introduced a whole new requirements that need to be fulfilled
layer of information sharing and by any operator seeking to apply for If you want to know more about the British licensing
bureaucracy to an industry already a “continuation licence” from the process, contact Stephen.ketteley@dlapiper.com or
Ashley.averill@dlapiper.com.
drowning under the weight of regulations. Commission, which will allow it to
Germany: Waiting
for Certainty
The CJEU’s recent decision in the Digibet case has only served to create more In November 2013, in a letter to the
legal uncertainty around the German licensing process, writes leading gaming remaining 41 applicants, the ministry (as
lawyer Martin Arendts. instructed by the gambling board) declared
that none of the applicants, not even the
The situation in Germany at the moment this number might be increased to 40 to state operators which had applied, fulfilled
with regard to sports betting and meet the expectations of the remaining the minimum requirements (contrary to the
gambling increasingly resembles a scene applicants). The fact that the detailed representation of the ministry in the court
in Waiting for Godot, the absurdist play licensing criteria have not yet even been cases which stated that 14 applicants had
by Samuel Beckett. The licensing process, published is even more significant. fulfilled the requirements of step two). In
which began two years ago, is becoming a The State of Schleswig-Holstein at first did January 2014, the applicants were requested
neverending saga, and one can now not follow the other 15 German states, and to submit additional information and
imagine Vladimir and Estragon discussing opted for a more liberalized system (without documents by 14 March 2014.
how perfect the situation might be if a maximum amount of licences, also In the meantime, state-owned ODS
licences had finally arrived. allowing online casino games and poker). ODDSET Deutschland Sportwetten GmbH
The Court of Justice of the European However, after state elections in 2012, which (ODS), had asked the Administrative Court
Union (CJEU), in its recent Digibet led to a new state government, Schleswig- of Wiesbaden to be granted a licence. In
decision, also did nothing to resolve legal Holstein joined the Interstate Treaty. The its interim decision of 20 December 2013
uncertainties, but made legal predictions Schleswig-Holstein Gambling Act ceased to the Administrative Court of Wiesbaden
even more intricate. The CJEU did not dwell be in force with effect from 9 February 2013, requested the Hessian Ministry of the
on the proportionality of the restrictive shortly after the referral of the Digibet case Interior to accelerate the licensing
provisions of the Interstate Treaty on by the Federal Court of Justice to the CJEU procedure and decide on the application of
Gambling, which, however, will be a topic of in January 2013 . The authorisations, issued ODS within three months. It held that the
a new referral from Germany (Ince case). before to operators, remain valid. ministry had to decide on the application
The Hessian Ministry of the Interior within reasonable time and that there was
The background was appointed to organise the sports no comprehensible reason why the ministry
In 2012, Germany decided to abandon its betting licensing procedure under the could not do so. However, the Hessian
strict state monopoly system with regard to experimentation clause, and to issue the Administrative Court of Appeal now
sports betting (after the CJEU, in its decisions licenses on behalf of the newly created repealed this decision, arguing that ODS
of 8 September 2010, held the sports betting gambling board (Glücksspielkollegium). had to wait for a final decision.
monopoly to be inconsistent with EU law). The tender for the 20 sports betting licences The court of appeal pointed to the fact
The German states (Länder) amended the was published in the Official Journal on 8 that applicants could bring an action
Interstate Treaty with an experimentation August 2012. More than 100 applications for failure to act (Untätigkeitsklage). In a
clause in section 10a and started a licensing were filed with the ministry. After the partial judgment for a private operator , the
procedure to grant up to 20 licences. second step, however, the procedure came Administrative Court of Wiesbaden already
However, after two years and after several to a standstill, while first legal battles had decided that ministry had to decide
court decisions (with even more to come), were fought in 2013 (until the Hessian on the application within three months.
not a single licence has been granted. It is Administrative Court of Appeal, in its However, the court allowed for an appeal to
quite obvious that the whole procedure BetVictor decision of 28 June 2013, decided clarify the procedural situation.
does not fulfil the criteria of the CJEU. that applicants first would have to wait for An end to the legal dispute is not near.
There is no factual reason for the maximum a final decision to ask the court for legal If the ministry will eventually decide to
amount of 20 licences (there are rumours remedy and interim protection). issue licences, and not to re-start the whole
procedure, it first has to send out rejection to a single Land. Thus, the existence for a other hand, tried to interpret that the CJEU
letters, and to wait for two weeks to finally limited period of more liberal rules does not held the Schleswig-Holstein Gambling Act
send out licences. In the meantime, most seriously affect the appropriateness of the to be in conformity with EU law (which
rejected applicants will certainly ask for restrictions on games of chance applicable the CJEU also did not do). In referral cases,
interim legal protection. I also expect in all the other Länder to achieve the the CJEU also refrains from declaring
that licence-holders will file suits against legitimate public interest objectives pursued. national law as inconsistent with EU law. So,
incidental provisions of their licences, Thus, the Court of Justice observes that the practical guidance for the national courts is,
regarded to be to restrictive. other 15 Länder were not required to change from my point of view, essential to support
their legislation in that field simply because the functioning of EU law.
The Digibet decision a single Land had followed a more liberal With regard to the current sports betting
The CJEU, in its recent Digibet decision of policy for a limited period. licensing procedure in Germany, a new
12 June 2014, did not help to clarify the So, would the CJEU have decided referral in a criminal case could prove
legal situation in Germany. This case was differently, if the two different sets of rules interesting. In the Ince case, the District
heard by the Third Chamber (not the Grand would have co-existed for two years or if Court of Sonthofen inter alia has asked the
Chamber as the previous referral cases two Länder had opted for a liberal policy? CJEU to clarify the criteria for a licensing
from Germany). After an oral hearing on 2 It also does not help national courts, if the procedure, namely: “When are the selection
April 2014 and without an opinion of the CJEU tries to distinguish the Digibet case criteria to be published?” In the quite
Advocate General, the CJEU only answered from its previous Carmen Media decision, detailed referral questions, the court also
some questions of the Federal Court of also a preliminary ruling on a referral points to several inconsistencies, including
Justice. It reiterated that it is the obligation from Germany. I fear that the consistency the fact the same law firm advises the
of the national court to verify whether requirement becomes largely inoperative, Hessian Ministry and the lottery operators,
the restrictions satisfy the conditions of if you have to distinguish between vertical the ministry first accepting 14 applications
the Court´s case-law concerning their consistency (Land and Federal authorities) then later arguing that the minimum
proportionality. So the Federal Court of and horizontal consistency (relationships requirements have not been fulfilled, and
Justice, if taking this remark into account, between the Länder). Should there really that state operator ODS does not fulfill the
would have to refer the case back to the be no consistency requirement in the obligation of separation between organised
trial court to determine the facts (and “horizontal relationship” between the sport and the operation of sports bets. We
whether these are compatible with the Länder? As the Schleswig-Holstein await the ruling with interest.
freedom to provide services). Unfortunately, example proved, an Internet ban is
the CJEU did not further dwell on the clearly not proportionate, as there is no
proportionality requirements and did not overriding requirement in the public
develop more practicable criteria. interest, as less restrictive measures seem
With regard to the consistency to work better and more effectively. Martin Arendts is one of the
requirement, the CJEU held that even Operators and authorities tried to leading gaming lawyers in
Germany. He is a General Member
assuming that the more liberal legislation interpret the Digibet decision in their
of the International Masters of
in Schleswig-Holstein may have interests. The attorney for WestLotto, the Gaming Law and regularly writes for national and
undermined the consistency of the policy plaintiff in the Digibet case, argued that international legal publications. Recently, he dealt
of prohibiting games of chance in the the CJEU confirmed the consistency of with several administrative law, constitutional law,
other Länder, the application of that more the Interstate Treaty with EU law (which criminal law, unfair competition law and trademark
it clearly did not). Politicians of the former proceedings in connection with sports betting,
liberal legislation was limited temporally
lotteries and poker.
to less than 14 months and geographically Schleswig-Holstein government, on the
bingo and poker, have been required to has been most welcome by the industry as waiting for the LGA to take the next step and
obtain separate licences for each product, it clearly identifies what the LGA requires propose amendments to the law that can
even though both products fell within the from a Key Official when adding and/or render the regulatory regime more relevant,
same licence category, and even if both decommissioning hardware. effective and attractive. The LGA should also
were provided by the same software start looking at more effective collaboration
supplier. As a result of this “quick win”, Role of key official with jurisdictions in and outside of Europe,
operators wishing to offer “player to player” The Authority is planning to launch Key providing added value to the Malta online
games will only require one Class 3 licence Official training and certification. The LGA gaming licence.
and no longer be required to obtain 2 shall be publishing further details in the
separate licences (one for bingo and one for coming weeks.
poker), when the products are provided by
the same platform provider. It remains to An open mind towards ‘cloud’
be clarified, whether operators that offer or environments
wish to offer other ‘Class 3’ games such as The Authority will with immediate effect
pool lotteries and betting exchanges shall start to accept hosting of servers in a cloud
benefit from this change. environment on a case-by-case basis and
after carrying out a risk assessment. Until
Servers will no longer be sealed last year, the LGA was highly sceptical
In order to keep track of current hardware, about the use of “cloud”, which it generally Joseph F Borg is currently a
the Authority is introducing the concept of considered to be a high risk environment. Senior Advisor to WH Partners, a
‘tagging’ instead of ‘sealing’ of servers. For Operators were only allowed to use a cloud law firm specialising in Gaming,
Corporate, IT, Telecoms and
several years, sealing of all components of environment for static information. The
Intellectual Property Law. He also
the hardware used by operators has been LGA has now recognised that with the lectures Gaming Law at the University of
the LGA’s preferred way of keeping track of latest technological advancements, a “cloud Malta. Before joining WH Partners he occupied the
the equipment utilised by operators under environment” can be considered for data post of Chief Regulatory Officer of the Lotteries and
their remote gaming licences. However, which is not static. Since the LGA said that it Gaming Authority - Malta.
the sealing process has been criticised will take a risk based approach and consider
by key stakeholders as being impractical, each request on a case-by-case basis, we
time consuming and a process which does understand that requirements may vary,
Dr. James Scicluna is a Partner
not provide the LGA with any additional from one business model to another. at WH Partners in Malta. He is a
comfort or security. The LGA has now dual-qualified Maltese advocate
decided to do without the sealing of each Next steps and English solicitor and General
component and to require solely the tagging Are these “quick wins” enough? Certainly Member of the International Masters
of Gaming Law and the International Bar
of each piece of hardware with an inventory not! Are they a step forward in the right
Association. He is ranked in the top 50 global
number. The hardware will also be sealed to direction? Yes, and they have been welcomed
gaming & gambling lawyers by Chambers &
the rack. Resealing or re-tagging will only be by the stakeholders at large. Gaming is Partners.
required if the hardware is moved or if new perhaps one of the most dynamic industries
hardware is installed. in the modern economy, and regulatory
regimes require continuous adapting and
Updates to incident reporting updating to remain relevant and achieve Dr. Robert Zammit is a Senior
Associate at WH Partners,
requirements their goals of protecting vulnerable persons,
specialising in regulatory,
As an ancillary to the previous measure, the keeping crime out of gaming and ensuring licensing and litigation law. His
Authority has updated its recently published fairness without imposing unreasonable principal areas of expertise are
procedure for “Incident Reporting, Addition burdens on the industry. licensing of gambling businesses and
and Decommissioning of Hardware” to While some further ‘quick wins’ that regulatory compliance in the area of gambling,
intellectual property, information security, privacy
reflect the LGA’s policy change with respect do not require legislative intervention are
and data protection.
to the tagging of equipment. This document on the agenda, the industry is impatiently
site. Thus, an Ancillary CSIE is required if not be tolerated. The letter was signed by do not have to pay taxes, meaning smaller
the affiliate marketer is paid based upon New Jersey Assistant Attorney General operating costs and more revenue.
how much money a player deposits or the George Rover and was sent to some of the New Jersey’s efforts to regulate affiliate
total number of bets the player makes, if most well-known affiliate websites in the marketers, through its cease-and-desist
there is a revenue-share agreement between industry: CardsChat.com, PokerSource. letters and revised guidelines, may help
the affiliate and the gaming operator, or if com, RakeBrain.com, Pokersites.com, to bolster its struggling online gambling
there is a hybrid revenue-share agreement RaketheRake.com, and one unnamed site. market, which suffered a decline in revenue
based in part on how much money the The letter to RaketheRake.com, for example, over the past couple of months. In May, New
player deposits or bets. cited Bovada Poker, Merge Gaming, Black Jersey’s regulated online gambling market
According to the DGE, master affiliates Chip Poker, and America’s Cardroom as generated $10.5m in revenue, a 9% drop
will need to acquire an Ancillary CSIE poker sites which are being promoted by from the previous month’s total of $11.4m
license if they have a revenue share deal in the affiliate. None of those sites are based and the second straight month of declining
place with their sub-affiliate(s). However, if in the US, and none are approved by the revenue since the market launched in late
the master affiliate and sub-affiliate only DGE. According to the DGE, the advertising November 2013. Online casino revenue
deal in flat-fee structured compensation of unregulated online gaming sites taints fell by $600k to $8.2m while poker revenue
plans, only a Vendor Registration is required. legitimate sites by associating them with dropped over $300k to $2.3m. For the
In addition, the revised guidelines detail illegal ones, and conversely may lend year-to-date, New Jersey’s online market has
compensation models for Refer-A-Friend the appearance that the illegal sites are earned $53.5m, with casino accounting for
deals, in which an i-gaming website pays somehow affiliated with authorised sites. $38.9m and poker generating $14.6m.
a flat rate to a user for each referral. No The continued presence of unlicensed In a regulated online gambling market
licence is required if the user receives less poker rooms in states like New Jersey has such as New Jersey, continued oversight of
than $2,500 in fees during a calendar year. put a major strain on licensed online poker affiliate marketers is essential to help steer
Regardless of the compensation rooms, which operate under a regulatory traffic to New Jersey’s licensed sites and
scheme, DGE’s latest guidance provides scheme that places them under certain away from unregulated offshore companies.
that the DGE will require all affiliates to constraints. Unlicensed online poker rooms, While there are still some kinks to work
produce a monthly report detailing all however, are not subject to the same rules as out – for example, how to manage and
compensation, and all compensation their licensed counterparts, allowing them regulate “super-affiliates” – this move by
must be based on the contract that the to divert traffic to their sites from legitimate New Jersey’s DGE should set precedence
affiliate provides to DGE. Further, affiliates operators. For example, unlicensed rooms for other states to follow, once they pass
may not receive compensation for business have a simpler sign-up process, which does i-gaming legislation of their own.
gained through contracts that are based not require a player verification check, the
outside of New Jersey. surrendering of a Social Security Number, Rachel Hirsch is an attorney at the
or geo-location. Unlicensed rooms can also Washington, D.C-based law firm
New Jersey’s Crackdown on Rogue accept all types of payment options and are of Ifrah PLLC. Ms. Hirsch focuses
her practice on complex litigation and
Affiliates under no compunctions about miscoding a
transactions, with a particular emphasis on
The revised guidelines follow a cease- credit card transaction. Unlicensed online
iGaming and Internet marketing and advertising.
and-desist letter sent by the DGE in April poker sites do not have to vet promotions or Her clients have included PokerStars, Full Tilt
to various poker affiliate sites, warning new games with regulators and have access Poker, and Microgaming. Ms. Hirsch graduated
them, in no uncertain terms, that the to players beyond New Jersey, giving them with honors from the University of Maryland
advertising of offshore poker sites that far more liquidity than licensed rooms. School of Law and practiced at Venable LLP prior
to joining Ifrah Law. Email: rhirsch@ifrahlaw.com.
offered games to New Jersey players would And, more importantly, unlicensed rooms
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Gambling Advertising:
What Really Matters
A new report on gambling advertising highlights the real opportunity for lead to a reconsideration of the existing
operators to follow Ladbrokes’ lead and address public concerns through their advertising codes, particularly bearing in mind
creative, argues Tom Grant of Harris Hagan. that the existing BCAP Code is well policed by
the ASA and is supplemented by the industry’s
A new report called “Betting on Digital” has marketers’ views are not always consistent own code of practice which reinforces the
been published, which examines some of with the consumers that were surveyed. scheduling constraints.
the challenges the gaming industry faces in Whilst the consumer responses inevitably The new report demonstrates that there are
ensuring its marketing activities effectively placed a high value on matters such as user two key forces at work here: on the one hand,
and accurately target the right audience. experience, game quality and discount offers, we see the growth and power of social media
The report is based on research carried there is an interestingly high stock placed on as gaming organisations naturally gravitate
out by IgnitionOne, a digital marketing firm, reputation, regulation and overall corporate towards an accessible and price-competitive
and ComRes, a polling organisation. social responsibility. Not all of the marketers means of reaching wider audiences; on
The research polled 2,000 people and felt, however, that consumers cared about the other hand, the current age of austerity
carried out interviews with 11 senior marketers whether or not a company donates to related has understandably given rise to a mood of
at various gambling organisations. Given the causes. A snapshot of some of these findings national cynicism. The gaming industry does
relatively small sample, one could argue that makes interesting reading: not stand alone here as the likes of Starbucks,
some of the claims should be taken with a • 40% of those surveyed said that they Apple and Amazon have faced a tremendous
pinch of salt, not least the statement that two would be more likely to place a bet public backlash in relation to their tax affairs.
thirds of “the British Public” are concerned with a company that they knew were It will be interesting to see whether gaming
about the amount of advertising of online acting responsibly and making financial companies will continue unabated in their
gambling. As David Letterman, the renowned contributions towards research, education quest to dominate acquisition through social
American chat show host, once quipped “a and the treatment of addicted gamblers; media or whether there is an opportunity
new survey showed that three out of every four • 77% of those surveyed agreed that online here for a gaming organisation to buck the
people make up 75% of the population.” gaming companies should pay taxes in the trend in their approach. There is a compelling
The report does, however, raise some countries in which they operate; argument that both gambling advertising and
interesting conclusions from its interviews • Only 26% of those surveyed agree the products itself have become somewhat
with gaming industry marketers, which that online gambling makes a positive generic. Without necessarily boring the
are as follows: contribution to the UK economy. consumer, there may be an opportunity for
1. An increased focus on mobile One of the headline outcomes of the an operator to zone in on some of the more
products – not only are consumers using research is that 67% of those surveyed are serious issues that consumers appear to care
devices more frequently but this presents concerned about the amount of advertising about – namely, spending limits, financial
increased opportunities for location-based for online gambling companies. Whilst the contributions towards research and education
marketing activity; survey revealed that TV is still considered and paying its UK taxes. The irony is that all
2. The importance of quality over to be a powerful tool, the ever multiplying gambling companies do these things already
quantity in respect of customer acquisition number of gambling adverts may be a concern (or, in the case of taxes, are about to) but do
– given the brand promiscuity of gaming for regulators. OFCOM published a report not seem to feel that they are worth shouting
customers, it is no longer a simple land grab earlier this year which revealed a staggering about. Ladbrokes have, however, started to
but there is now a more profound quest increase in the number of gambling adverts lead the way with their ‘responsible gambling’
amongst operators to align all of the key on TV In the UK from 152,000 in 2006 to 1.39 centric “Mr Brightside” advert. It is well known
ingredients to be a market-leader; million in 2012. There are, of course, various that perception is everything and gambling
3. The growth of new media channels factors at play here – such as cost and channel operators would do well to recognise that this
available requires a re-evaluation of proliferation – but the key concern relates applies to the public as well as to regulators.
priorities, as gaming companies place to the number of “impacts” (i.e. the times an
greater emphasis on their social gaming advert was seen by viewers) on children which Tom Grant is a partner at Harris Hagan
strategy whilst re-examining the value and increased by 272% during that period. It and specialises in commercial law
effectiveness of traditional TV advertising. remains to be seen whether either the OFCOM with a particular focus on gaming
related products and services.
What is particularly striking is that the report or the “Betting on Digital” report will
law. It has been the case for a long time The content of advertising and marketing others, or (c) participates in the operation or
now that affiliates advertising in to the will be under increased scrutiny in the administration of gambling by others”.
British market must make sure that their coming months as CAP/BCAP and the It should be obvious by now that POC
advertising material complies with the Commission review gambling advertising licensing is not something that can be
Committee of Advertising Practice (CAP) rules, partly as a result of an increase in ignored on the assumption that everything
or Broadcast CAP codes, as applicable, in complaints about gambling adverts over the will continue as before. It is not even a
addition to the Gambling Industry Code last three years. The results of the review question of encouraging affiliates to
and the marketing provisions in the Licence will be published in the autumn of this year, review their business relationships and/
Conditions and Codes of Practice (LCCP) with implementation by the end of the year. or making sure that they will comply with
that apply to all licensed operators. One The Commission has also appointed one of the new law. If you are an affiliate in the
of the existing LCCP obligations on an its Commissioners to carry out a review of British market and are not addressing the
operator is to include in his terms of trading social responsibility in gambling. It would be forthcoming changes yet, you may find
with affiliates a right to terminate an affiliate optimistic to the point of delusional to think that your client operators will soon come
contract promptly, should the affiliate that the outcome of these two reviews is knocking and ask you for assurances that
breach the advertising codes. going to present operators and affiliates with you are adapting your business model and
The recent amendments to the LCCP greater artistic licence in advertising. redesigning your websites to make them
appear to take the position much further and If a marketing affiliate goes further compliant. Having invested time and money
place an onerous burden on the licensee who than mere advertising and has some in getting licensed under the new regime,
must now ensure that the terms on which he greater involvement in the administration operators are not going to put their new
contracts with any third party who provides or operation of the gambling such as a licences at risk for the sake of any affiliate
an aspect of the licensee’s business does so branded skin, and say, he is responsible who does not toe the line.
in accordance with the LCCP, otherwise, for registering players and/or receiving
the licensee must terminate the contract. payment from them, then he may require
There is no express exclusion for affiliates his own operating licence. This was not
who are dealing with marketing on behalf something that needed to be considered
of an operator. Therefore, if say a marketing under the existing law, where the test for
affiliate runs a marketing programme or whether online (remote) gambling was being
loyalty scheme for a British licensed operator, provided in Britain was simply whether
it must comply with the LCCP provisions there was at least one piece of remote Peter Wilson is a regulatory
relating to such programmes. Affiliates will gambling equipment used in providing the lawyer who runs his own niche
need to start learning the relevant parts of facilities for gambling located here. Now law firm, Peter Wilson Legal LLP,
specialising in gambling law and
the LCCP if they want to avoid problems there is an additional test and one simply
business investigations. His gambling practice has
in promoting to the British market. There has to ask whether, regardless of where the been recognised for many years in both Chambers
will also need to be greater communication equipment is located, are the facilities used UK and The Legal 500. He is a member of the
and cooperation with the compliance team in Britain? If the answer to that is “yes” then International Masters of Gaming Law, International
in the operator’s business. For example, if a you must work out whether your activity in Bar Association (Business Crime and Leisure
Britain constitutes providing facilities for Sections), the Tax Investigation Practitioners
customer self-excludes with the operator, it
Association, the Proceeds of Crime Lawyers
appears that the affiliate must also ensure gambling, the definition of which (in section
Association, the Association of Regulatory and
that he takes all reasonable steps to prevent 5 of the Act) is as broad as it is unclear and Disciplinary Lawyers, and the Fraud Advisory
any marketing material being sent to the means any person who “(a) invites others to Panel. He regularly publishes articles on gambling
customer otherwise, again, he may find gamble in accordance with arrangements and other regulatory legal developments and is a
that his client operator is obliged to terminate made by him; (b) provides, operates or frequent speaker at gambling conferences both in
the UK and abroad. www.peterwilsonlegal.com.
the contract with him. administers arrangements for gambling by
The free-to-play or “freemium” pricing Gambling conceptual frameworks, to the capacity of social games to function as
model is itself inherently intertwined with Dr Miller argues, are simply not helpful a positive vehicle for social interaction.
these changes in mobile and internet when trying to analyse the impact of the The ability of games to motivate, allow
technology. The ease of online digital social games, which are played or and paid for creativity and enable collaborative
distribution, the reluctance of users to for differently. Social games are being played learning mean they are a growing feature of
pay for content (as well as piracy) and the for fundamentally different reasons such as education curricula.
demand for more flexible mobile gaming relationship building across social networks,
experiences are all reasons why it competition and simply hanging out friends. A platform for further engagement
dominates today’s app stores. This analysis is backed up by Harvest’s The place of social games in the digital
As a hot topic, the freemium model has consumer behaviour survey. Consumers economy is increasingly prolific. Social
been discussed extensively in relation to were asked the extent to which they could games are projected to reach $7bn in
in-app purchases. Yet as Harvest observes, differentiate between social games and revenue by 2015 and it is expected that
there has been little or no consideration by gambling – figures were consistently high 34% of the total Internet population will be
the media and regulators of the underlying for understanding the difference. playing social games.
forces behind it. As the cultural and social relevance of
Getting a good deal social games continues to grow, we hope
Gambling and social games - The consumer behaviour survey that our report will function as a resource to
no evidence of a connection consistently indicates that people are help educate and inform policy makers and
It’s fair to say that the assumption that getting a good deal from free-to-play the public alike.
casino-style social games are a form or cause social games. Less than one in 10 players At the same time, we believe strongly
of gambling, or at the very least linked to spent money on a social game on their that our research should not be a one-off
gambling, has been fairly widespread among last playing occasion. endeavour. As part of our commitment to
regulators and gambling studies researchers. Out of those that do pay, expenditure on going research we are commissioning
However, the report’s review of the on the last purchase occasion is typically a follow-up study specifically focused on
academic analysis highlights the absence less than one unit of local currency: 87% issues surrounding youth game-play.
of evidence that social casino games are of French transactions were less than We are also working on a second version of
converting people to real-money gamblers. €1.00, 90% of UK transactions were less the Best Practice Principles that we released
Despite the absence of conversion evidence, than £1.00, 91% of Australian transactions last October. These reflect an increase in
the allegation that free-to-play games, social were less than A$1.00 and 86% of US knowledge about social games thanks to
casino or otherwise, could be an active cause transactions were less than US$1.00. our research alongside ongoing regulatory
of gambling has had some currency. Yet as Even the more advanced upgrading developments from around the world.
Harvest point out, it is striking that the prolific features within game playing are on average It is imperative that we keep developing
rise of the social games industry has actually priced competitively with other forms of our understanding of the impact and
coincided with a decline in problem gambling entertainment, such as renting or buying a reception of our industry. The reason
rates in both the UK and Australia. movie. Only between 1% and 3% of in-game is straightforward. An evidence-based
Some gambling studies academics have expenditure exceeds $13. approach makes for better policy from
attempted to frame them as a “gambling industry and policy makers alike.
like” activity – for Dr Miller that is a Benefiting the mind
dangerously imprecise basis upon which Another interesting section of the report
to formulate policy. is its review of a wealth of psychological
Money, and particularly winning money, studies. Many show the positive potential of
Luc Delany is CEO of the
is integral to any definition of gambling. playing video games – a counter to clichés of International Social Games
Social casino games do not enable people disconnected and antisocial gamers. Association. He is a former policy
to win money and most players do not pay Benefits range across the spectrum, executive at Facebook and Google. He
to play. Categorisation as a form of from mood management, helping the is an external advisor to the University of
Maastricht and a fellow of the British American Project.
gambling is simply inaccurate. development of memory and attention skills
Round Table
The future of mobile payments
With mobile fast becoming the dominant channel, payments providers are can be fragmented and have a negative
under pressure to deliver fast solutions that meet the expectations of the affect on conversion. However, for those
famously impatient iGaming consumer. iGB Affiliate spoke to Ben West of that are optimised, the user experience can
Worldpay, Jon Prideaux of Boku and Rory Mudie of Redbox Mobile to be excellent, requiring significantly less
discuss how this is progressing. data entry than a typical card form –
a positive for fiddly touchscreens.
Roughly what share of digital can deliver an excellent mobile experience
payments are now being transacted which in turn encourages more play. This Jon Prideaux: There is a massive change
via mobile, and how does the is not to say that card payments through taking place and it is happening at an
gambling sector compare to mobile are completely frictionless yet. One astonishing place. Consumers are moving
others? When can we expect to of the largest barriers in a card payment towards the use of mobile devices, both
see mobile payments on a par with journey is 3D Secure, which can have smartphones and tablets. The world has
conventional methods?
“Some top-tier providers are seeing over 50%
Ben West: In the mobile gambling sector,
parity has been reached by some leading of their revenue delivered through their mobile
operators, especially when looking at digital
revenues. With the growth of mobile-only
channels. When comparing this to the UK
customers, some top-tier providers are ecommerce average of just 15%, it is clear that
seeing over 50% of their revenue delivered
through their mobile channels. When
the gambling sector is leading the charge in
comparing this to the UK ecommerce mobile revenue generation.”
average of just 15%, it is clear that the
gambling sector is leading the charge an impact on conversion. On a mobile long since passed peak PC. Those that
in mobile revenue generation. Payment device this effect is amplified due to the remain are mainly being used as work
trends typically mirror player betting/ lack of mobile optimisation, creating an devices, for leisure, consumers are using
gaming behaviour. The introduction of even larger blocker. For countries where mobile. The best data that I have shows
always-connected, mobile devices means Alternative Payment Methods (APMs) are that mobile devices account for about
players can play more often, wherever dominant there are similar challenges. a third of total sales, with desktop web
they are. In countries with established, Unlike card payments, where the operator basically flat and mobile growing faster
reliable connectivity, such as the UK, the can host the page and optimise the than tablets. On this trend, mobile will
opportunity has ramped up significantly. experience, the vast majority of APMs match desktop towards the end of this
Coupling this with the relatively simple require a redirect. Each APM provider is at year or early next. Some operators will
payment requirements (market dominated a different stage of mobile readiness. For undoubtedly be seeing more than half of
by cards and PayPal), gambling operators those that aren’t optimised, the experience their transaction on mobile already.
“Entering a card number, expiry date, CVV2 and a card number, expiry date, CVV2 and
your address on a smartphone is
your address on a smartphone is gruesome. And gruesome. And as for 3-D Secure?
as for 3-D Secure? If it’s a pain on the desktop, If it’s a pain on the desktop, it’s total
nightmare on a mobile. In my view, the
it’s total nightmare on a mobile.” only payment methods that will truly
get traction are those that can deliver a
Rory Mudie: I have no data about the trust and adoption of mobile payments simple one-tap solution, preferably without
proportion of payments going though due to the new interactions involved in having to register. Amazon and eBay
mobile and how gambling is different, the payment process. However, it could get a disproportionate share of mobile
but gambling is clearly a relatively high be argued that this challenge is not so commerce because they are able to use the
value sector. Most bookmakers are already present in the online world, especially in cards that they have on file to simplify the
reporting that between 30% and 50% of the gambling sector. consumer’s life. The same is true of Apple
their betting turnover is on mobile, so that Online/in-app mobile payments are with iTunes. Big gambling companies,
is worth hundreds of millions of pounds really an extension of eCommerce – a by definition, have a huge measure of
in bets per annum. At the moment, that is payment experience most digital gamblers consumer trust – storing card details to
almost completely done through debit and will be comfortable and familiar with. In enable convenient 1-Tap transactions may
credit cards. Very few alternative payment addition to this, customers who choose not be such a big deal for them, but smaller
methods are available on mobile sports to use APMs have already extended ones, without the brand recognition, may
betting sites. They only just have started their trust to this payment provider struggle to gain traction. My company is
to introduce systems such as Skrill and when they first enrolled in the payment one of those that helps to get consumers
Neteller on mobile. In mobile casino, the method. By offering recognised payment across the threshold by making that all
payment methods are also predominantly methods which require a redirect to a important first transaction really simple.
credit/debit card. Many will accept secure, familiar page, gaming operators You pay using the phone number, which
premium SMS for initial and subsequent may actually find an increased level of most of the time can be detected. You don’t
deposits, but then work to convert the confidence is given to their end users. have to register.
player to card deposits. Mobile casino is not It could even be argued that gaming
quite as big a deal as sports betting yet, but customers, by their nature, may be Rory Mudie: Trust is extremely important,
it has also started to grow fast. more receptive to new technology and and players are getting nervous about
experiences and are therefore not so entering credit card details on their phones,
The take-up of mobile payments apprehensive about trust. As long as they due to worries over security. Alternative
in gambling has long been seen as have enough trust in the operator’s brand, payment systems will have to be trusted,
inextricably tied to consumer trust. then making payments through their easy to use, quick and of no cost to the
Is this still the case, and if so, how mobile device might not be too much of a player. They will also have to be low cost
can the tipping point be achieved concern, especially those customers who to the betting operators to be attractive.
more quickly in terms of getting have migrated from the provider’s desktop Seamless integration with mobile apps and
more players to trust and embrace experience to their mobile channel. web-apps is also key, so that the user flow
the mobile channel? is not broken. This means that a mobile
Jon Prideaux: I don’t think that there are payment service will have to be deeply
Ben West: In a face-to-face world, there is any particular trust issues related to mobile integrated into the mobile solutions of the
a definitely a challenge around consumer - it’s a convenience issue. Entering gambling operators.
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Feature
Upon first hearing the rumour that publicly confidence (see Figure 1).
listed Amaya Gaming was acquiring
global giant Pokerstars, it would be fair to
say that most industry insiders thought to
themselves: “Oh God, please not another
insane story with no legs looking to
manipulate the stock market”.
It was Industrial Alliance Securities
analyst Neil Linsdell who first alerted
the world on May 20, issuing a report
Source: Eilers Research
stating that Amaya may be eager to “‘trade
up to a larger poker platform.” Noticing Figure 1 revenue streams to offer assurity of the
an odd run-up in Amaya’s share price With this transaction, Amaya has managed company’s ability to cover the interest
which coincided with Lindsdell’s report, to do something no online gaming company expense. Given online gaming’s fairly fluid
CalvinAyre.com’s Steven Stradbrooke has done before: instill enough confidence revenue and player base, this is the first
broke the news and went digging. What in numerous sizable financial institutions in time we have seen an acquisition, large or
the writers at CalvinAyre.com uncovered order to attract new capital into the sector. small, using debt as the primary source of
was more shocking then anyone could In 2006, I wrote an article for iGaming capital (see Figure 2).
have expected, their well-informed sources Business entitled Going Private, which
indicating that Amaya had an agreement highlighted why there was so little private
in place to acquire the giant Pokerstars. equity and hedge fund capital invested in
Following Amaya’s attempt to dispel the online gaming sector. Sure, a few names
the rumours, which failed to deny that have occasionally popped in support up
discussions could have transpired, two over the years, but overall, the online gaming
weeks of speculation ended on June 13, industry has suffered from a lack of capital
when it was finally confirmed that this for a variety of reasons. Amaya’s coup of
seemingly incredible rumour was in fact attracting several new large institutional
true. Amaya had, with a lot of help from investors to the online gambling sector
private equity and investment bankers, deserves to be seen as nothing less than Figure 2
garnered the capital to acquire the poker a stroke of genius. Blackstone Group, However, at a rate of 10% plus Libor, a
giant’s parent company Oldford Group for Deutsche Bank, Macquarie and Canaccord moderate decline in revenue going forward
an enormous $4.9bn in cash. have all been huge supporters of the could leave the combined giant in a tricky
land-based gaming sector, but it is rare spot as the company is currently just
The transaction that they have backed an online company, covering their interest expense if using last
So just how does a company with a particularly one with a controversial history. year’s combined EBITDA run rate.
market capitalisation of less than $1bn, Another aspect of this transaction
debt of $370m and cash on hand of only that makes it truly groundbreaking is the The valuation
$233m buy a company for $4.9bn? The use of debt, so rarely used for online The $4.9bn valuation, while at a slight
simple answer is debt – a lot of it - gaming transactions. The use of debt premium relative to its peers, seems to
coupled with a big dose of investor requires companies to offer fairly stable be very fairly priced. In 2013, Rational
36 | iGamingBusiness | Issue 87 | July/August 2014 1. EV or Enterprise Value is defined as Market Capitalization [Equity] plus Debt less Cash and EBITDA defined as Earnings Before Interest,
Taxes, Depreciation and Amortization is the best back of the envelope proxy for cash flow.
Feature
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Amaya-Stars:
a new world order?
Amaya has pulled off an audacious coup in convincing high-profile financial a stronger, larger market than dominate a
organisations to stump up $3.5bn to help it buy the world’s leading iGaming weaker, smaller market.
brand, but do its listed rivals really have that much to fear? Analyst Nick Batram If we look at the regulated online New
of Peel Hunt explains why there’s still much to play for. Jersey market, its performance thus far
has been anaemic. While payment
The proposed acquisition of PokerStars/ with enormous product potential beyond processing and geo-location issues have
Full Tilt by Amaya Gaming would not only poker. At just over 11x historical EBITDA, been blamed, could it be that it is lacking a
be the biggest deal the online gaming world the price for a leading global brand doesn’t brand of the scale of PokerStars? We have
has seen in financial terms, but it could also look overly expensive. no doubt that if PokerStars were in New
have seismic repercussions for the structure Turning to the US, there is a view that Jersey, the market would be bigger than it
of the industry as a whole. the banks would not have stumped up for is today. It may mean that the other
Before we dive into the main issues the the deal unless there was a considerable operators lose market share, but they may
transaction raises, let’s congratulate David confidence that PokerStars will be able to end up with a bigger business as a result. It
Baazov and his team for being on the verge enter the market, sooner rather than later. may also lead to fewer operators, but this
of pulling off such an audacious deal. We Competitors wishing to keep the brand will only be an acceleration of a process
haven’t spoken to a single investor, advisor out of the US will undoubtedly argue that that will ultimately happen anyway.
or competitor that hasn’t reacted in awe
at what Amaya is trying to do. Buying the “While unregulated earnings may have previously
world’s leading online gaming brand is one
thing; persuading high-profile financial frightened off the land-based casinos, Amaya’s
organisations as Blackstone, Barclays, deal may lead to a higher appetite for deal risk.”
Deutsche Bank and Macquarie to stump
up over $3.5bn in financing is an incredible simply changing the ownership doesn’t 888 has been able to grow its poker
achievement in its own right. address the fact that a significant proportion business in several markets, despite being
Ok, so down to the meat of the deal. of PokerStars’ value was created from its a distant second behind PokerStars. We
This transaction is happening because continued operation in the US post-UIGEA. would also argue that one reason 888
the world’s largest online gaming brand That is, any bad actor clause should apply has such a strong proposition in poker is
is finding it difficult to join the regulated as much to an asset as it does to a company. that PokerStars has set the bar so high (it
party in the US. It may also be happening However, whichever way your moral is often overlooked that other businesses
because, structurally, the poker market compass points, should other operators operated in the US post UIGEA; part of the
globally is under pressure, something that really fear PokerStars? reason PokerStars was so successful is that
will eventually catch up with PokerStars, We recently met an executive from a it has an awesome platform). Of course, not
even if it hasn’t thus far. The gamble is that European leisure group that has a dominant all operators have reacted as positively to
by breaking all ties with the past in terms position in several markets. When asked competition as 888, and this is likely to be
of ownership, PokerStars’ entrance into the about the threat from new competitors the case in the US as well.
regulated US market will then be expedited. entering these markets, he said he welcomed What the Amaya deal has done is create
David Baazov may argue that it isn’t much of this. From his experience, markets with two uncertainty for other operators, and markets
a gamble because, even if the US regulatory or three strong operators were almost always hate uncertainty. It is no coincidence that
door doesn’t open, he is acquiring a mega healthier than those with little competition. the share prices of 888 and bwin.party
brand, generating substantial cash flow, He would rather have a smaller share of have been hit hardest by the news of the
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Feature Interview
“You can see from our shareholder roster that we have many of the
big institutional names there, BlackRock, River & Mercantile, Standard
Life, Slater. They feel that the regulatory environment we work with is a
positive one, and not going towards some kind of prohibition.”
markets, for content and search, as well as the best interests of the investors, because this affect your ability to attract
for new territories. We are always happy they invested in us and not in an operator. significant institutional investment?
to look at successful affiliates with proven They believed in our business model, still First of all, this trend has been going on
businesses. We are looking also in different do, so we don’t want to become an operator. for a while. When we went on the road a
verticals, because historically we were But in closed markets - New Jersey springs few months ago, we met with a very wide
more focused in casino. Social gaming is to mind, or Belgium which has a very limited spectrum of institutional investors, and you
very interesting for us, we would also like amount of operators that are effectively tied can see from our shareholder roster that we
to expand our footprint in sports betting, down to the land based operators – these are have many of the big names there. We have
and of course poker, mainly for Europe, territories where we may be a little got BlackRock, River & Mercantile, Standard
but more with some kind of US upside, more flexible. Life, Slater and so on. They feel that the
as going forward we see the US being regulatory environment that we work with
predominantly being a poker market. We After a stellar opening which saw it is a positive one, and not going towards
are also looking into companies that offer rise to over 70p, the share price has some kind of prohibition. In addition, we are
very interesting media opportunities for us, fallen back of late. How would you proving our business in other territories as
particularly any company that does mainly explain this trajectory? well. We are
mobile and social advertising in a very First of all, there has been some early profit
good way. We are very active in these fields, taking, mainly the retail market. We are not
but we can always get better and we are seeing the sell down from our institutional
looking for companies with a unique edge investors. They are more long term investors.
in the media buying field. And of course, There was also big hype in the beginning,
technology companies. We mainly develop some articles that came out, and the stock
our campaign optimisation technology in did go up. Some were a little confused
house, but if somebody came along with regarding the expectations for the full
some unique tool or know-how we needed, year 13, even though it was a great year, a
we would look into it. record-breaking year in all aspects, and it
was exactly in line with analyst expectations.
XLMedia is also targeting “country 2014 is on track and going very well. I’m
specific joint ventures with very positive. I think people might have
operators”. How would these been a little more diligent with reading the
work and which markets are you admission document, and then they could
considering? have extrapolated quite easily. There is also
This is more relevant for our markets that a general tech sell-off going on. If you look
have been regulated already. We would at companies like Rockafeel, that really
look into, for example, maybe running took a hit in the last year, the Matomy Media
acquisition for a certain regulated operator, IPO that got cancelled at the last minute,
or doing some kind of joint venture white and a few others put theirs on hold. But
label with an operator in a market that is the core of what we do remains the same.
mainly closed. As a general rule of thumb, As long as we grow and expand our
we don’t want to alienate our clients by business, both in technology and in
becoming an operator, hence we are not revenue, as planned, we’re fine.
looking to buy any operators. With our
cash balances and position in the market, This business has been
there’s quite a few operators we cold have built on a dot.com model in
bought, but that would change the company markets such as Finland,
completely, and I think that will not serve Sweden and Norway. Will
iGamingBusiness
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iGamingBusiness
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Gaming Business
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Business
GamingBusiness
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Issue 8786|86|July/August
| Issue | May/June2014
May/June 2014|| 45
Feature Interviews
showing strong growth in German- verticals. Which do you feel offer the You are already working on a fixed-
speaking and English-speaking countries, most potential for XL? fee basis in New Jersey with 888 and
although obviously not the non-regulated Social gaming, because I wouldn’t even WSOP.com. When can we expect to
US, and we are deploying the business go as far as calling it a different vertical, see you licensed there?
model across other countries such as it’s basically a different product within Myself and a colleague met with the
Greece, and some others, of course only the gaming scene. I think financial spread Department of Gaming Enforcement in
with regulated operators. Denmark is a betting, CFDs, forex, binary options, these New Jersey, and they were happy to see
very interesting market for us, because kind of things are very relevant. We’ve done us, not because it was us specifically, but
it’s regulated, so we will be putting more and we still do tests in other fields as well, affiliates generally don’t come there to
focus on Denmark going forward as we’ve tried dating, we’ve done web hosting, meet them. We believe we will apply finally
well. So while our business model will be all kinds of products. The idea is not so for the casino ancillary service licence
slightly different with the various operators much to diversify but to keep some kind of quite soon, we have all the forms in place.
we work with and there may be slightly operational tension, to reconfirm this theory However, the listing changed the ownership
different methodologies in regulated that we can use our skills for other things. structure of the business significantly,
markets, it effectively stays the same, and And every time we do this, and reach an ROI so in the beginning, they wanted every
the need for the product that we deliver is positive and a sales gain, we can just scale shareholder holding above 3% to fill in the
still there. I would say in the regulated and this up or go back to gaming, and we always form, I told them, “Guys, I’m not going to go
saturated environment that this is even go back to gaming. This is where we see it to Blackrock, Mercantile, and ask them to
more the case, because the fight for market going forward in the near future. fill in your due diligence forms. They are
share becomes even more difficult when not an active partner in the business.” Then
you work within a regulatory environment Your admission document mentions we entered some kind of negotiation with
and have to pay more taxes. control of some 2,000 domains but the Department of Gaming Enforcement,
these were not made public. Why which is still going on, we are working with
Was your pull out from Turkey in was this? them on which executive needs to fill this in.
October of last year dictated by your First of all, we don’t want our business I think this will be resolved and quite soon,
imminent listing in London? to be measured by one site or another, and hopefully in a few months we will have
That was part of it, but I would say we would because our model is not based on this. If we the licence. We see New Jersey as the first
probably do that regardless of the listing, It were a company that operates just one site, or step in the door. We are also in discussions
was a strategic decision to focus on more five big sites, and all the revenue comes from about getting a licence in Nevada. If you
forward-facing markets. Turkey is probably those, that would be a very interesting and are licensed in Nevada and New Jersey, it
not gong anywhere positive. All of us, relevant KPI for our investors. But when we will be much easier for us going forward to
both founders and shareholders, we run a combination of many, many different get a licence in any other state. Of course,
value our freedom and want to be able sites with targeted media buys, what we do I think the fact we are a PLC does help
to travel anywhere(!). with each affiliate, each site, or even a group of our case. It’s much easier for an American
sites is not a relevant KPI. Second, if you look regulator to look and say, “Oh, they’re a
Ex-Ladbrokes CEO Chris Bell is your at 2,000 sites, not all of them are big 5,000- public company, I can find out anything
chairman. How did this come about, page sites. You have a lot of small support sites about them on the internet.”
and what particular attributes do you that play specific roles, to help the ranking
feel he brings to the table? and traffic driving, I don’t think this would Having been through the IPO, what
It’s a combination of being very add any more value to the analysis of potential advice would have for other affiliates
knowledgeable in the field and very up-to- investors. Plus, we are public now, so people considering this route?
date, even though he’s been with Ladbrokes know about us, they see our numbers, I think I’m happy that this succeeded because we
before 888 even existed. He’s very up to if we were to be too straightforward as to worked so hard, but also because I think this
date with trends, he knows what’s going what properties we own, you could imagine might open the door to similar companies
on, he has a lot of interesting questions there are trends of negative SEOs, using in our business. Affiliates, historically, have
which make us think. He also potentially questionable search engine tactics against been, shall I say, very camera shy. I think
introduces us to a lot of people, as he has other sites, so we would potentially have a lot many affiliates or marketing companies,
quite a few connections, so I think he’s a very to lose. So I don’t think it’s in our best interest in the gaming scope especially, do have the
good chairman to have on board. to be too straightforward about this. But the potential to go public or to become large
main reason remains the first one, that we established operations. If in some way
You have mentioned the applicability don’t want to be measured on one site, or a we helped some of them cross the barrier
of the business’ skill set to other specific cluster of sites. towards that, I would be very happy.
supported by
Mobile is
the future
for live dealer
Ian Dunning of EntwineTech explores the main factors driving the rapid number of mobile broadband connected
development of live dealer games on mobile devices for iGaming Business. devices has gone hand hand with the
growth in mobile betting and gaming.
One of the drivers of the current growth view high definition game play seamlessly Sports betting sites were the early
of live dealer and a massive opportunity and this experience is driving demand adopters, focusing on sports such as
for the future is the development of live for the product. Thirdly, the cost of high football with big in-play opportunities.
dealer solutions specifically for mobile. end smartphones in real terms has been However, casino and live dealer casino
This growth will be driven by a number falling to the point that a smartphone that product suppliers and operators quickly
of converging factors. Firstly, the recent can deliver a good live dealer experience followed, to the point some operators are
increase in the number of high-end
smartphones hitting the market has “A smartphone that can deliver a good live
changed the customer experience of live
dealer on mobile. Traditionally, live dealer dealer experience can be purchased for around
games have required more processing
power than what had previously been
$100, thus massively increasing the numbers of
available on mobile devices, however potential customers.”
now there are an increasing number of
smartphones hitting the market with a can be purchased for around $100, thus seeing up to 80% of their total revenues
high end processor and lots of RAM. A massively increasing the numbers of coming from games played on mobile
number of smartphones now possess potential customers. The potential can devices. The last 12 months have been
quad-core chips and up to 2GB or more be seen in the trends for broadband particularly impressive for the growth of
of RAM. As a consequence, the time connectivity. In 2005, there were 170m mobile betting, with many operators
has arrived when mobile devices have fixed device (PC) broadband connections, seeing a doubling or tripling of their
advanced enough to be able to handle the by 2015, this number is expected to reach mobile business. Mobile has become
workload imposed by these games. 550m. Compare these numbers to those such a significant part of the landscape
Secondly the user experience of live of mobile broadband-connected devices. that some start-ups are ditching web
dealer games has improved, caused In 2005, there were a negligible number completely and going straight to mobile.
predominantly by the increase in screen of mobile connected devices, by 2015 it While the availability of good
sizes of mobile phones and the roll out is estimated that there will be 2.1 billion broadband connectivity and the major
of 3G and 4G broadband. In particular, mobile devices connected to broadband. advances in hardware have played a big
4G networks now enable customers to In recent years, the growth in the part in the growth of mobile, another
www.evolutiongaming.com
AS REAL AS IT GETS
2014
Differentiate or die
Innovation is becoming a critical differentiator as the live dealer casino space to conform or be the first to play a new game,
matures, as Mathias Larsson of Ezugi explains. product marketing of new games shall be a
central differentiator of success.
There is no doubt that iGaming is a highly mobile browser. The casino customer and
competitive marketplace with maturing user experience is central to the engagement The gaming experience
markets and product offerings. So how and usage, and therefore must be different Many companies consider innovation and
can operators differentiate themselves in for different devices and platforms. It’s differentiation in regards to the physical hard
a homogeneous marketplace, when most therefore an omni-channel, multi product- product or the tangible process. However, live
of the products in that market are more or specific delivery that is required, as opposed gaming players just don’t buy a mobile phone
less the same, with perhaps just some minor to a one-size-fits-all approach. because it’s a mobile phone and they can play
differences in design or front end branding? the game. It’s what the phone can do for them
Live dealer casino games are a good UI innovation and likewise the game – it’s the experience,
example of the question. Firstly, technology Gaming consumers are uber tech savvy the engagement and how it makes you feel.
and continued investment by the telecoms customers looking for instant gaming Live dealer gaming allows players
companies in both super-fast fixed line and gratification, and if you can’t deliver it, they to confirm that the games are fair and
the mobile 4G networks and infrastructure shall find someone that can. Therefore, trustworthy, as you can see and interact with
has meant that the bandwidth to support in order to innovate and differentiate, the dealer, which is one of the reasons for the
the deployment of live casino products for live gaming solution providers need to rapid growth over RNG games. Live gaming
both desktop and mobile network is good meet these ever-changing user interfaces, is like watching your favourite television
enough in most markets today. preferences, product delivery pathways and show, you wish to be entertained. So I believe
Live casino gaming is being driven by experiences. In mobile for example, our user you need to enhance the gaming experience
voracious consumer demand and that of interface (UI) optimisation engineers have or entertainment delivery for the player.
the operators looking to keep pace with added functionalities including a swipe Therefore, live gaming providers such as
the needs of their gaming players. The feature that leverages the natural behaviour ourselves need to offer live gaming streams
popularity of live gaming for the player is of the human thumbs on both sides of from different exotic locations. So as against
the transparency, interaction and emotions, the mobile device, which the end user is just offering a stream from one studio, Ezugi
which replicate the live land-based casino already familiar with, which represents both is going to offer streams from different
environment for the player without leaving innovation and differentiation. studios and land-based casinos all around
the comfort of their home via their desktop the world, delivering a true global experience
computer or smartphone. However, as the Game innovation for both the players and the operators.
market and product adoption matures, The UI, as we have explored, is important both Of course, there shall be challenges ahead
players become more demanding. for innovation and differentiation, but the over the next 12-24 months. That is why
Innovation therefore becomes more of a key actual live game is what captures the hearts, we as a gaming solutions provider have
differentiator for the operators and their live minds and share of wallet for the operators. taken those requirements into account and
casino software providers, becoming critical It is therefore critical that operators partner have produced market-ready, feature-led
to driving the creation and execution of new with providers that are able to design, test and products for different devices, with gaming
products, services, and business processes. deploy new games and feature sets into the entertainment central to that process for
For example, most online casinos now market place on a regular basis. But access to innovation and differentiation.
offer live blackjack, live roulette, live exclusive live gaming content for geographical
baccarat, live sic bo and live dealer poker, market penetration can help make or break
Mathias Larsson holds a
which are pretty much the standard operators’ marketing acquisition or retention
Masters in Finance and is
product set deployed across desktop and programmes. This component shall become
an experienced technology
mobile devices. But that isn’t innovation or increasingly central as gaming in general entrepreneur. With management
differentiation, that’s merely making your becomes similar to fashion, whereby you’re roles in live casino gaming, digital
product accessible by delivery channel. In ‘hot’ one moment and ‘out’ the next. Coupled and product lifecycle marketing,
the mobile example, it is not good enough with the decreasing attention spans of he is Director of Business Development for Ezugi, the
innovative live casino dealer gaming system provider.
to merely offer a desktop version through a consumers, numerous distractions and desire
rt
repo g
ew in
A n iGam ss
by usine
B
Over the past three years the growth of mobile gambling has been
explosive and now forms a significant portion of all interactive revenues
for key European gambling operators, arguably led by the likes of
Paddy Power, William Hill and Betfair. Juniper Research released new
projections in early 2013 for the global mobile platform, anticipating
that by 2017 mobile turnover will reach $100 billion.
It is no longer a question of entering the mobile space, but rather how are
you mobilizing your business to push forward and create, rather than react
to, the opportunities the platform affords.
Key Features:
• Insight into the key players in the industry and which business models
are most successful
• An analysis of the different payment methods
• An overview of different devices and their target markets
• A look into the future of mobile development and how many are opting
for a hybrid of HTML5 and App development
• A breakdown of how to turn your company mobile
• Insight into the significant trends occurring in the mobile sector which
may have a profound effect on mobile gambling
• An in-depth look at the new mobile marketing techniques that are
available including affiliate marketing, app marketing, display, email,
location-based marketing, push marketing, search engines – PPC and
natural, SMS, social networks, video and Weve.
Ask for your free executive summary,
or to order the report, email
reports@iGamingBusiness.com or call
+44 (0) 207 954 3489 and quote 14FMobile1. www.iGamingBusiness.com
Feature
Seth Palansky, VP, Corporate Comms/ lion’s share of poker play throughout the Jamie Kerstetter, New Jersey
Editor-In-Chief, Caesars Interactive duration of the event. PartyPoker pro
Entertainment I’m not sure what numbers suggest of Regulated online poker in the US has had
We have branded the heck out of the WSOP how poker play was in the past when there an immense impact on me, allowing me
footprint of the Rio, created a bunch of were sites up and running that Americans to return from Mexico to make a living in
exciting promotions and enticements on played on, and if online traffic spiked or my home state of New Jersey. But even for
WSOP.com to try and attract folks…but time decreased during WSOP. recreational players, regulated online poker
will tell what the reaction is. We saw great With this being the 45th land-based will have a positive effect on them during
deposit numbers for WSOP.com on Day 1 WSOP, we are really excited about the the WSOP, regardless of if they play online
from players physically depositing at our opportunity to extend the brand online themselves. The player pool in NJ WPTs
cage at Rio, but I wouldn’t want to use one overtop of the WSOP this year. But we’re increased in size and decreased in strength
day of data to know. honestly not sure if the traffic conversion as many online qualifiers satellited in for a
The truth is that the WSOP is much more comes over the top of the event, or if the fraction of the buy in.
than the 65 WSOP gold bracelet events. We capturing of the player pool while they are The poker economy relies on new
also have 90-100 cash game tables running here ends up converting more year-round players getting into the game, enjoying their
daily, 24-hour satellites, plus thrice daily play for the remainder of the year. experience, and returning to try again even if
deep-stack tournaments that themselves We are very optimistic about online poker. unsuccessful at first. Online satellites allow
attract about 2,000 entries a day. So we see a We think it has a very bright future in the US these players to qualify cheaply for every
ton of poker play at the Rio. and are very encouraged thus far. event from $1ks to the $10k main event,
We’re confident that one way or another, We have a player support room dedicated giving normal people without million dollar
we’re well positioned and capturing the to WSOP.com on site, a live cage, a special bankrolls a chance at glory and huge prizes.
Bill Rini, head of online poker, as The $2 Million Stacked Summer. which allows players to get in on the online
WSOP.com On the tournament side, we kicked action during the WSOP dinner breaks.
We set out to offer a really compelling things off with a High Roller series of In addition to that, we bumped up our
promotional schedule for our first WSOP. tournaments the first week of the WSOP. first time deposit and reload bonuses to
It was important for us to showcase the site A week of higher buy-in ($200 + $15 up 100% up to $1,000 during the entire WSOP.
and demonstrate how the offline and online to $500 + $30) tournaments with a $50K Prior to the start of the WSOP we had
offerings could complement each other. guaranteed main event. already awarded over 100 WSOP bracelet
For instance, we’re running satellites Next week, we’ll kick off the WSOP event seats. We’re on pace to award at least
nearly every night into the next day’s offline Online Championship with $550K in 100 more during the WSOP as well. In fact,
event. The online satellites buy-ins start at guarantees. For two weeks we’ll be running we have a 25-seat guarantee on Day 1A of
$11 buy-ins which is much smaller than the tournaments in both Nevada and New the WSOP Main Event.
offline satellites so it brings the chance at a Jersey with a $200K guarantee main event. As far as pro sponsorships, we have great
WSOP bracelet to many players with We also have Sit&Go leaderboards relationships with the pro players. They love
more modest bankrolls. running throughout the WSOP as well the brand. We have WSOP bracelet winners
We’ve also loaded up with Sit&Go as a cash game promotion called Multi- and other notable pros playing on the site all
satellites for WSOP seats including a Table Madness that rewards players who the time. Not because we sponsor them, but
$5,000 + $100 heads-up satellite for a play multiple tables. because they’ve chosen to play with us.
WSOP Main Event seat. There’s also a Mini-Fest tournament As far as our competitors and their
The schedule we put out there seemed to series with smaller buy-in events, which sponsored pros go, we’re neutral on what
be well received. Both the poker media and starts up later in the WSOP schedule and a patch someone wears. I think we have a
the players commented that we hit all of the Last Chance Series for players who missed healthy rivalry but anything that’s good for
bases. Since we are guaranteeing over $2 their shot to return for the WSOP Main poker, overall, is good for us so we don’t
million in tournaments over the course of Event final table in November. draw any hard lines with other sites or
the WSOP, we branded our summer series Nightly we also offer a Dinner Break Turbo sponsored players.
Social Casino
Q1 update
Adam Krejcik of Eilers Research provides an overview of the social casino the top-10 list thanks to the strength of
gaming market, tracking market size, revenue estimates and market share for its mobile apps on Google Play Store (#2
all the major publishers. social casino publisher worldwide on
Google Play Store in Q1 2014).
Following results from the some of the social casino apps on iOS this quarter.
major publicly traded social casino game Greentube, part of the Austrian Top 5 social casino
publishers, as well as select data from Novomatic Group and which operates game publishers in Q1
some private companies, we estimate the Pharaoh’s Way, appears to have had a These were as follows:
global social casino game market grew by soft quarter, with mobile revenues 1. Caesars Interactive,
8.2% in the first quarter of 2014, driven by declining double-digits sequentially, 2. IGT/DoubleDown,
+1% quarter-on-quarter (q/q) growth on which we believe is due to increased 3. Zynga,
Facebook/Web. competition. Dragonplay also moved into 4. GSN/Bash, and
Facebook’s total web game business,
reported as ‘payment & other fees’,
declined 2% q/q in the period, while Figure 1 - Social Casino Game Publishers Market Share - 1Q14
mobile revenues increased 20% q/q,
driven by favorable secular growth
trends and growing popularity of the
social casino game genre. Caesars interactive
19%
Caesars Interactive Entertainment (CIE) Other
further distanced itself as the largest social 34%
casino game publisher worldwide, with an
estimated 19.1% market share, thanks in Double Down (owned by IGT)
part to its acquisition of Pacific Interactive. 11%
5. Big Fish Games. estimate mobile now accounts for 39% of prior estimate of $9.9 million. Social casino
These five companies accounted for just all IGT/DoubleDown gross revenues vs. 25% revenues were +500% in fiscal 1H14, and
over half of all the social casino revenues in the prior year period. ARPDAU was $0.21 overall and $0.32 for its
generated in Q1 2014, per our tracking. Zynga (social casino only) – We estimate top grossing app, Heart of Vegas. Aristocrat
total social casino revenues of $56.2 million; plans to launch its apps on mobile in 2H14.
Comparing Q1 actual Zynga reported Poker revenues of $31.7
results vs. estimates million ($45.3 million on “gross” basis). We Outlook
Every quarter we compare actual results were forecasting total gross social casino Following 1Q14 results we are maintaining
from publicly traded social casino game revenues of $65.9 million; upside was largely our industry forecast - we look for the
companies versus our preliminary estimates. driven by mobile as management noted global social casino game market to reach
Revenues are reported below are on a that Zynga Poker (mobile) users increased $2.6 billion (+31% y/y) in CY14 and exceed
gross basis. For Zynga, we include just +19% q/q. The addition of Hit it Rich Casino $3.3 billion (+26% y/y) by CY15. We expect
social casino game revenues (management (Facebook + mobile) and Riches of Olympus mobile/tablets to help drive the majority
provides actual revenues for Zynga Poker (mobile only) also helped drive social casino of growth given the favorable secular
and we estimate for other titles). revenue growth this quarter. trends. We also note the social casino
Caesars Interactive – Reported gross Williams Interactive – Reported gross game genre is relatively underpenetrated
revenue of $115.7 million vs. our estimate of social casino revenues of $27.3 million vs. our on mobile accounting for less than 10% of
$105 million. Upside was driven by greater- estimate of $29.8 million. MAUs and DAUs total mobile game revenues versus ~45%
than-expected contribution from Pacific were 4.9M and 1.3M, respectively, which were of Facebook game revenues. We also look
Interactive (we est. ~$8M for half quarter roughly in-line with our estimates; however for non-English speaking markets to enjoy
contribution – MAUs of 3M and DAUs of ARPDAU of $0.23 was below our $0.25 accelerated growth over the next few years.
770k in Q1 2014, per 10-Q). Also, estimate. The sequential decline in ARPDAU
improved monetization rates in was due to reduced marketing & promotional
Eilers Research, LLC is a boutique research
Slotomania and Bingo Blitz (ARPDAU activities and increasing contribution from
firm focused on servicing the gaming equipment,
increased 14% q/q) helped drive record mobile. Specifically, Jackpot Party Casino technology, and interactive gaming sectors within
revenues this quarter. continues to perform very well on Google the global gaming industry. In this article, we provide
IGT/DoubleDown – Reported Play Store; however monetization rates are highlights from our “Social Casino Tracker – 1Q14 ”,
gross revenues of $68.8 million vs. our lower relative to Facebook & iOS, causing a quarterly report, which is meant to serve as a useful
tool in determining the market size, revenue estimates,
estimate of $65.9 million. Upside was overall ARPU dilution.
and market share for the major social casino gaming
driven by +19% q/q mobile revenue Aristocrat (Product Madness) – Reported
publishers. We believe our methodology is unique as
growth vs. our estimate of +7% q/q. The gross social casino revenues of AUD$16.1 we extrapolate from public data and integrate it with our
upside on mobile was driven by million in fiscal first half of 2014 (ending own proprietary estimates. Note all revenue estimates
favorable industry trends and improved March 31, 2014), which translates into are presented on a “gross” basis (i.e. before platform
monetization rates for DoubleDown on US$15 million; we estimate US$9 million fees). For more information about our firm and services
please visit www.eilersresearch.com
iOS, especially on the iPad version. We was generated in calendar 1Q14 vs. our
The Index true regardless of what aspect of the sector prior to any seasonal correction from the warm
For the two-month period ending May 31, they operated in. The majority of the strong summer months or reduced poker activity
2014, the iGaming Index ended the period performing companies are either those resulting from the WSOP, which did not kick
down -3.8%, far underperforming the broader companies that typically perform well, such until late May. Any positive momentum right
markets with the S&P 500 and FTSE 100 as Net Entertainment, Optimal Payments now seems to be stemming from the potential
ending up 2.6% and 4.6%, respectively. Since and Playtech, or those fuelled by speculation, of new jurisdictions, including California and
the beginning of the year, the Index has ended such as Amaya (recently linked with Pennsylvania. California’s different interest
slightly down every two-month period, and PokerStars) or Ladbrokes (by the Playtech groups seem to be making solid process,
cumulatively is down over 10% since the relationship). In total, only 11 share prices though not without hiccups. While the various
beginning of the year. advanced, while 19 retreated. factions of tribes now seem to be in alignment,
The financial markets, and the US market With regard to those factors that impact the Morongo and its association with numerous
in particular, have remained incredibly overall Index, good financial news was hard card clubs seem to think that the “bad actor”
strong over the past couple of years, despite to find. It certainly did not emanate from New language, posed by a unified bill, is self-serving.
a mixed economy. While during the period Jersey, with April revenue actually decreasing One does have to question Morongo’s thinking
both Indexes hit all-time highs, the stocks to $11.4m from $11.8m in March. What is on this one… if San Manuel or Pechanga
for the iGaming Index did not. This held worrying is that this flattening of the market is actually thought PokerStars a viable option,
The original iGaming Index was launched on the 1st June 2004 with a base value of 1000. The Index aims to be the most comprehensive indicator and benchmark for the performance of the iGaming sector.
Playtech Limited PTEC LN $2,004.6 GBP 683.00 6.50 1.0% 836.50 575.00 81.6% 15.0%
Paddy Power PLC PLS DB $2,095.0 EUR 52.45 -5.05 -8.8% 67.95 51.29 77.2% 12.1%
William Hill PLC WMH LN $3,008.0 GBP 345.00 4.00 1.2% 494.50 320.30 69.8% 9.9%
Betfair Group PLC BET LN $1,057.2 GBP 1,007.00 -99.00 -9.0% 1,149.00 812.00 87.6% 7.9%
Bwin.Party Digital Entertainment PLC BPTY LN $978.6 GBP 119.50 -7.10 -5.6% 141.20 108.10 84.6% 7.3%
Betsson AB BETS'B SK $839.7 SEK 230.00 -5.50 -2.3% 247.00 160.00 93.1% 6.3%
Unibet Group PLC UNIB'SDB SK $810.2 SEK 318.50 -6.50 -2.0% 361.00 214.50 88.2% 6.0%
Perform Group PLC PER LN $728.2 GBP 277.00 32.00 13.1% 592.00 180.00 46.8% 5.4%
Optimal Payments PLC OPAY LN $624.9 GBP 387.25 26.21 7.3% 507.45 155.00 76.3% 4.7%
International Game Technology IGT NYSE $1,851.9 USD 12.55 -1.51 -10.7% 21.11 12.22 59.5% 3.7%
Net Entertainment NE AB NET'B SK $479.2 SEK 157.00 3.00 1.9% 164.00 91.75 95.7% 3.6%
888 Holdings PLC 888 LN $442.5 GBP 125.60 -25.10 -16.7% 174.50 124.50 72.0% 3.3%
Zynga Inc ZNGA NASDAQ $1,527.2 USD 3.45 -0.85 -19.8% 5.69 2.71 60.6% 2.4%
Caesars Entertainment CZR NASDAQ $1,570.0 USD 18.23 -0.78 -4.1% 26.47 12.46 68.9% 2.2%
GVC Holdings PLC GVC LN $279.4 GBP 456.50 83.00 22.2% 456.50 272.50 100.0% 2.1%
Churchill Downs Inc. CHDN NASDAQ $919.3 USD 86.17 -5.13 -5.6% 95.84 77.93 89.9% 1.9%
Amaya Gaming Group Inc. AYA V $572.7 CAD 11.46 4.01 53.8% 11.46 5.83 100.0% 1.8%
Ladbrokes PLC LAD LN $1,405.3 GBP 152.60 17.60 13.0% 217.50 129.20 70.2% 1.3%
Lottomatica (GTECH) GTK MI $2,861.7 EUR 20.18 -1.87 -8.5% 29.50 17.99 68.4% 0.6%
MGM Resorts International MGM NYSE $7,547.3 USD 25.75 -0.11 -0.4% 28.39 13.70 90.7% 0.6%
Game Account Network PLC GAME LN $56.4 GBP 102.50 -37.50 -26.8% 178.50 102.50 57.4% 0.4%
NetPlay TV PLC NPT LN $48.8 GBP 16.50 -2.88 -14.8% 23.75 14.88 69.5% 0.4%
32Red PLC TTR LN $42.5 GBP 59.00 -5.50 -8.5% 88.25 49.25 66.9% 0.3%
mybet Holding SE FXXN FF $25.0 EUR 1.27 0.25 25.0% 1.39 0.83 91.4% 0.2%
Scientific Games SGMS NYSE $456.1 USD 8.96 -4.77 -34.7% 19.03 8.96 47.1% 0.2%
Rank Group PLC RNK LN $627.0 GBP 160.50 2.40 1.5% 165.40 128.00 97.0% 0.2%
Bally Technologies Inc. BYI NYSE $1,384.3 USD 59.00 -7.27 -11.0% 82.67 54.83 71.4% 0.1%
Sportech PLC SPO LN $161.7 GBP 78.88 -9.12 -10.4% 99.00 78.50 79.7% 0.1%
Boyd Gaming Corp. BYD NYSE $708.9 USD 10.95 -2.25 -17.0% 14.48 9.20 75.6% 0.1%
Global Cash Access Holdings Inc. GCA NYSE $350.0 USD 8.90 2.04 29.7% 9.99 5.89 89.1% 0.0%
Note: iGaming Business is not licensed to give investment advice. The iGaming Index should not be relied upon as an indicator of the future performance of any company within the index or an indicator of the future performance of the sector.
All Share Price data and Market Capitalization reflected in local currency.
*Index weighting (1) adjusted to reflect exposure to online operations only and (2) all market capitalizations adjusted into US$ at end of the period.
wouldn’t they have approached the poker growth in the online gaming market in the in the wake of uncertainty and volatility by
giant long before this past spring? Regardless, US. These shares are in need of a boost, as vastly increasing their short positions on
the Morongo’s antics certainly don’t help they seem to continually lag in recent months Paddy Power and William Hill. Short sellers
move things forward in California, but it now relative to the broader market. at hedge funds borrow a security they expect
seems that’s business as usual in the Golden to fall so they can sell it now, buy back later at
State. Many others however think this is just a Index components a lower price, then pocket the difference after
temporary issue, and remain hopeful this will (decreasing order of contribution) returning the shares to the lender.
be resolved soon. Shares in Playtech (+1.0%) still remain quite According to Markit data, by early May,
While Pennsylvania has made significant volatile this period, once again. In the recent “interest from short sellers in several British
process, it is not without its issues. The State past, Playtech’s share price has continually betting firms has risen over the past two
has held several hearings in recent months experienced trading outside its support levels, months, with Ladbrokes shares on loan
to better assess the prospects of Internet both to the upside and downside. Factors climbing to more than 6% of the total available,
gambling. At the first hearing, held by the affecting the share price included numerous up from 4.7%, while William Hill’s shares on
House Democratic Policy Committee on additional potential taxes imposed by new loan have risen to 2.6% from 0.3%.”
May 1, the tone was a bit uncertain with and impending regulation, the one-time On May 1st, the DCMS issued a statement
OnlinePokerReport.com editor, Chris Grove, unexpected dividend, as well as the surprise that saw significant relief to the bookmaker
noticing a “lot more ‘ifs’ in the Pennsylvania announcement from Playtech Founder Teddy woes, with the restrictions on the bookmakers
hearing as opposed to ‘whens’ in the California Sagi that he was selling £326m of his shares. not as bad as initially thought. Most
hearing”. At a second hearing, hosted by the Playtech’s shares as a result, swung 20-25% importantly, there were no changes to what
Pennsylvania Senate Committee, the topic was each way in a matter of days. Throughout was potentially the worst-case scenario
specifically to address the revenue potential April, Playtech’s share price seemed to have of limiting the stakes and prizes on retail
for the state. All of the casino executives in stabilized, with the company completing the machines, keeping the current £100 max
the state spoke out in favor of the potential for month with very solid Q1 2014 earnings. stake on B2 machines. Rather, the statement
Internet gaming, calling it a necessity for the Revenues were up 17% quarter-over-quarter, focused on more sensible changes, including
preservation of revenue, with the increased fuelled mainly by 26% growth in casino. Asia planning consent changes (making it a
competition from Maryland and potential of was also a driver of Playtech’s growth, up 76%, requirement for change of class of a high street
New York. Well almost all of the executives dwarfing the 3% European revenue growth. shop from a bank, building society or estate
were in favor, one cannot forget Andy Abboud, Despite the better-than-expected earnings, agent to go through planning permission) and
the SVP of government relations at Las Vegas Playtech’s share price didn’t move. the need for those wishing to wager more than
Sands, and vocal puppet of Sheldon Adelson. Playtech’s share price demonstrated its £50 per stake to use account-based play or
He claimed that, without basis, the technology delicate state in mid-May, when it dropped load cash over the counter.
is “not there” to effectively regulate Internet over a 10% in a matter of two days, with no The speculation surrounding the DCMS
gambling. He urged caution regarding reported news to accompany the drop. One had been swirling for about a week prior to
poker-only legislation, calling it the “nose of could speculate that Playtech’s decision to pull the final announcement, with The Telegraph
the camel under the tent.” When asked by the out of Belgium could have triggered investor leaking the likely outcome the weekend
Republican state senator, Randy Vulakovich, fears, signaling that Belgium could be the first prior to the announcement. While this was a
why Las Vegas Sands’ position differed from of a number of countries that Playtech exits in significant victory for the bookmakers, from a
its fellow operators, Abboud called online its quest to act as the gateway into regulated share price perspective it was pretty much lost
gambling a “small market, small opportunity, markets. With little information from the on City speculators, whose uncovered short
but with tremendous liability.” One does have company, the brief tumble could also have positions could have gone very unprofitable if
to question Sands’ thinking here as well. If been the secondary effect stemming from the share prices had increased.
online gaming in Pennsylvania is too small for the departure of Paddy Power CEO Patrick And fall they did. The small correction
the big bad Macau operator, then why not just Kennedy, which occurred at precisely the same began on May 13th, which was also the day
divest all of your US assets and leave the rest of time as the sell-off. of Paddy Power’s Q1 2014 results. The results
us to get on with it. Obviously, it’s not too small Paddy Power (-8.8%) William Hill (+1.2%) were very positive with sports stakes up 20%,
for the rest of your peers. Self-serving hiccups and Ladbrokes (+13.0%). it was news of the departure of Paddy’s long-
seem to be the SNAFU of the industry. It is Over the several past months, UK Treasury time and well-respected CEO, Patrick
something that will require some getting used has launched a vicious attack on the UK Kennedy that may have ignited the mini-
to though it doesn’t make the process any more bookmakers, who face increased taxes on two correction. Within three days, Paddy Power
pleasant. It certainly is not doing wonders for fronts, as well as curbs on how they run their fell 14.4%. Ladbrokes and William Hill fell
the performance of the share prices of the high street betting shops. The grave situation 8.9% and 7.7% respectively, despite little news
publicly listed gaming companies, who seek has created a quite profitable situation for coming from both companies.
to participate and hopefully profit from the City hedge funds, which have prospered The growing interest of shares that are
shorted is a very public number amongst rationale in a detailed presentation made our Buy recommendation and 178p Target
City traders, and the increasing short sale of available to the public on the dedicated Price.” Morgan Stanley analyst, Vaughan
any company, let alone a sector, certainly acts website. bwin.party’s share recovered slightly Lewis, was equally bullish, citing 888 as the
an overhang on the share price. The news after the dip, when the company demonstrated real vehicle to get exposure to the US online
of the CEO departure was hardly a surprise. signs of compromising with the activist gaming market, given their early dominance in
However, when there is growing consensus shareholder, removing three of prior board all three states. Investors obviously didn’t agree.
that the share price drop is inevitable, members to pave way for a deal with Ader. After seeing its share price gain momentum
even the small piece of news can send the bwin.party’s share price also saw reprieve, over the past few months, Zynga (-19.8%)
markets spiraling, making the correction a as a result of the company’s executives being lost significant value post-Q1 2014 earnings.
self- fulfilling prophesy. While William Hill acquitted in France after ten long years of The company underperformed relative to
and Ladbrokes were able to recover from battle over charges they violated the legal estimates, generating Q1 revenue of $168m,
the mid-May correction, Paddy Power didn’t gambling monopolies in place in France down 36% from the corresponding period in
bounce back as quickly. This again may be between 2003 and 2005. 2013. Adjusted earnings came out at $13.8m,
attributable to the continuing media focus Optimal Payments (+7.3%) saw its share less than half of the $28.7m taken from
on Kennedy’s upcoming departure, with no price recover slightly after losing close to 30% Q1 last year. As part of the announcement,
obvious successor. of value in March. While this may seem like Zynga announced a large-scale management
Betfair (-9.0%) was not spared in the UK a big correction, it seems a mere hiccup when restructuring, which saw founder Mark Pincus
sell-off this period. With little new news from compared to the over 200% increase in the stepping down from his role as operational
the company, the major focus of attention this share price within the last 12 months. Optimal director. Zynga has struggled to build upon
period was Betfair’s sizable jump in revenue continues to protect its early stage lead in the hits like Farmville, Cityville and Words with
and market share in New Jersey. Although the US payments sector, launching their newly Friends. Recent games like Zombie Swipeout,
increase was off of a fairly low-based number, licensed Neteller eWallet in New Jersey with Slots and Matching with Friends, while well
the results were encouraging, with the market Borgata and Caesars. In May, Optimal offered made, have not proven as popular as previous
share doubling from 4.3% to 8.1%. Given the additional investor confidence at their AGM, titles. In addition, the decline in poker is too
difficulties of competing with an unknown stating that trading for fiscal year 2014 is great an event to be offset even by the best new
brand and no inherent database, the jump in “materially ahead of market expectations”. performing apps such as Hit It Rich!
market size puts Betfair back on the map for The bullish statement prompted Numis Amaya’s (+53.8%) share price surged
the fight for market share in the state. On the analyst Ivor Jones to revise forecasts upwards during the period, closing almost 100% up
other side of the pond, the company shared for 2014, citing management’s laudably on where it stood 12 months earlier. With the
little news this period. Analysts look to the June cautious outlook and a recently drifting share Index period ending before the Amaya-Stars
11 preliminary figures and guidance, expecting price as reason to purchase the stock. While deal was finally announced on 13th June,
the company to focus on cash preservation for Optimal’s share price has yet to break 510 this increase only represented the start of the
the upcoming months. pence since June 2006, Jones believes “the sustained run-up in the Canadian company’s
bwin.party (-5.6%) shares remained share price is materially out of step with the share price which began around 20th May,
fairly steady throughout April and halfway value of Optimal and reiterate our Buy rating coinciding with Industrial Alliance Securities
through May, before dropping close to 10% and 600p price target”. analyst Neil Linsdell’s issue of a note stating
on May 13, similar to that of the other online 888’s (-16.7% ) share price was unable to that Amaya may be eager to “‘trade up to a
gaming stocks. While the short position on retain its value, dropping-off in mid-May along larger poker platform.” Puzzled by the 33%
the stock remains at a medium rating, with the rest of the sector. At the beginning jump in share price from $7.71 to $10.25 in
according to Markit.com, it was also likely of the period, 888 announced solid Q1 2014 just four trading sessions and equally puzzled
the contentious battle between the company results, generating $113.8m revenue, up by the nearly five times spike in share trading
and its activist shareholder, Jason Ader that 11% year-on-year, and ahead of consensus volume on the Friday (May 23rd) following the
may have further ignited the sell-off. Ader, a estimates. While casino was again the star US Memorial (Bank) Day, and with no news
well-known former gaming analyst, performer, with a 14% increase in revenue to from the company capable of driving such an
took a position in the company in the $54.3m, it was bingo that stole the show, up 2% increase, CalvinAyre.com senior writer Steven
hopes of creating value for shareholders. year over year, demonstrating that 888, unlike Stradbrooke broke the news that “something
As discussions between the two groups many of its closest competitors, had stopped is clearly going on behind the scenes”, and
didn’t materialize as planned, Ader took a the downward spiral. According to analyst revealed that their well-informed sources
more public and aggressive route, Simon French of Panmure Gordon: “The stock had indicated that “an agreement is in place
launching the website Savebwinparty.com. trades on a 2014E EV/EBITDA of 10.3x, but that would see Amaya assume ownership of
In early May, tensions increased as Ader this still doesn’t adequately capture the group’s the Isle of Man-based online poker colossus,
made his intensions of appointing three strong trading momentum and attractive US thereby clearing the way for the Stars brand
board members known, outlaying his footprint, in our view. We therefore reiterate to return to regulated US markets.” Amaya’s
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attempts to dispel any rumours certainly didn’t the return of former CEO Richard Haddrill losing Caesars, GCA defied investor weariness,
deny that discussions could have taken place, at the helm, replacing long-time colleague announcing better-than-expected earnings,
and the stock continued to climb. The day of Ramesh Srinivasan. According to Deutsche prompting Deutsche Bank Analyst, Andrew
the announcement saw a 42% increase to a Bank Analyst Andrew Zarnett, “there will Zarnett, to issue a positive note titled, A Beat
record high of C$20 by the close in Toronto, an be considerable speculation around this then a Raise! outlining GCA’s potential upside,
almost doubling of the stock price in a week. move as it is sudden, surprising, and in a despite recent setbacks.
The two days leading up to the announcement way, somewhat confusing.” According to
also saw traded share volume spike up over Zarnett, in his prior tenure, “Mr. Haddrill Looking forward
double the previous seven-day session and did a tremendous job as the BYI CEO”. His In the US, we look to New Jersey signs of
share price, jumping 29% over the two-day departed in 2012, “for reasons we never felt growth, as the May figure didn’t pose well.
period. Clearly, there had been a bad leak from we truly understood, which now make even California and Pennsylvania remain near term
one of the many institutions participating in less sense in our view.” Analysts at Union hopes, as the summer sessions come to a close
the transaction. Gaming saw the shakeup as a much-needed in the next few months.
GameAccount Network (-26.8%) catalyst to ignite the challenged sector. Just
cannot seem to retain investor confidence, after the period completed, but before time of
despite announcing earnings this period that writing, Bally finally threw their hat in the ring
surpassed investor expectations. The company to finally join the rest of their major suppliers
share’s price starting dwindling down until in the social casino sector, acquiring Israeli-
April 22, when the company announced an Based Dragonplay for $100m in cash, working
increase in revenue of 123% year-over-year, capital and earn-out, totalling 5x EBITDA for
which sent the shares up 11%. The euphoria the social gaming company.
was short-lived, as the share began selling Global Cash Access (29.7%) fought back
shortly after. It is unclear as to why the lack of hard, after receiving the blow last period that
support to the share price, especially because they would be losing Caesars Entertainment
during the period Betfair, GameAccount’s as a client for a second time. GCA initially Melissa Blau has been in the
operating partner for real-money gaming lost Caesars back in December 2010 as the online gaming sector for eight
in New Jersey, announced a doubling of its payment processing arm for its casino floor. years as both an operator and
share of the local market. The company also Within a year, GCA then purchased the assets advisor. In her current capacity,
Melissa is an advisor focused on
announced the signing of Osage and Empire of MCA Processing, effectively buying back
bridging US and European interests.
City for its social gaming offering. They will 50% of the business. In March, however, the Through her consulting company,
join Foxwoods in offering a simulated gaming two parties once again severed ties when iGaming Capital, she has been advising mainly land-
product to their customers. GCA refused to accept Caesars’ new payment based companies in developing their online gaming
Bally Technologies’ (-11.0%) share price terms, demonstrating the business is still strategy as well as informally advising on M&A
opportunities and capital raising.
took a small hit on surprise news of another highly price sensitive. The result was negative
Melissablau@iGamingcapital.com.
senior management shuffle, which saw on GCA’s share price going into April. Despite
Upholding California’s
Competitive Edge
The amendments to California’s two proposed iPoker bills recently 2,657 jobs within five years as a result of an
recommended by 13 tribal leaders fly in the face of players’ rights and online poker market. And yet, if legislators
consumer fairness, argues John Pappas of the Poker Players Alliance. exclude the most preferred online poker
brand, the market will be smaller and so will
As the debate around regulating online The Morongo Band of Mission Indians, the revenues and jobs available to the state.
poker in California progresses into yet Commerce Club, the Hawaiian Gardens Players are equally concerned about a
another year, state legislators, consumer Casino and the Bicycle Casino from provision to penalize Californians playing on
advocates, poker players, casinos and tribal entering the marketplace. unlicensed websites. Though thousands of
leaders have all weighed in on how to Clearly not every online operator deserves Californians are playing poker on unregulated
implement important consumer protections a state license, which is why establishing a websites because the state does not currently
while ensuring the state can benefit from a formal licensing process is so important. But regulate it, they would prefer to have access
regulated online poker market. allowing businesses to write into the law to licensed operators. I believe players will
As an advocate for the game of poker which of their competitors should be excluded migrate to those licensed websites when they
and an avid player myself, it’s my job to before they are assessed by regulators is a are available as we have seen most recently in
provide the players’ perspective to ensure any clear political overreach and will only serve to New Jersey. However, penalizing players for
proposed online poker legislation provides a unnecessarily de-rail this multi-year debate. accessing unlicensed websites is short-sighted,
fair and safe environment for play. Recently, Only state regulators can effectively hold misdirected and will do nothing to address
13 tribal leaders sent a letter to the authors of potential licensees to the highest levels of the main issue of effectively keeping unlawful
two proposed California online poker bills, accountability and ethics, and for good operators out of the state.
state Senator Lou Correa and Assemblyman reason. Regulators are in the strongest Advancements that have led us into the
Reginald Jones-Sawyer, to offer their position to conduct a thorough vetting 21st Century have been bolstered by smart
recommended amendments. While it is of potential licensees and their business technologies and competition, most of
encouraging that all parties are engaging in partners, including an audit to ensure their which was born in the heart of California’s
the debate, there are specific provisions being technology protects the integrity of the game Silicon Valley. Allowing the state’s online
offered by these tribes that simply fly in the and against underage and problem gambling. poker market to be monopolized would only
face of players’ rights and consumer fairness. Regulators are also the most qualified to set stifle innovation and expose consumers to
At the top of the list is the so called “bad high standards to thwart fraud and abuse of the whims of a few controlling entities. It is
actor” provision, which essentially seeks customers, and enact regulations to prevent time our lawmakers in California embrace
to offer a competitive advantage to some money laundering and ensure tax compliance, the state’s innovative nature and take these
operators by precluding others from even among other standards. important steps toward advancing good
being considered for a license. Arbitrarily Furthermore, players from across the public policy for all residents.
based on the 2006 Unlawful Internet Gaming state have spoken very clearly that they
Enforcement Act (UIGEA) as a benchmark want PokerStars as part of the market. A
for suitability, the provision is not grounded recent Poker Players Alliance survey of
in the actual law. Therefore, these “bad our members found that more than 95 John Pappas is Executive
actor” guidelines are baseless as both the US percent wanted the opportunity to play on a Director of the Poker Players
Department of Justice and the United States PokerStars site or platform. Alliance (PPA). John has
been engaged in high-level
Court of Appeals for the Third Circuit have The truth is that competition motivates
policy and political consulting
offered opinions that UIGEA did not make any companies to improve their services and in Washington, DC. for the last
form of gaming illegal. meet the needs of their customers. Beyond 14 years. He is a regular commentator
Digging a little deeper, it is obvious that establishing a fair marketplace for players, for legal and legislative issues related to poker, and
the provision mainly seeks to exclude the the potential for economic growth in the state has appeared on FOX News, CNBC, MSNBC, CNN,
is estimated to be as high as $845 million in FOX Business and numerous local news programs to
popular online poker provider PokerStars
discuss and debate Internet gaming policy.
and its California-based partners including state revenue to California and an additional
networking
into
net worth
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Management & Marketing
US operators face
staffing challenges
While the slow start to US iGaming has restricted operators’ hiring budgets, in New Jersey, and have recently began
there are also other factors impairing their ability to recruit and structure or are in the process of hiring their No.1
interactive teams, writes Luke Cousins of Pentasia. interactive employees, in order for us
to be able to effectively analyse wider
With the regulated US market little built, for several reasons, the main ones recruitment trends in their companies.
more than 12 months old, the process of being the broader regulatory framework As for the European operators, which
structuring and hiring their interactive and geographical proximity to Europe. already have the product and iGaming
teams is still a work in progress for Here I will examine how these factors, experience in place, they have hired
licensed iGaming operators. amongst others, are affecting the hiring senior US nationals to give them local
For the majority of the US land-based and structuring of US iGaming businesses knowledge and an understanding of the
casino groups active in Nevada, New Jersey across five key areas: executive, marketing, US consumer market. These candidates
or Delaware, this is the first time they have operations, technical and product. have broadly been recruited from large
ever had to build interactive teams, whilst US media and marketing companies,
for European operators, they are grappling Executive and from amongst the few US nationals
for the first time with having to build US The ‘No.1’ hires of the US and European with experience of regulated US real-
entities in line with regulatory frameworks operators demonstrate the biggest money and social gaming. It has
and their respective US strategies. difference between their respective proven valuable for these candidates to
There are however two underlying requirements. The US casinos have understand and have connections to
factors at work which are making it undertaken lengthy executive search media and marketing agencies, to assist
challenging for both US casinos and processes to attract the top European their initial marketing strategy.
European operators to hire the required iGaming talent, because their organisations Across both sections of the industry,
talent and structure their interactive lack that previous experience in the we have seen a large number of
businesses on the ground in the US. The industry. These candidates have been consultants used to manage strategy until
first, and main, issue is that with the vast sourced from the leading brands and these hires are in place, mainly to help
majority of existing talent in the regulated from C-level positions, having had guide the hiring process and manage
iGaming Industry being based over in previous experience of managing large ongoing vendor selection discussions.
Europe, visa restrictions have created a P+L responsibilities on behalf of
log-jam in bringing experienced candidates European iGaming businesses. The Marketing
to the new market. Secondly, US nationals successful candidates have come Marketing has seen the most hiring
have been slow to join a new and still small from strong marketing and product activity of any area in the developing US
industry which is not really in the public backgrounds, to ensure their company’s iGaming sector. With product being the
eye outside of New Jersey, where only a strategy is being realized across both responsibility of the product partners
small percentage of hired talent currently divisions. It’s worth bearing in mind here and currently being relatively similar
resides. It is in New Jersey where the vast that five large US casino groups building across the licensed operators, the battle
majority of interactive teams are being interactive divisions are yet to launch for market share is currently based on the
marketing strategies being undertaken by Operations There are however signs of recent
the various operators. All licensed operators are required to development in these areas, and we
For European operators, the hiring have certain number of operational staff have recently experienced the leading
strategy reflects the level of marketing on the ground in New Jersey in line with companies initiating searches for project/
responsibilities they are transferring from the regulation. This involves Fraud and client service managers to take ownership
Europe to the US, which is still a gradual Risk teams as well as a compliance officer. of the third-party relationships to manage
process. The majority of companies now The size of teams varies depending on the multiple product integrations, whilst
have their VP Marketing in place, who has the volume of depositing players being also ensuring they receive the most
assumed responsibility for building a team. generated by the business. The largest teams competitive commercial agreements. Once
This has however happened at a slower can have up to 25 people, the smallest being in place, they will assume responsibility for
pace than these companies previously five. Companies have varying timelines to get detailed competitor analysis.
forecast, reflecting the slow growth of these people in place depending on when The recruitment landscape in the US,
the regulated market. Eventually, these they received the licence and how much and specifically New Jersey, will continue to
companies plan to have marketing teams in traffic they are generating. These candidates reflect the growth of the market, and with
place including specialists in the following have generally come from retail banking other States presumed to regulate in the
areas: acquisition, campaign management, backgrounds, and are a mixture of near future, greater opportunities will be
affiliates, media, product, retention, VIP, Spanish and English speakers. provided for candidates to enter this new
brand, digital, social media, analysts Many operators are still using and exciting market.
and PR, as well as teams of executives in customer service teams through
support of these roles. However, due to partnered businesses, whilst they build
hiring budgets being limited by the slow their own operations. We see this being
growth of the New Jersey market, marketing a high level of focus for companies at the
teams for the launched operators currently end of 2014, as following the launch of
consist of between 2 – 12 employees. the products and having achieved a level
However, this is increasing each month. of comfort with their marketing structure,
The US operators have to date been they will want to bring more operational
more cautious with their marketing hires, control in house.
and currently have the VP Marketing in
place with very few hires underneath them, Technical and product
supported by other resources from vendors, These areas have received the least
consultants, European partners and their attention so far in New Jersey. Operators Luke Cousins is Principal
Consultant for Pentasia (U.S.)
existing land based talent. This situation currently have limited product offerings in
Inc. He joined Pentasia in
will however develop as they gain more place as suppliers deliver their interactive October 2008, having spent
confidence in the market and have a larger products under their guidance, therefore the last two years successfully
pool of consumers to approach. When they apart from the required IT Security staff recruiting for the senior finance market
do expand further, their teams will follow a of one or two people in the AC Casinos with Michael Page International. A graduate of Brunel
similar size and structure to that previously University, Luke is responsible for placing personnel
managing the server requirements, there
into the iGaming and E-Payments industries.
outlined for the European operators. has been very limited hiring.
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ALDERNEY
Type of Company Entity Available for Category 2: B2B Licence Restrictions on Jurisdictions from
iGaming Firms (resident and non-resident): which you can take Wagers
Limited companies. Carry a fixed annual fee of £35,000. There are no restrictions.
Associate certificates (typically for key
Corporation Tax Rate software suppliers) carry a fixed annual fee
0%. of £10,000. Temporary use licenses (typically Contact Details of Government
for disaster recovery purposes) carry a fixed Department or Regulator
Additional Gaming Tax Rate annual fee of £10,000. Robin Le Prevost
No additional taxes. Director of E-Commerce Development
Licence Duration States of Alderney
Minimum Share Capital for an 12 months (rolling). PO Box 1015, St Anne’s
iGaming Company Alderney
£2.00. Do Local Banks Process Online Gaming British Channel Islands
Transactions? GY9 3HT
Security Requirements/Indemnity and Yes. T: +44 [0] 207 993 8564
Ring Fenced Protection for Player M: +44 [0] 7781 109 809
Deposits Bandwidth Type Available
A variety of mechanisms are acceptable All types of bandwidth are available from a
commensurate with the business plan and variety of suppliers.
commercial performance of the operator.
Software Testing Requirements
Licence Fee Yes, Technical standards are published
Category 1: B2C Licence: by the Alderney Gambling Control
The licence fees are based on annualised Commission (AGCC).
Net Gaming Yield (NGY), as follows:
• NGY up to £1m - annual fee £35,000 Reporting Requirements to the
• NGY of £1m to £5m - annual fee of Gaming Regulators and/or Financial
£70,000 Regulator
• NGY of £5m to £7.5m - annual fee of Periodic financial reports are required.
£100,000
• NGY in excess of £7.5m - annual fee of Anti-Money Laundering Policy for
£140,000 iGaming Firms
(In the first year of operation the licence fee is All operators must comply with the AML
£35,000, irrespective of NGY). legislation in force.
Alderney.
The IT, B2B and
support service hub at
the heart of Europe.
World leading regulation offering a perfect environment from which to offer
eGambling IT services into all major regulated markets. Technical capability without
limits combined with a supportive government and a world class leading commercial
environment. Alderney is the leading choice for the world’s eGambling industry.
PO Box 1015, Alderney, British Channel Islands, United Kingdom GY9 3HT
Phone: +44 (0)2079 938 564 Mobile: +44 (0)7781 109 809
Email: info@alderneygambling.com
TEAM
States of Alderney
HOSTING, TELECOMMUNICATIONS & TECHNICAL
Sure International, Continent8, C5 Alliance, JT, Long Port
LEGAL, FIDUCIARY, RELOCATION & CONSULTANCY
Carey Group, Collas Crill, Fort Group
Jurisdictions
Jurisdictions
2014
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GIBRALTAR
Located at the southernmost tip of Europe, Licensed Operators Gambling Activities
Gibraltar currently licences operators Ladbrokes (International) Plc Fixed-odds
under the Gambling Act 2005. Gibraltar Ladbrokes Sportsbook LP Casino
Fixed-odds
began offering licenses to online gaming
Victor Chandler (International) Ltd Fixed-odds
companies in the mid-to-late 90s. Currently, Casino
the country licences online sportsbooks, Stan James Plc Fixed-odds
online casinos, and online betting exchanges Casino
as well as land-based casinos (Gala Casino). bwin.party digital entertainment Plc Fixed-odds
Casino
Gibraltar primarily licences operators
Spielo International (Gibraltar) Ltd Casino
with a proven track record and those who 32 Red Plc Casino
establish a bricks-and-mortar presence in Fixed-odds
Gibraltar, all of which requires an extensive Digibet Ltd Casino
vetting and due diligence process. For Fixed-odds
Cassava Enterprises (Gibraltar) Ltd (888.com Plc) Casino
fixed-odds betting operations, gaming tax is
Fixed-odds
currently levied as from April 1, 2005, at one Mansion Online Casino Ltd Casino
percent of the turnover up to £42,500,000 of Onisac Limited Casino
annual turnover with the gaming tax capped Prospreads Limited (formerly FuturesBetting.com Ltd) Financial Spread Betting
at £425,000 per annum, with a minimum WHG (International) Ltd Casino
WHG (International) Ltd Fixed-odds
annual tax payable of £85,000.
Hillside (Gibraltar) Ltd (Bet365 Group Ltd) Casino
Betting exchanges are currently taxed on Petfre (Gibraltar) Ltd (Betfred) Fixed-odds
the same basis as fixed-odds operations. Casino
For Internet casinos, gaming tax is currently Gamesys (Gibraltar) Ltd (Entertaining Play Ltd) Casino
levied at one percent of the gaming yield or Approved Betting Products
Probability (Gibraltar) Ltd Casino
gross profit. The maximum and minimum
TSE (Gibraltar) LP (Betfair Group) Betting exchange
cap is the same as for fixed-odds betting. Casino
tombola (International) Plc
Nektan (Gibraltar) Ltd Casino
BetClic Everest (Gibraltar) Ltd Casino
Fixed-odds
Address IGT (Gibraltar) Ltd Casino (B2B)
The Gambling Division Gala Interactive (Gibraltar) Ltd Casino
HM Government of Gibraltar Coral Interactive (Gibraltar) Ltd Fixed-odds
Ministry of Education, Financial Services, Bally Technologies (Gibraltar) Ltd Casino (B2B)
Gaming, Telecommunications and Justice (incorporated SHFL RGL No. 61)
Ongame Network Ltd (Amaya Inc Group) Casino
Suite 771, Block 7, 7th Floor, Europort
EU Lotto Ltd Fixed-odds
GX11 1AA, Gibraltar
Odobo Ltd Casino (B2B)
T: 00350 20064142 Scientific Games (Gibraltar) Ltd Casino (B2B)
F: 00350 20064150 (incorporated WMS RGL No. 068)
E-mail: gamblingcommissioner@gibraltar.gov.gi Realistic Games (Gibraltar) Ltd Casino (B2B)
https://www.gibraltar.gov.gi/remotegambling NE Services Ltd (NetEnt) Casino (B2B)
t
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A re aming
iG s
by sines
Bu
Key Features:
• Global betting market overviews by region
• Strategies into areas of opportunity: how you can expand and grow
• Important factors affecting growth in the industry and how to avoid
the pitfalls
• Discover the marketing strategies of online and mobile sportsbooks
• Regulatory issues and the growing role of smartphones and how it’s
affecting sports betting offerings
• Social media and in-play betting
The report will also feature commentary from leading executives in the
digital gaming industry who provide their own expert views on what
is next for sports betting. It will provide case studies of major digital
sportsbook operators, betting exchanges and suppliers and determines
who the winners and losers will be.
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ISLE OF MAN
Type of Company Entity Available for Licence Duration Reporting Requirements to the Gaming
iGaming Firms Five years then renewal is required. Regulators and/or Financial Regulator
An Isle of Man company must be incorporated Access to the business, its systems and
in the Isle of Man in order to be licensed. Licence Fee audited accounts when requested by the
Initial application and 5 year renewal Gambling Supervision Commissioners.
Corporation Tax Rate fee £5,000.
0%. Standard online licence annual fee £35,000. Anti-Money Laundering (AML) Policy
Sub-licence annual fee £5,000. for iGaming Firms
Additional Gaming Tax Rate Network services licence annual fee In line with international standards for
Duty payable on retained gross profits: £50,000. money laundering and terrorist financing,
• Duty payable on retained gross profits: all online gambling licence holder must
• For gross gaming yield not exceeding £20 Licence Application Timescale adhere to the Money Laundering and
million per annum: 1.5% Within 12 weeks of receipt of application Terrorist Financing (Online Gambling)
• For gross gaming yield of more than £20 Code 2013. Guidance notes can be
million per annum, but not exceeding £40 Operational Requirements found on the Gambling Supervision
million per annum: 0.5% 2 x local Directors, MLRO & Designated Commissioner webiste.
• For gross gaming yield exceeding £40 Official (all these can be supplied by local
million per annum: 0.1% CSPs) Restrictions on Jurisdictions from
The exception is football pools which Banking performed in IOM which you can take Wagers
carries a 15% duty rate. Players registered on IOM servers It is the responsibility of the operator
to make these decisions, however; the
Minimum Share Capital for an Do Local Banks Process Online Gambling Supervision Commissioners may
iGaming Company Gaming Transactions? ask for confirmation that independent legal
By discussion as part of licence Yes. advice has been taken if they have a concern
application process. about a specific target market.
Bandwidth Type Available
Security Requirements/Indemnity Private Circuit and MPLS connectivity
for Players Deposits solutions are available and provided over
Operator must demonstrate full protection two resilient fibre optic rings and one
of player funds. Legislation ensures a point-to-point cable. Details of Government
separate account for player funds will Department or Regulator
legally protect them. Software Testing Requirements Steve Brennan, CEO, Gambling
Certificate from an approved testing Supervision Commission
Licence Categories house is required as part of the licence E: gaming@gov.im
All products (sportsbook, casino, p2p etc) fit application process. Details can be T: +44 (0)1624 694331
under one licence, no additional classes of obtained from the Gambling Supervision W: www.whereyoucan.com/egaming
licence required Commission.
JU
RI N
S
S DICT IO
MALTA
Type of Company Entity Available for require that player funds are held
iGaming Firm Remote separately in a Client’s Account. The LGA Contact Details of Government
Gaming Companies in Malta are regulated monitors the Accounts monthly and Department or Regulator
by the Remote Gaming Regulations, 2004 reviews bank statements to ensure that the Lotteries and Gaming Authority
(LN176/2004) under the Lotteries and funds are covered. Suite 1, Level 3, TG Complex, Brewery
Other Games Act, 2001 (LOGA). Licensees Street,
are classified according to the manner they Licence Fee Mriehel, BKR 3000 Malta
assume game risk. €8,500 annually. W: www.lga.org.mt
E: info@lga.org.mt
Corporation Tax Rate Licence Duration T: +356 2546 9000
35% tax on companies with certain Five years, this is renewable thereafter. F: + 356 21 316 599
rebate claims.
Do Local Banks Process Online
Additional Gaming Tax Rate Gaming Transactions?
Class 1: €4,658 per month for the first six Yes.
months since the ‘go live’ date, and €6,988
per month thereafter. Bandwidth Type Available
Class 2: 0.5% on gross amount of stakes Multi-fibre links connected to various
accepted. international carriers at Gigabit capacities
Class 3: 5% on real income. such as Cable and Wireless, Telecom Italia
Class 4: Exempted from tax for the first six and Interoute.
months, €2,329 per month for the next six
months and then pay €4,658 per month for Software Testing Requirements
the full duration of the licence. RNG test certificate and adequate systems
Class 1 on 4: €1,165 per month since the review processing. A certifier is appointed
‘go live’ date. by the LGA to audit the process before
The maximum gaming tax payable annually granting a licence.
by one licensee shall not exceed €466,000.
Reporting Requirements to the Gaming
Minimum Share Capital for an Regulators and/or Financial Regulator
iGaming Company Bi-annual Accounts, Incident Reports,
Classes 1 & 2: €100,000. Classes 3 & 4: Monthly Players’ Balances, Clients Funds’
€40,000 The Minimum Share Capital bank statements and Decommissioning of
must be issued and fully paid up. gaming and control systems equipment.
The Malta Remote Gaming Council’s The Malta Remote Gaming Council The Council’s goal is to serve as an
main strategic objective is to create is made up of all stakeholders in the ongoing discussion forum giving
a dynamic regulatory environment remote gaming industry including valuable feedback to the Authority
for Remote Gaming. The Council licensed operators, data carriers, on points raised by the stakeholders
was launched in March 2005 and Internet service providers, lawyers enabling it to keep abreast with the
has operated successfully since. and professional services providers. latest developments in the industry.
H2 forecasts:
Along with California, New York and Pennsylvania are seen as the next viable intrastate markets in the US. With
iGaming bills in play in both, iGaming Business’ data partner H2 Gambling Capital provides exclusive data and
forecasts based on their current proposals.
New York
NY Senator John Bonacic’s poker-only Delaware and Nevada, applicants would
Washington Times he didn’t intend to
“push it” this year, he said he hoped the
bill would kickstart the conversation
among New York legislators on iGaming.
S6913, introduced in March, proposes not need to hold an existing gaming or Based on this 15% GGR tax scenario, H2
the issue of up to ten licences of ten-year racing licence in the state. H2’s revenue projects that New York state could
duration for a one-off fee of $10m. A near data and forecasts are based on the generate $361m in online poker revenues
identical companion bill was subsequently proposed 15% tax on licensed operators’ in Year 1 post-licensing, rising to $494m
introduced in the Assembly by Gary J. online poker GGR contained within the and11.3% of the state’s gambling market
Pretlow in May. Unlike in New Jersey, two bills. While Bonacic since told the by 2018.
New York Interactive Gambling Gross Win (US$m) New York State % of Gross Win Interactive
12%
1000 11.3%
10.1% 10.8%
900 10% 9.5%
8.8%
800
700 8% 7.1% 7.3%
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013E
2014E
2015E
2016E
2017E
2018E
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014E
2015E
2016E
2017E
2018E
Offshore Onshore
New York State Onshore Interactive Gambling New York State Average iPoker Gross Win per Adult 2016 (US$)
Gross Win (US$m)
800
25
700 22.84
600 20
500 494
15
437
400 12.25
361
300 10
8.13 7.59 7.25
5.93
200
103 107 196 210 225
98 3.13
66 82 92 5
100
0
0
2010
2011
2012
2013
2014
2015E
2016E
2017E
2018E
New York State United Kingdom Italy Denmark France EU28 Spain
Pennsylvania
In Pennsylvania, which recently held two Each would pay $5m for their license and pay
complement existing casino stakeholders’
gaming businesses, as well as its wider
impacts, is now fully underway. Based on a
14% GGR tax scenario. H2 projects that GGR
legislative hearings (see p13) with a focus on 14% of gross gaming revenues. from online poker could reach $129m in
iGaming, Senator Edwin Erickson is poised While the bill’s chances of passage this Year 1 post-legalization, growing to $176m
to introduce SB 1386, providing for the issue year are slim, the conversation among and 5.1% of Pennsylvania’s total gambling
of licences to land-based casinos in the state. legislators over how iGaming could gross win by 2018.
Pennsylvania Interactive Gambling Gross Win (US$m) Pennsylvania % of Gross Win Interactive
3000 14%
12.2%
12.1%
12%
250
9.7%
206 10%
200 182
7.2%
176
150 152 152 156 8%
140 6.8%
150 138 129
6% 5.0% 5.1%
105 92 4.9%
97 97 4.6% 4.4%
100 94 94 4.2%
4%
2.4%
2.1% 2.0% 2.0%
50 1.9%
90 88 84
2%
0
0%
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013E
2014E
2015E
2016E
2017E
2018E
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014E
2015E
2016E
2017E
2018E
Offshore Onshore (iPoker 14% GWT)
12.25
11.42
12
10
8.13
8 7.59
7.25
6
5.93 All information courtesy of H2 Gambling Capital,
June 2014. H2 is universally regarded as the industry
4
standard for data regarding all aspects of the global
3.13
gambling industry. H2 has worked with or supplied
2
information to over 700 organizations over the past
decade and offers the most complete one stop
0 iGaming/land-based market data service. For further
Pennsylvania United Kingdom Italy Denmark France EU28 Spain details or access to H2’s subscription service/US
NB. Taxation in all the European Nations is higher, poker has less tradtion and is one of a number of interactive gambling products
state-by-state forecasts, email: data@h2gc.com.
California
the numbers
With several bills in play, Michael Genest of Capitol Matrix Consulting (GBGC) while LECG’s were “derived from”
analyzes the considerable fiscal and economic benefits of intrastate poker estimates provided by H2 Gaming Capital. 1
to the US’ most populous state. These are the two leading firms worldwide
that track and project the activity of Internet
We estimate that legalizing internet studies have produced a substantial range gaming sites. While Blue Sky relied on
intrastate poker in California as proposed by of estimates regarding the volume of play, GBGC for some per-player dollar figures,
SB 51 and SB 678 would result in additional the revenue to be generated by a tax on they also used the results of direct surveys
state revenues over the first five years of GGR and by the increased economic activity of Californians to project the numbers
$845 million. In 2015, it would also increase generated by the legalized sites. of players.2 Each of these approaches is
California’s total economic output by $334 reasonable and the range of projections they
million and add 1,952 jobs, with annual Offshore play estimates provide simply reflects the fact that there
amounts growing in subsequent years. Our The estimates of the volume of play on will always be significant uncertainty in
estimate is based in part on our review of offshore sites vary significantly for several estimating the volume of any illegal activity.
previous estimates of proposals to legalize reasons. Genest Consulting (the precursor Moreover, as LECG stated in its report:
internet poker in California, and in part on to Capitol Matrix) and Blue Sky both used “a strong case can be made that a legal
new data provided by industry experts that projections for offshore GGR in 2011, while California system will be able to recapture
takes into account changes in the illegal LECG used projections for 2012. Genest much of this activity, but until the system is
internet poker market since Black Friday in Consulting’s projections were provided in place, the ultimate share of business that
April 2011. by Global Betting & Gaming Consultants returns to California is unknown.”
bills stipulate that operators of such sites Proposed Market Structure for Legalized One monopoly site Up to 3 Hubs Not Specified Not Specified
Intrastate Sites multiple sites
must maintain the physical plant and the
Estimated First-year GGR of proposed, < $50 m $370 m to $704 m $452 m $624 m
employees inside the state and serve only legalized, intrastate site
players located within the state’s boundaries. Proposed GGR Tax Rate 10.0% 20.0% 10.0% 10.0%
Previous estimates of Internet poker volume Other State Revenues Minimal $130 m to $256 m $36.3 m $54.2 m
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Estimating GGR and gaming tax revenues in retention and thereby seriously reduce the and correctly assumed that higher tax rates
a legal intrastate market volume of play. would result in lower GGR levels, in part
Players in a newly legalized market would • Blue Sky’s first report relied on surveys because they would make it more difficult
be of two types, those switching from the of Californians to determine the recapture for firms to invest in player recruitment and
illegal, offshore market and those who rate. While this has the advantage of being retention, which is both costly and necessary
begin playing Internet poker only after it is California specific, a survey-based estimate to maximize the volume of play. H2 advises
legalized.3 The LECG study indicates that the should be viewed with caution. It is unclear us that a tax rate of 10 percent would not
former would be serious players, gambling how honestly respondents would answer create a significant disincentive, but rates
more money over longer times, while the a question that, in essence, asks whether much higher than that level would tend to
latter would be casual. Each they would cease playing illegally if a legal have significantly deleterious effects on the
study used a different approach to alternative were available. In addition, volume of play in the market.
estimating the “recapture rate” of those Blue Sky’s reports did not analyze a
playing on offshore sites: specific proposal, so a key condition of Estimating other state revenues
• Genest Consulting assumed that there creating a strong poker market, competition, Legalizing intrastate internet poker would
would be only minimal transfer from is not addressed. create, at least in theory, four other sources
offshore sites for two reasons. First, the • Blue Sky’s second report came a month of increased revenue to the state beyond the
specific proposal analyzed called for a after Black Friday. While the exact impact of tax on internet gaming itself: (1) corporate
one-site monopoly. Industry experts advised Black Friday was not yet known at that time, profit taxes on the companies operating
Genest Consulting that such a monopolistic Blue Sky correctly assumed that the closure the legal sites, (2) personal income tax on
site would not have succeeded in attracting of the three largest offshore sites would players’ winnings, (3) personal income tax
customers away from the established shift far more play into a legalized market. on the earnings of employees working on
offshore sites in the pre-Black Friday Accordingly, they increased their estimated the sites, and (4) increased income and sales
environment. Second, players moving from GGR in a legal market by 38 percent. tax from the increase in the state’s economy
the illegal sites to the legal sites would have • With regard to new players being that could result from legalization.
to report their earnings for income tax attracted to the newly legalized market, the
purposes. This would reduce their chances approaches of each report also differed: The special case of exclusivity
to (illegally) avoid taxation and would make • Genest Consulting did not think the Genest Consulting relied on legal advice
playing on the legal site much less attractive. monopolistic site proposal it analyzed would from its client to the effect that legalizing
• LECG assumed a range of recapture rates, draw significant numbers of new players Internet poker would violate the exclusivity
from a low of a flat 25 percent to a high of into the internet poker arena. clauses in existing Indian Gaming
80 percent growing to 100 percent over time. • LECG relied on estimates from H2 compacts. To the extent that exclusivity is
LECG based these ranges on H2’s analysis Gaming and Capital. Both H2 and GBGC violated, it would automatically free up the
of the transfer rates in other countries in general rely on data gleaned from gaming tribes to cease making the payments
that have legalized Internet gaming and monitoring Internet play worldwide and to the state that the compacts require. In
on the testimony of industry experts. they use the experience in other countries 2010-11, those payments totaled $365
The proposal that LECG was analyzing to model the growth rates of play and the million. Obviously, the potential loss of that
would have created a more competitive, effects of legalization on the volume of play amount of revenue would have dwarfed
and therefore a more attractive gambling in specific markets. any state revenue gain from legalization.
environment by allowing up to three hubs • In both of its reports, Blue Sky uses its However, a more recent legal opinion
with multiple sites potentially operating survey methodology to project the impact of provided to us by our client indicates
on each hub. However, it should be noted legalization on current non-players. that Internet poker would not violate the
that it would still have suffered from a exclusivity clauses in the compacts. While
substantial income reporting disincentive. Of course, once the GGR estimates are exclusivity remains an issue for further
In addition, the proposal analyzed by complete, the revenue to be expected from legislative consideration, given the most
LECG did not specify the tax rate, so they taxing that GGR is simply a function of the recent legal opinion, we do not assume in
provided separate estimates for 20, 30 and tax rate. It is worth noting, however, that this analysis that SB 51 or SB 678 would
40-percent rates. Industry experts advise us LECG modeled several different tax rates result in any revenue losses to the state.
that a tax rate above 10 percent or so would
make it financially difficult for operators to
invest sufficiently in player recruitment and 3
These could include players who stopped playing after Black Friday but return upon legalization.
GGR and revenues from the 10 of the offshore market that existed prior to earning substantial incomes, often in the
percent tax Black Friday. hundreds of thousands of dollars annual,
Figure 2 displays H2’s most recent projection H2 advises that there is no definitive data are in this category.
of the size of a legalized intrastate Internet on what California online poker players did • Some moved their gaming to brick
poker market in California, assuming after Black Friday, but that they probably fall and mortar casinos or card clubs in
legalization takes effect in 2015. The into one of several categories: California or other states.
revenue that the state would collect from • Some may have continued to play on the As a result of these uncertainties, H2
the proposed 10 percent tax is also displayed few remaining offshore real-money poker advises that at least in the initial years of
(see figure 2). sites. In fact, H2 estimates that in 2014, legalization, the projections of GGR should
The methodology that H2 used to these sites will have a GGR from California be regarded as an upper limit. Industry
make these projections is quite similar players of about $38 million. experts, however, advise us that over time,
to how it made the projections for the • Some switched to free-play, social gaming the California market has the potential to far
earlier LEGC study, essentially modeling or subscription poker sites. exceed these projections.
what has happened in other countries • Some switched to real-money sites that
after legalization and using the current offer games other than poker and which have The bottom line
worldwide volume of play as an indicator of yet to be effectively shut down by the DOJ. Figure 3 summarizes our estimate of total
market potential. In fact, the market volumes • Some ceased play altogether. revenues that can be expected under SB 51
are similar, adjusting for growth to the year • Some moved outside the USA. Very or SB 678. It is noteworthy that our estimate
2015, to H2’s earlier estimates of the volume likely, the professionals who had been of increased ‘other” revenues equates to
about 7 percent of GGR, as compared to
Figure 2 - Projections of a legal intrastate, Internet market in California LEGC’s 15 to 16 percent and Blue Sky’s 8 to
and the state revenue from a 10-percent Tax (Dollars in millions)4 9 percent. The major reason for our lower
estimate is the impact of Black Friday on
2015 2016 2017 2018 2019
offshore, illegal Internet gaming. The effect
GGR $729 $867 $992 $1,149 $1,292
has been to significantly reduce the relative
State Revenue from the 10- percent $73 $87 $99 $115 $129
GGR Tax
amount of offshore spending available to
be recaptured, thereby limiting the relative
amount of indirect revenues associated with
Figure 3 - Total revenues from a legal intrastate Internet legalization of Internet poker.
market in California (Dollars in millions) Figure 4 summarizes the estimated total
2015 2016 2017 2018 2019 5-year Totals impact on California’s economy (see table).
Direct State Revenues from GGR Tax $73 $87 $99 $115 $129 $503
Subtotals, Other State Revenues $48 $58 $68 $78 $88 $342
Figure 4 - Estimated total fiscal and economic impact on California from legal Michael C. Genest opened
Genest Consulting in January of
intrastate poker
2010 to provide advice, analysis
2015 2016 2017 2018 2019 and advocacy on fiscal and policy
Gross Gaming Rev. $729 million $867 million $992 million $1.14 billion $1.29 billion issues affecting state and local
Economic Output $334 million $352 million $354 million $410 million $460 million government. In January 2011, Genest added
State Revenues $121 million $145 million $167 million $193 million $217 million
two partners, Brad Williams and Peter Schaafsma,
Jobs 1,952 2,053 2,063 2,375 2,657
and founded Capitol Matrix Consulting. Prior to going
into private practice, Mr. Genest served for four years
as Governor Arnold Schwarzenegger’s chief financial
4
SB 51 and SB 678 require substantial deposits of sites that register to operate internet poker. The deposits would be used to pay the policy advisor in his role as Director of the California
GGR tax until they are depleted. Figure 4 does not attempt to model this cash- flow because it would depend on the numbers of sites
Department of Finance.
and it would not affect state revenues in total.
EUROPEAN REGULATION
In conjunction with Ash Averill, Associate at DLA Piper, iGaming Business of the monopoly and local operators. Only
provides a snapshot of the European iGaming markets, charting the regulated land-based casinos and betting operators can
online gambling products and legalised operator types within each country, apply for a licence pursuant to the draft bill
and impending market updates (where applicable). and ISP blocking is also proposed.
DENMARK
Regulated Gambling Products: Sports
betting, horse race betting, poker, casino,
bingo and lottery.
Operator Type: Sports betting, poker and
casino licences are available to private
operators. Bingo, lottery and horse race
betting (fixed odds only) is controlled by the
state monopoly.
Status: The Danish online gambling regime
went live on 1 January 2012.
ISP blocking measures are active in
the jurisdiction and the Danish Gaming
Authority has been granted an injunction
in order to block operators and suppliers
that have been targeting Danish customers
without a the requisite licence.
A decision is expected in 2014 from ECJ on
whether or not taxing online casinos less than
land-based casinos amounts to state aid.
ESTONIA
Regulated Gambling Products: Sports
betting, horse race betting, poker, casino,
bingo and lottery.
Operator Type: Licences for all gambling
products are available for private its infringement proceedings against the regulates sports betting, horse race betting,
operators save that the monopoly has Member State. poker, casino and bingo. The other 15 states
exclusive rights to lottery. Active enforcement measures are in place of Germany currently only permit sports
Status: Only 18 operators are currently (restrictive marketing for offshore operators betting and horse race betting.
licensed in the jurisdiction, 9 of which relate and ISP blocking). Operator Type: Private operators can no
to online gambling. A “blacklist” of almost longer obtain licences in Schleswig-Holstein,
800 operators is constantly maintained FRANCE and those in existence will expire on 30 June
and updated by local authorities and ISP Regulated Gambling Products: Sports 2019. In the other 15 states, horse race betting
blocking is in force. It is understood the betting, horse race betting, poker and lottery. licences are available at a regional level but
Estonian government is intending to require Operator Type: Private operators can the position surrounding the 20 available
players to set weekly or monthly limits obtain online licences for sports betting, sports betting licences is still uncertain.
before gambling online, a development horse race betting and poker. The monopoly Status: The licensing regime in Germany is in
which could occur this year. has exclusive rights to lottery. a state of flux. Two separate regulatory regimes
Status: France is a regulated market that has are in operation and the 20 federal sports
FINLAND been sanctioned by the European Commission. betting licences have still not been awarded.
Regulated Gambling Products: Sports On 13 February 2014, French Members of On 12 June, the ECJ ruled that the existence
betting, horse race betting, poker, casino, Parliament introduced a bill which amends of two regulatory frameworks within one
bingo and lottery. several provisions of the French Consumer Member State does not necessarily contravene
Operator Type: All gambling products Code. The amendments expand the European legislation but has left national
are under the exclusive control of the three definition of prohibited games of chance to courts to decide on the matter. The judgment
monopoly providers, Raha-automaatiyhdistys capture games that are, even in part, based does not deal with the limit on sports betting
(“RAY”), Fintoto Oy and Veikkaus Oy. on chance. The full impact of the changes is licences however and challenges are expected
Status: Ruling from the ECJ confirmed that yet to be determined. after the licences have been awarded.
Finland’s three monopoly providers are
legally permitted which has subsequently GERMANY GREAT BRITAIN
been written into law. In November 2013, Regulated Gambling Products: Schleswig- Regulated Gambling Products: Sports
the European Commission also withdrew Holstein, a small Northern German state, betting, horse race betting, poker, casino,
bingo and lottery. the Hungarian National Assembly adopted measures including ISP and payment
Operator Type: All licences are available the draft legislation, which entered into force blocking are contained in the draft bill
to private operators save for lottery, which 15 days after it was promulgated. However, together with higher tax rates and fees.
is reserved exclusively for the monopoly the executive order necessary to implement
provider, Camelot. the licensing regime has not yet been LITHUANIA
Status: Foreign operators can transact with, introduced. The National Tax and Customs Regulated Gambling Products: Lottery
and advertise to British customers, but only Authority has the ability to require ISPs to Operator Type: Local or national lottery
those regulated in the EEA or a “white list block any unlicensed sites, which took effect licences are available for locally established
jurisdiction” (Alderney, Isle of Man, Antigua on 2 January 2014, but no action has been companies.
and Barbuda, and Tasmania). taken so far. Status: Other than lottery, the law is silent
A move to a local licensing model has on whether or not gambling activities can or
been announced and is expected to be IRELAND cannot be offered online.
implemented in Summer 2014, with a Regulated Gambling Products: Online Draft legislation was notified to the
corresponding tax rate of 15% of gross profits gambling is not specifically accounted for in European Commission in February 2014. It
entering into force on 1 December 2014. Ireland’s outdated legislation and as such all requires operators to establish a Lithuanian
products are currently unregulated. company in order to obtain a licence and
GREECE Status: Ireland is in the process of have a share capital of at least 4 million Litas
Regulated Gambling Products: Sports updating its legislation which will create a (circa. £1 million). The draft also sets out
betting, horse race betting and lottery comprehensive online gambling regime and enforcement measures to be taken against
Operator Type: All products are exclusively payment restrictions. It is not anticipated that illegal operators as well as software and
reserved for the monopoly providers although the legislation will be introduced before 2015. technical requirements.
24 transitional licences for private operators Lithuania were also the subject of further
remain active, whereby all gambling products ITALY information requests by the European
are permitted. Regulated Gambling Products: Sports Commission in November 2013.
Status: The licensing regime in Greece (like betting, horse race betting, poker, casino,
Germany) is also in a state of flux. The Greek bingo and lottery. LUXEMBOURG
government submitted a new draft law to Operator Type: All products are available Regulated Gambling Products: Lottery
the European Commission in March 2013, to private operators save for lottery which Operator Type: Monopoly.
which effectively rescinds the 24 transitional is reserved for the monopoly provider. Status: The general prohibition on
licences granted to operators enabling them However, it is currently not possible to gambling in Luxembourg appears
to keep transacting with Greek residents. obtain a licence in Italy. sufficiently wide to cover all forms of
It is understood that the European Status: Italy is a fully regulated market. online gambling.
Commission have criticised the revised Italy extended the number of betting markets
legislation and until the position is resolved, available to its residents last year and it has MALTA
the transitional licences will remain in recently approved new variants of poker, Regulated Gambling Products: Sports
force. Despite this, the Hellenic Gaming which may help attract new interest to the betting, horse race betting, poker, casino,
Commission has essentially sanctioned product in Italy. bingo, lottery.
the launch of OPAP’s betting monopoly Operator Type: Private operators can apply
without notifying the relevant decree to the LATVIA for a local licence but not in relation to
European Commission. Regulated Gambling Products: Sports lottery products.
betting, horse race betting, poker, casino, Status: On 3 June, the Maltese regulator (the
HUNGARY bingo and lottery. Lotteries and Gaming Authority) introduced
Regulated Gambling Products: Sports Operator Type: Although online gambling a number of policy changes for its licensees.
betting, horse race betting, poker, casino, is regulated, only five operators are licensed These include changes regarding hosting
bingo and lottery. in the jurisdiction. Lottery is reserved for state- servers abroad, audit requirements and the
Operator Type: Only the state monopoly, owned Latvijas Loto. cloud environment. It is still anticipated that
Szerencsejáték Zrt. and local concession Status: Updated legislation was supposed Malta will update its gambling legislation in
companies can apply for a licence. to be implemented in January 2012 but the near future.
Status: In January 2013 the Hungarian parliament has extended the submission
government submitted an amendment to period twice and developments seem to NETHERLANDS
its Gambling Act which essentially reserved have stalled. The new legislation restricts Regulated Gambling Products:
gambling activities for the state or local the provision of online gambling to Latvian Sports betting, horse race betting, poker,
concession companies. On 26 June 2013, registered operators. Stricter enforcement casino, bingo, lottery.
Operator Type: Monopoly for all products. ROMANIA general licence and a specific licence for
Status: The fall of government in April Regulated Gambling Products: each gambling activity from the National
2012 delayed the plans to regulate remote Mutual horse racing, mutual sports betting Gambling Commission. Draft laws
gambling but in May 2013 the Remote and lottery. introducing slots and betting exchanges are
Gambling Act was published. It stipulates Operator Type: Monopoly currently in consultation phase.
the conditions which operators will be able Status: Given licences are only available The National Gambling Commission
to offer online gambling in the Netherlands, for Romanian companies under the current has taken action against unlicensed
including establishment within the EEA, legislation, in order to comply with European operators and a number of fines have
player protection requirements and a two- law, in December 2013, the government already been imposed.
tier tax system. announced its intention to submit a new, EU
The draft legislation was sent to the compliant draft to the European Commission. SWEDEN
European Commission in March 2014 and It is anticipated to provide a fully regulated Regulated Gambling Products:
it is understood a licensing regime could be regime and could be implemented as early as Sports betting, horse race betting, poker,
implemented in early 2015. this year. The draft law allows entities within bingo and lottery.
the EU to apply for a licence, it imposes a Operator Type: Only public benefit
NORWAY reform on licence fees and eliminates the tax organisations, the horseracing industry and
Regulated Gambling Products: Sports on player revenues. the state lottery may obtain a licence. No local
betting, horse race betting and lottery licences are available for private operators.
Operator Type: Online gambling in Norway SLOVAKIA Status: The Swedish government intends to
is reserved for its two monopoly providers: Regulated Gambling Products: Sports update its online gambling regulations but
Norsk Tipping and Norsk Rikstoto. betting, horse race betting, poker, casino, have confirmed that it is unlikely to happen
Status: The monopoly has extended its bingo, lottery. for the next two years. However, in the
offering to include live betting, e-bingo and Operator Type: All products are operated meantime, the government has appointed
casino games in an attempt to redirect traffic by the monopoly save that land-based sports an investigator to find ways to combat
from unlicensed sites. However, the new betting operators can offer services online advertising from unlicensed offshore
government is understood to be considering a due to a legal loophole. operators (deadline of 30 November 2014 to
limited licensing regime for foreign operators, Status: No developments are anticipated in report on findings).
with any proposals likely to be announced in the short term. In November 2013, the European
the 2015 budget. Commission requested Sweden to comply
SLOVENIA with EU rules on the free movement of
POLAND Regulated Gambling Products: Sports services with regard to the regulation and
Regulated Gambling Products: Sports betting, horse race betting, poker, casino, supervision of its gambling monopoly.
betting and horse race betting. bingo, lottery.
Operator Type: Licences are only available Operator Type: Online gambling must be UKRAINE
for companies with a local establishment. operated by land-based casinos or lotteries Regulated Gambling Products: All online
Status: New legislation enacted on 1 and, as a result, only the monopoly holds gambling products are prohibited.
January 2012 only permits betting and online licences in Slovenia. Status: Gambling has been illegal since
only four licences have been granted to Status: Slovenia has published a new draft the introduction of the “Law on ban of
local companies (Fortuna, Milenium, STS gambling law but it seeks to reserve its gambling business in the Ukraine” in 2009.
and Totolotek). restrictive position on gambling. The law has Since then a number of laws regulating
Poland were also the subject of a further not yet been voted on in parliament and a gambling activities have been drafted but
information request from the European timeline for implementation is unclear. none have actually been enacted, save for
Commission in November 2013. one law giving police and enforcement
SPAIN authorities additional powers to enforce the
PORTUGAL Regulated Gambling Products: Sports ban on gambling.
Regulated Gambling Products: Sports betting, horse race betting, casino, poker,
betting, horse race betting, poker, casino, bingo and lottery.
bingo, lottery. Operator Type: Private operators can All-In is an online resource focused on the fast-moving
Operator Type: Monopoly for all products. apply for licences for all gambling products global gaming market. DLA Piper’s global gaming team
Status: A draft law for online gambling save for lottery. has created a dedicated site to deliver topical legal and
regulatory updates from specialists
in Portugal is likely to be introduced to Status: The first online licences were
throughout our network. Visit All-In at
parliament in June but implementation is issued on 1 June 2012. Under the law,
http://blogs.dlapiper.com/all-in/.
anticipated to be 2015. online gambling operators must hold a
Data Centre
o
South
Dakota
Since the US Department of Justice publicly reversed its position on the White Live (iGaming)
scope of the 1961 Wire Act in December 2011, conceding that it only Green Legislation Enabled/Lottery Online
reserved jurisdiction over sportsbetting, iGaming Business has been reporting Iowa
Nebraska
Amber Work in Progress/Under Consideration
on various state activity with regards to the broadening of intra-state lottery Red Undecided/Back to the Drawing Board
and iGaming models. The most recent update includes the introduction of a Blue No Movement
new online gambling bill in Pennsylvania. Black Prohibited/ Pending Prohibition
Utah
Operator Type: Applicants with existing land- around 8% on a month-over-month basis in May. Regulated Gaming Type: Online lottery
based license New Jersey’s online gambling industry generated Operator Type: Georgia Lottery controlled
Colorado a total of $10.5m, down from the $11.4m recorded
Go-live Date: Live. There are now three real-money Estimated Go Live Date: Online
online poker platforms in operation in Nevada. in April, driven by falls in both casino and poker. Illinois: Green
Kansas
Ultimate Poker, WSOP.com and Real Gaming, Poker revenue dipped 12% month-over-month Regulated Gaming Type: Online lottery
formerly South Point Poker. In March, Ultimate to $2.27m, while online casino revenue was Operator Type: Illinois Lottery controlled
Poker’s parent company Ultimate Gaming signed a down 7% to $8.2m. The Borgata Hotel Casino Estimated Go Live Date: Online
deal to provide online poker for customers of Reno’s & Spa continued to lead Atlantic City’s casinos
Peppermill and four other affiliated casinos. in the nascent Garden State iGaming market, its Michigan: Green
Borgata-branded and software partner PartyPoker Regulated Gaming Type: Online lottery
Delaware: White marginally increasing their collective market share
Oklahoma
Operator Type: Michigan Lottery controlled
Regulated Gaming Type: Full-service online to 38% from 36% in April. Second place Caesars’ Estimated Go Live Date: Late 2014
rizona gaming market share held steady at 27%, despite its revenue
Operator Type: Centralized iGaming system via falling to $2.8m, from just over $3m in April. The California: Amber
Delaware Lottery and operated by the three state Gamesys-powered Tropicana’s recent growth also Present Status: Thirteen California tribal leaders
casinos came to an end, generating just under $1.9m in have provided amended bill language that would
New Mexico
Estimated Go Live Date: Live. Delaware became revenue in May, down from $2.1m the prior month. provide a licensing and regulatory framework
the first state to launch a full service online gaming for real-money Internet poker in California.This
offering on October 31, 2013. The iGaming program Maryland: Green included restrictions on companies which took
is run by the State Lottery, and is powered by a Regulated Gaming Type: Online lottery online gambling business from US consumers after
vendor collaboration between 888 and Scientific Operator Type: Maryland Lottery controlled 31 December 2006. PokerStars owner the Rational
Games/WMS, which saw free-to-play versions go Estimated Go Live Date: No further updates. As Group and its California land-based partners the
live in August 2013. The state’s iGaming law also previously reported, the Maryland Live! Casino Morongo tribe, the Commerce Club, Hawaiian
provides the opportunity to explore compacts with launched a free-to-play online casino last year to Gardens Casino and Bicycle Casino swiftly issued
other states, a function also evident in the Nevada build awareness and a database, but there has a response to the 13 tribes’ announcement and
and New Jersey regulations. been little in the way of news since then as to proposed amendments, stating that while they
when in 2014 the lottery will be available online. supported legislation that would allow Californians
New Jersey: White
Texas
to play on well regulated and trusted websites,
Regulated Gaming Type: Full-service Minnesota: Green “[w]e strongly oppose the so-called ‘bad actor’
online gaming Regulated Gaming Type: Online lottery, instant language that is nothing other than a blatant
Operator Type: Atlantic City casinos with win tickets attempt to provide certain interests with an unfair
existing land-based license Operator Type: Lottery controlled competitive advantage by arbitrarily locking out
Estimated Go Live Date: Live. The New Jersey Present Status: Online. trusted iPoker brands.”
Data Centre
Wisconsin New Yo
Michigan
Washington
North Maine
Montana Dakota
Oregon
New
Minnesota Vermont Hampshire
Idaho
South
Wisconsin New York Massachusetts
Dakota
Wyoming Michigan
Rhode Island
Pennsylvania
Connecticut
New Jersey
Pennsylvania
Iowa
Nebraska
Nevada
Ohio
Delaware
Utah Indiana
Illinois Maryland
Colorado
West
California Virginia Virginia
Kansas
Ohio
Missouri
Kentucky
North Carolina
Tennessee
Arizona Oklahoma
New Mexico South
Arkansas
Carolina
District of
Illinois Indiana Mississippi Alabama Georgia
Columbia
Louisiana
Texas
West
Virginia Florida
Missouri
Kentucky
Mississippi
You have to change to survive and flourish.”. language now defines an authorized game as Florida: Red
The State Gaming Commission added in a “[a]ny interactive game approved by the board Present Status: Back to the drawing board
statement: “The AGA’s decision to withdraw from pursuant to this chapter”, The bill provides for an Georgia
discussions regarding online gaming reinforces intended tax rate 14% of gross gaming revenue, Connecticut: Red
Louisiana
the Commission’s position on this topic. The Alabama
and a one-off fee of $5m per licence. A ‘bad Present Status: Undecided
Commission believes that a slow and deliberate actor’ clause in the bill will exclude companies
approach to this issue is the most responsible that violated the Unlawful Internet Gambling Utah: Black
way to move forward, given the significant and Enforcement Act of 2006. It also provides for Present Status: Prohibited
varying opinions on this matter.” interstate online poker compacts.
Texas: Black
New York: Amber Mississippi: Amber Present Status: Prohibited at the state level.
Present Status: Poker-only bill under Present Status: Study into pros and cons of However, there remain plans to allow the state to
consideration. Internet gambling underway. opt in to any federal online poker legislation.
Florida
Data Center
Data Centre
iGaming Dashboard
In conjunction with H2 Gambling Capital, the iGaming Dashboard offers a monthly overview of the
iGaming sector in numbers. This is the June 2014 edition.
total global igaming gross win (€bn) PERCENTAGE OF GLOBAL INTERACTIVE GROSS WIN DOT
45
COUNTRY/state monopoly
60%
40
35 50%
30
40%
25
20 30%
15
20%
10
5 10%
0
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013P
2014E
2015E
2015E
2017E
2018E
0%
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013P
2014E
2015E
2015E
2017E
2018E
Percentage of Global Gambling Gross Win Interactive Global Interactive Gambling Gross Win by Region (2013e) (€bn)
12%
10% 6%
1%
8%
14%
2% 29%
6%
4%
2% 48%
0%
N America Latin Am / Caribbean Europe Asia/ME Africa Oceania
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013P
2014E
2015E
2015E
2017E
2018E
14%
8%
12%
6% 47%
10%
6%
8%
12%
6%
4%
2%
21%
0%
a
pe
be /
ica
nia
ge
ric
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rib m
ra
er
ea
Ca tin A
an
Af
e
Eu
Am
Oc
ia
Av
As
La
al
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ob
Gl
US STATE TRAFFIC
Competitive intelligence services company, Experian Hitwise, provides data on the top-visited
gambling sites ranked by US Internet traffic for the entire US and by state, based upon a sample
of 10 million US Internet users. The data does not include mobile traffic.
Most Popular
Gambling
Rank Rank Rank
Websites Total Visits Visits Share
Apr 14 Mar 14 Feb 14
Websites inthe US
PCHLotto 14,236,694 4.15% 4 2 1
Ranked byVisits
Share
2014
World Series of Poker 8,599,653 2.51% 2 12 17
Most Websites
Segmented Segmented
Visits Rate
Massachusetts State Lottery
Commission
55.28% 93.08%
Popular Illinois Lottery 32.51% 88.70% FoxWoods Resort Casino 2.79% 43.02%
Ranked by
Bovada.lv 3.47% 4.86% PCHLotto 1.61% 1.28%
Illinois Lottery Online 2.78% 95.02% King.com 1.43% 2.48%
Visits from PCHSlots 2.50% 4.83% Powerball 1.41% 2.44%
Illinois* Twinspires.com 2.43% 9.06% FreeSlots 1.12% 1.84%
TVG 2.09% 10.13% BetUS 1.06% 19.21%
FreeSlots 1.72% 3.30% Mohegan Sun 1.03% 21.06%
Lottery USA 1.54% 5.29%
Most POPULAR GAMBLING WEBSITES
Ranked by Visits from
Massachusetts*
Most POPULAR
GAMBLING WEBSITES
Ranked by Visits from
IOWA* Websites
Segmented Segmented
Most
Visits Rate
pOPULAR
Most
PCHLotto 7.87% 1.02%
Bovada.lv
FreeSlots
5.81%
5.38%
1.13%
1.44%
GAMBLINg
WEBSITES
Popular King.com 4.72% 1.32%
Ranked by
Gambling
World Series of Poker 4.70% 1.61%
Cappers Mall
2.16%
2.05%
2.38%
N/A
new
CALIFORNIA* jersey*
Websites Segmented Visits Segmented Rate Segmented Segmented
Websites
California Lottery 20.79% 94.60% Visits Rate
Most
Popular GAMBLING
Most POPULAR
Websites Ranked by Gambling
Visits from NEVADA* Websites
Segmented Segmented
Websites
Segmented Segmented Ranked by
Websites
Visits Rate Visits Rate Visits from
FLORIDA*
World Series of Poker 27.31% 31.90% Florida Lottery 45.20% 90.96%
MARKETPLACE 2014/15
Welcome to the MarketPlace listings section in iGaming Business. All listings below are from our suppliers guide
MarketPlace 2014/15. To request a free copy of this publication or to have your company listed below please contact
Ian Larcombe on +44 (0) 207 954 3412 or email ian@igamingbusiness.com.
Secure Trading
Netrefer www.securetrading.com
www.netrefer.com
SoftSwis
Online Casino Reports GreenTube_MagDirectory_58x58.indd 1 02/06/14 15:56
www.softswiss.com
www.onlinecasinoreports.com
corPorate Service ProviderS and truStS
PIMS SCA
www.pims-sca.com Affinity Management Services
www.affinity.co.im
Think Management
www.thinkmanagement.com
Net
NetEntertainment
EntertainmentMalta
MaltaLtd.
Ltd. Equiom
The
SuiteMarina Business
A, Dolphin Centre
Court A, www.equiom.im
affiLiate manaGement Software Abate
EmbassyRigord Street,
Way, Ta’Xbiex
Ta’ Xbiex MSD XBX
111120
MALTA
MALTA SMP Parners
Income Access Phone:
Phone: +356
+356213
213116
11621 21 www.smppartners.com
www.incomeaccess.com fax: +356 213 324 90
Fax: +356 213 324 90
sales@netent.com corPorate SociaL reSPonSiBiLity SoLutionS
Netrefer sales@netent.com
www.netent.com
www.netrefer.com www.netent.com Playscan
www.playscan.com
affiLiate ProGramS
crm and caLL centre ServiceS
iAffiliates Edict eGaming
www.iaffiliates.com www.edict.de ANT Marketing
nokibetaffiliates www.AntMarketing.com
Greentube
www.nokibet.com
www.greentube.com Correlsense
Skrill www.correlsense.com
GTECH
www.skrill.com
www.gtech.com fiXed oddS
BinGo Software Microgaming Kiron Interactive
GTECH www.microgaming.com
www.kiron.co.za
www.gtech.com
Net Entertainment
Microgaming www.netent.com fraud Protection & id verification
www.microgaming.com Experian
SoftSwiss
caSino Software www.softswiss.com www.experian.com
Betradar Alderney
www.betradar.com
Alderney Gambling
www.alderneygambling.com
Game Software
1X2gaming Gibraltar
www.1x2gaming.com Continent 8 Technologies
www.continent8.com
Secure Trading
www.securetrading.com Gib Telecom
www.gibtele.com
GTECH
www.gtech.com
Isolas
www.isolas.gi
Gaming Management Software Isle of Man
Comtrade Continent 8 Technologies
www.comtrade.com www.continent8.com
BetConstruct
Microgaming Capital IOM www.betconstruct.com
www.microgaming.com www.capital-iom.com
BetGames.tv
SoftSwiss Equiom www.betgames.tv
www.softswiss.com www.equiom.im
Comtrade
Manx Telecom www.comtrade.com
Hosting
www.manxtelecom.com
Evolution Gaming
Bmit www.evolutiongaming.com
Netcetera
www.bmit.com.mt www.netcetera.co.uk
Ezugi
Continent 8 Technologie Jersey www.ezugi.com
www.continent8.com
First Names Group Microgaming
Curacao e-Gaming www.firstnames.com www.microgaming.com
www.curacao-egaming.com Vivo Gaming
Malta
www.vivogaming.com
eCommerce Park Continent 8 Technologies
www.e-commercepark.com www.continent8.com Lottery Software
Realex Payments
www.realexpayments.co.uk
Safecharge
www.safecharge.com
Secure Trading
www.securetrading.com
Skrill
www.skrill.com
PoKer Software
BetConstruct
www.betconstruct.com
Connective Games
www.connectivegames.com
GTECH
www.gtech.com
marKetinG, PromotionS, PriZeS & mercHandiSe
Microgaming
Gaming Rewards Acquiring has never been as www.microgaming.com
www.gaming-rewards.com flexible.
PromotionS, PriZeS & mercHandiSe
Income Access
www.incomeaccess.com Gaming Rewards
www.gaming-rewards.com
moBiLe GaminG
Initial Rewards
1X2gaming www.initialrewards.com
www.1x2gaming.com
recruitment
Comtrade
www.comtrade.com www.ecommpay.com Esanda
www.esandarecruitment.com
Greentube
www.greentube.com
2 The National Lottery UK www.national-lottery.co.uk Lottery, Mobile Lottery 52 My Georgia Lottery www.mygalottery.com Lottery
3 BetFair www.betfair.com Betting Exchange, Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Betting Exchange, Mobile Bingo 53 SBOBET www.sbobet.com Casino Games, Live/In-Play Betting, Mobile Sportsbooks, Racebook, Sportsbook
4 William Hill www.williamhill.com Backgammon, Binary Options, Bingo, Casino Games, Forex, Live/In-Play Betting, Lottery, Mobile Binary Options 54 Atlantic Lottery www.alc.ca Bingo, Fantasy Sports, Lottery
5 888 Casino www.888.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Bingo, Mobile Casinos, Mobile Poker, Mobile Racebooks 55 Sportsbook.com www.sportsbook.ag Casino Games, Live/In-Play Betting, Mobile Racebooks, Mobile Sportsbooks, Poker, Racebook, Sportsbook
6 Ladbrokes www.ladbrokes.com Backgammon, Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Bingo, Mobile Casinos, Mobile Live Dealer 56 BetVictor www.betvictor.com Betting Exchange, Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Casinos, Mobile Live Dealer
7 Paddy Power www.paddypower.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Casinos, Poker, Racebook, Rummy Games, Skill Games 57 UFX Markets www.ufxmarkets.com Forex
8 TAB Racing and Sports www.tab.co.nz Live/In-Play Betting, Racebook, Sportsbook 58 TwinSpires www.twinspires.com Mobile Racebooks, Racebook, Sportsbook
9 TAB Sportsbet www.tab.com.au Mobile Sportsbooks, Racebook, Sportsbook 59 Sun Bingo www.sunbingo.co.uk Bingo, Casino Games, Lottery, Mobile Bingo, Mobile Casinos
10 eToro www.etoro.com Forex, Mobile Forex 60 PlayHugeLottos.com www.playhugelottos.com Lottery, Mobile Lottery
11 Unibet www.unibet.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Bingo, Mobile Casinos, Mobile Live Dealer, Mobile Lottery 61 FXCM US www.fxcm.com Forex, Mobile Forex
12 Betfred www.betfred.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Bingo, Mobile Casinos, Mobile Live Dealer, Mobile Lottery 62 TVG www.tvg.com Mobile Racebooks, Racebook, Sportsbook
13 SkyBet www.skybet.com Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook, Spread Betting 63 Bets10 www.bets10.com Bingo, Casino Games, Lottery, Poker, Sportsbook
14 FanDuel www.fanduel.com Fantasy Sports 64 Stan James www.stanjames.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Casinos, Mobile Racebooks, Mobile Sportsbooks
15 Sportsbet www.sportsbet.com.au Live/In-Play Betting, Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook 65 Mecca www.meccabingo.com Bingo, Casino Games, Lottery, Mobile Bingo, Mobile Casinos
16 32Red www.32red.com Casino Games, Lottery, Mobile Casinos, Spread Betting 66 DerbyJackpot www.derbyjackpot.com Racebook, Sportsbook
17 WorldWinner www.worldwinner.com Backgammon, Skill Games 67 Oanda - FXTrade www.fxtrade.oanda.com Forex, Mobile Forex
18 InstaForex www.instaforex.com Forex, Mobile Forex 68 Ace 2 Three www.ace2three.com Rummy Games, Skill Games
19 Bovada www.bovada.lv Bingo, Casino Games, Live/In-Play Betting, Lottery, Mobile Casinos, Mobile Poker, Mobile Sportsbooks, Poker 69 DraftKings www.draftkings.com Fantasy Sports, Mobile Fantasy Sports
20 Coral www.coral.co.uk Bingo, Casino Games, Live/In-Play Betting, Lottery, Mahjong , Mobile Bingo, Mobile Casinos, Mobile Poker 70 TopOption www.topoption.com Binary Options
21 Tombola www.tombola.co.uk Bingo, Lottery 71 Binary.com www.binary.com Binary Options
22 Casino.com www.casino.com Casino Games, Lottery, Mahjong , Mobile Casinos, Mobile Lottery 72 TheLotter www.thelotter.com Lottery, Mobile Lottery
23 Jackpotjoy www.jackpotjoy.com Bingo, Casino Games, Lottery, Mobile Casinos, Mobile Lottery 73 Foxy Bingo www.foxybingo.com Bingo, Casino Games
24 Virginia Lottery www.valottery.com Lottery 74 Wozhongla.com www.wozhongla.com Lottery, Mobile Lottery, Mobile Sportsbooks, Sportsbook
25 WSOP www.wsop.com Casino Games, Mobile Poker, Poker 75 Play Now www.playnow.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Poker, Sportsbook
26 Sportingbet www.sportingbet.com Casino Games, Live/In-Play Betting, Lottery, Mobile Casinos, Mobile Lottery, Mobile Racebooks, Mobile Sportsbooks 76 TomWaterhouse.com www.tomwaterhouse.com Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook
27 Tatts www.tatts.com Lottery, Racebook, Sportsbook 77 DraftStreet www.draftstreet.com Fantasy Sports
28 24Option www.24option.com Binary Options, Mobile Binary Options 78 iFOREX www.iforex.com Forex
29 Nairabet www.nairabet.com Binary Options, Live/In-Play Betting, Sportsbook 79 Totesport www.totesport.com Bingo, Casino Games, Fantasy Sports, Lottery, Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook
30 MyBet www.mybet.com Casino Games, Live/In-Play Betting, Lottery, Mobile Sportsbooks, Poker, Sportsbook 80 TABtouch www.tabtouch.com.au Live/In-Play Betting, Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook
31 Illinois Lottery www.illinoislottery.com Lottery, Mobile Lottery 81 Tempobet www.tempobet22.com Casino Games, Live/In-Play Betting, Poker, Sportsbook
32 Markets.com www.markets.com Forex 82 Party Poker www.partypoker.com Casino Games, Mobile Poker, Poker
33 Rummy Circle www.rummycircle.com Rummy Games, Skill Games 83 Costa Bingo www.costabingo.com Bingo, Casino Games, Lottery, Mobile Bingo
34 PokerStars www.pokerstars.com Mobile Poker, Poker 84 IronFX www.ironfx.com Forex, Mobile Forex
35 Pinnacle Sports www.pinnaclesports.com Casino Games, Mobile Sportsbooks, Sportsbook 85 NetBet www.netbet.com Casino Games, Live/In-Play Betting, Poker, Sportsbook
36 The Health Lottery www.healthlottery.co.uk Lottery 86 Gamebookers www.gamebookers.com Casino Games, Live/In-Play Betting, Mobile Racebooks, Mobile Sportsbooks, Poker, Racebook, Sportsbook
37 Horse Player Interactive www.horseplayerinteractive.com Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook 87 Sky Vegas www.skyvegas.com Casino Games, Lottery, Mobile Casinos
38 IG www.ig.com/uk Binary Options, Forex, Mobile Spread Betting, Spread Betting 88 Sports Interaction www.sportsinteraction.com Casino Games, Live/In-Play Betting, Lottery, Mobile Casinos, Mobile Racebooks, Mobile Sportsbooks, Poker
39 Gala Bingo www.galabingo.com Bingo, Casino Games, Lottery, Mobile Bingo, Mobile Casinos, Sportsbook 89 Centrebet www.centrebet.com Mobile Racebooks, Mobile Sportsbooks, Racebook, Sportsbook, Spread Betting
40 Tipico Online Gaming www.tipico.com Casino Games, Live/In-Play Betting, Sportsbook 90 LeonBets www.leonbets.com Casino Games, Mobile Sportsbooks, Poker, Sportsbook
41 www.BetCRIS www.betcris.com Bingo, Casino Games, Live/In-Play Betting, Mobile Sportsbooks, Poker, Racebook, Sportsbook 91 Forex.com www.forex.com Forex, Mobile Forex
42 StarGames www.stargames.com Bingo, Casino Games, Mobile Casinos, Poker, Skill Games 92 Sky Poker www.skypoker.com Casino Games, Lottery, Poker
43 PlayMillion Casino www.playmillion.com Casino Games 93 Las Vegas USA Casino www.lasvegasusa.eu Bingo, Casino Games, Mobile Casinos
44 Oz Lotteries www.ozlotteries.com Lottery 94 Bodog www.bodoglife.com Bingo, Casino Games, Live/In-Play Betting, Lottery, Mahjong , Mobile Casinos, Mobile Racebooks
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