Wednesday, December 18, 2019
By Andrew Tottenham
Managing Director, Tottenham & Co

Earlier this year, the UK Gambling Commission published its annual report on Young People and Gambling, with young people defined as those between 11 and 16 years old. Despite the alarmist headlines there was much to be cheerful about. Although 11% said they had spent their own money gambling in the past 7 days, this was down from 14% in the previous year’s survey. However, included in these figures is young people who have bet or played cards for money with friends. I am not sure this is something that should be frowned upon; betting with friends for money or other things is surely part of growing up.

As an aside, I do remember playing poker for money at my school and being reasonably successful. It made me think I was a good player, so much so that a few years later, when I was about nineteen, I went to a local casino to play poker. In less than 20 minutes I had lost everything. Lesson learned!

By Hannah Gannagé-Stewart
CDC Gaming Reports

A lot can happen in a year in this industry, and the anticipation that preceded the re-regulation of the Swedish market now feels like a lifetime ago, despite the re-regulation only just closing in on its first full 12 months.

It was always going to be a bumpy ride, with prospective licensees concerned from the outset that they would be hamstrung by the might of the legacy monopoly operator Svenska Spel. The latter, in turn, was on the defensive against the flood of new competitors.

While neither extreme has resulted from the new regime, the market as a whole does seem to have had a little of the wind taken out of its sails (or sales, as the case may be). According to figures released by the Swedish Gaming Authority, Spelinspektionen, in November, overall gambling revenue fell in the three months to the end of September, totalling SEK5.90bn, down from SEK6.11bn in Q2 and SEK5.94bn in the first quarter of 2019. Revenue from the state lottery and slot machines also fell 3.2% from SEK1.41bn to SEK1.37bn over the same period, while state casino revenue remained stable at SEK245m.

The Euro News Revue
by Hannah Gannagé-Stewart and Andrew Tottenham
G3 Newswire - 17 December 2019
The Fitzwilliam Club in Dublin is the first casualty of Ireland’s Gaming and Lotteries (Amendment) Act, 2019 (GLAA), having to close its doors after 16 years of operation. Ireland’s “casinos” have operated in a grey area, claiming to be private members clubs, and have been allowed to operate devoid of regulation until the passage of this Act.

In 2009, the international Financial Action Task Force, in a report entitled, “Vulnerabilities of Casinos and Gaming Sector”, pointed out that the private members clubs in Ireland were quasi-casinos that create a risk of money laundering but fell outside of Ireland’s AML laws. Pressure was put on Ireland to regulate the sector. Since then, successive Governments have attempted to regulate these clubs but without success. But, finally, the GLAA makes it illegal to operate casino games without a permit, but a permit will only be issued if the odds for all players, including the house, are the same. In other words, casino-banked games are not permissible. More closures to follow! (AT)
iGaming Business - 16 December 2019
As we close in on almost 12 months of Sweden’s re-regulated gambling regime, iGaming Business (iGB) has several updates. First, the Swedish Gaming Authority (Spelinspektionen) has published its latest strategy for clamping down on illegal gambling. In a bid to wheedle out unlicensed operators, the authority will be checking whether operators are offering deposits, withdrawals and winnings in Swedish Kronor, and whether their terms and conditions are in Swedish and tailored to Swedish customers. It is also working with other regulators to identify unlicensed operators. If caught, they will be fined, and the authority may turn to the police to enforce bans. 

However, iGB also reports that Spelinspektionen, having issued penalties to 21 licensees over the past year, is struggling to get the penalties paid. Which implies it will have a tough time issuing sanctions to unlicensed operators. iGB reports that the authority has levied around SEK117.6m in fines over the year, the largest of which (SEK19m) was imposed on Betsson’s Nordic Gaming Group, for repeatedly offering players bonuses when the rules state they may only offer a single bonus when players sign-up. But Åland Islands-based Paf is the only operator to have stumped up, paying a SEK4m (€382,000/$431,900) fine for having breached the regulator’s rules in March, by allowing self-excluded players to access its site.

Meanwhile, iGB reported on a recent study revealing that Swedish gambling participation has dropped to 60% of adults in 2019. The study was commissioned by Spelinspektionen and carried out by polling specialist Novus. The study found there had been a drop of six percentage points, from 66% in 2018. It claims the number of gamblers in the country is 16% lower than when the survey was first carried out in 2013. The survey also revealed that Swedish adults who gamble are more likely to equate it with entertainment than a way to win money. 62% of players cited entertainment as their main reason for gambling, which was up one percentage point from 2018, 36% also said they looked for the most entertaining offer when choosing an operator, second only to seeking security from an operator’s platform. (HGS)
G3 Newswire - 13 December 2019
A third casino has opened in the Principality of Liechtenstein. The two other casinos, operated by Novomatic and Casinos Austri, opened in 2017, following a change of the law in 2010 which lifted the prohibition on gambling. Casinos are not without their detractors in the Principality. Many worry that Liechtenstein, which has fought hard to clear the name of its banking industry after accusations that its secrecy laws fostered money laundering, will once again become embroiled in a money-laundering scandal, this time involving casinos.

The government favours a market-driven approach to the number of licences to be issued, and more casino openings are in the offing. Clearly, it is not the 38,000 residents of this tiny Principality that these casinos are focussed on. Liechtenstein is tucked neatly between Austria and Switzerland, and with a casino GGR tax that is based on a sliding scale from 12.5 percent to 40 percent, it gives operators a significant advantage over the Swiss casino tax, which has a maximum rate of 80 percent. (AT)
SBC News - 12 December 2019
Following complaints, the European Commission has opened a State Aid investigation into whether the taxation framework governing casinos owned by a German Lande breaches European State Aid rules. In general terms, there are four criteria for something to be considered State Aid, which can only be granted in certain circumstances. Outside of these circumstances it is illegal, and if found to be so the Member State has to claw back the advantage granted, with interest. The four criteria that all need to be met are as follows;
  1. the measure confers a selective advantage
  2. the advantage is granted to one or more entities
  3.  the advantage is granted through State resources (including a loss of tax revenues), and
  4. the advantage could distort competition on the European market.
The Commission is ultimately political and is unlikely to want to take on the German Government on something so relatively small as the Lande-owned casino groups. And so it is my prediction that the taxation framework will not be found to be illegal State Aid because it will fall at the last hurdle - competition was not distorted. (AT)
SBC News - 11 December 2019
The Danish Gambling Authority Spillemyndigheden is set to introduce mandatory deposit limits beginning 1 January 2020. The country’s monopoly operator Danske Spil made it mandatory for players to set deposit limits across its igaming products from 2 July this year; they were unable to play until they set personal limits. The measure now applies to all regulated online gaming operators along with other updates intended to bring online casinos in line with the inspection requirements required of lotteries. For example, the regulator’s logo must now appear on all licensee’s sites; players must be given the opportunity to self-exclude online, rather than having to notify a customer service department; and operators are expected to keep player data on file for at least five years.  (HGS)
iGaming Business - 6 December 2019
The Irish Bingo Players Association and various bingo operators have successfully blocked proposals for prizes from bingo games in Ireland to be capped at just 50% of takings. The cap was introduced as part of the The Gaming and Lotteries (Amendment) Bill 2019, which has been passing through the Irish legislature, Oireachtas, this month and aims to update legislation from 1956. Following an amendment on 6 December, the bill now states that no more than 75% of the total takings can be allocated to prizes and at least 25% should be allocated to charitable or philanthropic causes. The bill also includes changes to licensing and a €5 cap on the maximum stake on gaming machines. The bill is seen as an interim measure, with greater reform expected throughout 2020. (HGS)
This report is edited by Andrew Tottenham and Justin Martin
Tottenham & Co
232 Cranmer Court
London SW3 3HD, UK