Finsoft/Spielo G2 Games Issue

[ThePOGG]

sadly, if that were true, every rogue would have gone under, but thousands of players who don't read CM will still play there

Unmarketable on my site I can't take responsibility for what other webmasters choose to do, i can only do the best with what i can control.

 

[deucebag]

....based on?

Nothing wrong with having that POV, but it's fairly empty if you have nothing to substantiate it.

Based on the number of "mistakes" made in this case that all conveniently serve to trick players into playing the rigged game. Not only did they choose to use a rigged real money game, they used a misleading help file telling people that the RTP for certain bets was 100%, and they used a differently rigged "play money" game that paid out at a higher rate, which would mislead anyone who wanted to test the game fairness without risking their own funds.

I think it's more likely that this was intentional than not. The only argument I've seen to the contrary is that they would be too stupid to do this intentionally (which is a pretty bad argument IMO).

 

[Nifty29]

Based on the number of "mistakes" made in this case that all conveniently serve to trick players into playing the rigged game. Not only did they choose to use a rigged real money game, they used a misleading help file telling people that the RTP for certain bets was 100%, and they used a differently rigged "play money" game that paid out at a higher rate, which would mislead anyone who wanted to test the game fairness without risking their own funds.

I think it's more likely that this was intentional than not. The only argument I've seen to the contrary is that they would be too stupid to do this intentionally (which is a pretty bad argument IMO).

Well I think it's a fair conclusion.

I'm not 100% in agreement with it, but it's fair nonetheless....the statements made by betfred certainly did their position/reputation no favors.

 

[manuels58]

Can you please explain why you think this is unlikely?

I think they knew what they did, and are as guilty as Spielo G2.

I agree, in principle.

If you think about the casinos management, can anyone think (or even dream) that the involved casinos managers didn't ever noticed the unusual and abnormal results/payouts of the rigged games (please bear in mind that we are talking here of years of usage/playing)?
If they didn't, they were (are) incompetent and if I were in the shoes of the casinos owners I would be very worried on how their managers would discover a game paying out over the expected RTP (meaning a prejudice to the casinos owners).

My last assumption is just a way of saying that, as far as we are aware in this thread, I honestly don't know how extent is the group of those who were aware of this "deceit" (let's call it this way).

I also can't understand why there were so many of the posters thanking and congratulate Nordicbet (as an entity) for their decision of removing and reimbursing the players' losses, as if the problem was resolved in definitive and if it was enough for reinstating them back in the Accredited List, itself!
No investigation in order of knowing/clarifying if there was any involvement from anyone (person and/or entity) else?
(Sorry, I'm repeating myself)

On other hand, since both Betfred and Nordibet (by deduction) have accused Finsoft of being the guilty part, it is really very weird for me (I run businesses for thirty years now) that no one from that company comes in and (at least) tries to give an explanation, or an excuse for what happened (even if it was that "human error", or "inadvertence" (as per say "administrative error")?

In view of this behaviour from the several entities involved, and as others have said before, this only happens because the online gambling industry/business assume they can't be touched and so, why give it more rope?

All this really worries me and tells me that the fun I like to get from online gaming... is not exactly that anymore.
As far as this thread is spreading, the more I think I shall stay aside of online casinos

 

[manuels58]

Simple casino operations and the fact that the vast majority of people that work at online casino have only the vaguest understanding of how online games actually work. Most of the casino employees i speak to don't even understand the basics and use things like RNG certification to try and hide their ignorance behind. Very few casinos actually test games in house and even if they did, most of them would test for the wrong things in this instance. In fact - and Chris feel free to smack me if i'm wrong here - i don't think any test their free games at all.

I'd certainly say that ignorance is a weak defence in this instance and this highlights a major issue with the entire industry, but there's a huge difference between intentionally programming a game to cheat and not doing your background checks thoroughly enough.

The one exception to this to my mind is Betfred, but i'm not convinced they actually knew any more than any other casino, just that they got a report back from a partner company justifying it, trusted it and put their stamp on it. It was a stupid thing to do - if you don't understand the issue, hire someone independent who does, don't just spew out whatever the defending party tells you.

And do players have any responsibility on that? Of course they don't.
The incompetence of the casinos employees (from top down) are not players responsibility, instead we players have all rights to not comply with their wrong actions.

Side note: Please don't take me wrong POGG, my comment is generic. I consider you one of the most active and one that have most contributed to make this thread worth it

 

[manuels58]

Based on the number of "mistakes" made in this case that all conveniently serve to trick players into playing the rigged game. Not only did they choose to use a rigged real money game, they used a misleading help file telling people that the RTP for certain bets was 100%, and they used a differently rigged "play money" game that paid out at a higher rate, which would mislead anyone who wanted to test the game fairness without risking their own funds.

I think it's more likely that this was intentional than not. The only argument I've seen to the contrary is that they would be too stupid to do this intentionally (which is a pretty bad argument IMO).

At least that argument is not accepted in court, nor in business management, fortunately to all those who complain or make visible this kind of situations and possible schemes.

I then completely agree with you (and I have explained why in previous posts)

 

[ThePOGG]

And do players have any responsibility on that? Of course they don't.
The incompetence of the casinos employees (from top down) are not players responsibility, instead we players have all rights to not comply with their wrong actions.

I understand your point, but i'm not really sure how much more can be achieved.

If you want casinos blacklisted because they don't do thorough internal checks on all games provided, then you'd need to blacklist the entire industry. Next to none of them do this. If you want them blacklisted for not having a strong understanding of their games, once again that's the entire industry. It's the rare individual that i speak to that does have an understanding of game theory. That is an incompetence that pervades the entire industry. As it stands, i'll blacklist them for something that isn't uniform across the industry - making a wilful choice to associate with an organization that's been proven to cheat. All these would have the same ultimate affect on Betfred, it's the ramifications elsewhere that are different.

 

[manuels58]

I understand your point, but i'm not really sure how much more can be achieved.

If you want casinos blacklisted because they don't do thorough internal checks on all games provided, then you'd need to blacklist the entire industry. Next to none of them do this. If you want them blacklisted for not having a strong understanding of their games, once again that's the entire industry. It's the rare individual that i speak to that does have an understanding of game theory. That is an incompetence that pervades the entire industry. As it stands, i'll blacklist them for something that isn't uniform across the industry - making a wilful choice to associate with an organization that's been proven to cheat. All these would have the same ultimate affect on Betfred, it's the ramifications elsewhere that are different.

It wasn't that exactly my point. My point is more generic and pro-active.

The intention of many of the posts / posters in this thread is certainly to contribute to upgrade the regulation and supervision of online gambling industry, thus increasing players confidence on it. At least that's the way I see it.
Otherwise this thread wouldn't be worth it, right?

 

[ChopleyIOM]

I didn't brush anything aside, I removed these casinos as soon as it was affirmed that the software was screwed up. I knew that the players were being refunded their losses - I figured it would have been resolved quicker (as my last post indicates), but at the end of the day - what is important IMO is squaring the players away. This is happening.

With all due respect Bryan (and I absolutely do respect you and what you have achieved with CM over the years, let me clear on that) - but 'squaring the players away' isn't the important thing here.

The important thing here is that we have accredited casinos stating upfront and with no apparent shame that they have no problem offering and profiting from card games that are rigged and cheating BY DESIGN. This point has been repeated time and time again in this thread by many different folks, (folks who are far smarter and better respected than me), they are breaching the terms of their licences and they are demonstrating an absolutely fundamental lack of understanding of fair play.

Betfred stated quite clearly that they bought in the 'fixed price model' (i.e. rigged, fraudulent and cheating) of the game quite deliberately, and all they're apologising for is uploading the wrong help file. Oh yes and having it play differently in free play mode too.....

If a player found himself in this sort of situation and tried the same excuse 'Oh sorry I used a bot by accident' - he'd be laughed out of CM and banned for good measure.

No one here feels that these casinos deliberately tried to cheat anyone. Every casino uses casino software, and I really don't care how outstanding the software is - there will always be issues via bad programming or simple human error. This situation is more complicated because we have a screwed up game that has slipped by the operators as well as the licensors. I think this has surprised most everyone. In fact, this is unprecedented. A situation like this has never happened before with respectable companies like this..

There are only two possible explanations for what happened here.

1) Betfred are corrupt
2) Betfred are incompetent

Neither of which is a desirable quality for an accredited casino IMO.

Were they really running this game for YEARS and no one noticed it was making them a tidy sum of money despite its advertised 100% RTP? They either did it deliberately (corrupt, and there is evidence to point towards that with the help file and free play mode), or no one noticed for YEARS (incompetent).

Ignorance and 'sorry it was an accident' doesn't work if you crash into someone else whilst you're fiddling with your stereo in the car, why does it work for an accredited casino?

I hope the source of your discouragement is not because I brought the casinos back on board. It was clear to me that the situation was being properly addressed. Betfred took longer than I expected, (again, please read my previous post) and they haven't been fully brought back on board yet. But this is a very dynamic environment and I take many things into consideration when dealing with these serious matters.

I'm afraid I must vehemently disagree with you there Bryan.

This situation has not been addressed at all, let alone been 'properly addressed'. The OP has been bought off to make her go away, we have some vague promises that other players might get refunded if Betfred care to find them, (who's auditing that process, by the way?), and even then with a six month limitation.

The core issue of Betfred stating on this thread in plain English that they have no problem with a cheating card game that breaches the terms of their licensing jurisdiction has NOT been addressed.

Most importantly - and this is the crux of the matter - people are listening and trying to do the right thing. And the bottom line is that this is what it's all about: raise an issue and get results. It's not a witch hunt or a casino bashing event - this is a problem that is being addressed and resolved.

I agree that some people are certainly trying to do the right thing, but from where I'm sat that sure as hell ain't the casinos.

And this is not about some accredited list or who is promoting whom. I do not use the Accredited list to punish or reward people - people who know me personally or who have been on this site for years are aware of this. The Accredited section has a very long history, those who are wise to it would understand.

I may have been posting here for less than a year but I've been reading the site for many years, call me a 'delurked lurker' perhaps

If the accredited list is not to 'punish' bad casinos and 'reward' good casinos, what is it actually for then? You may wish to use different terminology, but ultimately, isn't it about the good guys getting the recognition they deserve and the bad guys getting called out on it?

Betfred were off the accredited list for a very short period of time, before the OP had even been refunded, and we have had no statement from them for eleven days. Certainly the issue of them deliberately implementing a cheating card game has not been addressed.

What does their swift return to the accredited list say? What message does it send?

The casinos operators are doing the right thing, and we have the ears and eyes of all operators involved and have been in contact with the licensing jurisdictions as well. Why be discouraged? I could understand this if nothing was happening - if we were getting "speak to the hand" responses and the proverbial brick wall. But this is not the case. In fact, these situations should give you a sense of empowerment if nothing else.

Sorry Bryan I don't feel empowered at all. From my perspective every single safeguard that was supposed to be in place to stop this sort of thing happening has failed in a quite spectacular fashion.

Betfred got away with running this game for years, advertising it with a fake RTP, running a different version of it in free play, and then duping players with a rigged and adaptive version of the game in real play. It absolutely stinks, and to see their name on the accredited list alongside genuinely worthwhile casinos such as Redbet, 32Red and Jackpot Party is a very poor show.

Bet365 are no better, they got the help file right but they still have not addressed Eliot's maths stating that the game should have reached a 97.5% RTP over one million plus games, not 96% as Bet365 stated in this thread. (EDIT - Please note correction from ThePOGG below). Also, Bet365 have no problem with the basic nature of the game, that of it being both cheating and fraudulent and in breach of the code of their licensing jurisdiction.

Nordic Bet did the best I suppose, but I would still have to question what kind of casino would allow this kind of game onto their books in the first place - did they knowingly buy the 'fixed price model' of the game as well?

Please Bryan, which part of this fiasco is supposed to make me feel 'empowered'?

 

[ThePOGG]

Bet365 are no better, they got the help file right but they still have not addressed Eliot's maths stating that the game should have reached a 97.5% RTP over one million plus games, not 96% as Bet365 stated in this thread.

To be fair about this, Bet 365 stated that the RTP of Reel Deal was approaching 96% after one million rounds and my understanding is that the paytable of Reel Deal at Bet 365 would produce a 96% RTP. They haven't release the RTP of Hi Lo Gambler, but Eliot calculated that it should be approximately 97.5%.

 

[ChopleyIOM]

To be fair about this, Bet 365 stated that the RTP of Reel Deal was approaching 96% after one million rounds and my understanding is that the paytable of Reel Deal at Bet 365 would produce a 96% RTP. They haven't release the RTP of Hi Lo Gambler, but Eliot calculated that it should be approximately 97.5%.

Ahhh right my bad there, I'm keeping up with this thread as best I can but it can be hard during a busy working week

I would still say the RTP issue is very much secondary to the real elephant in the room though, which is 'casino says it's OK to present cheating, adaptive and licence breaking rigged card games to their customers as long as they make RTP'.

 

[thelawnet]

It wasn't a testing issue, though. Finsoft deliberately made a card game with two different RTP's and offered it like this to the casinos. Casinos could choose one RTP or the other. Betfred picked the 96% one (or used the default version), but had the wrong help file and ran the 100% RTP version in free mode. Honest mistakes IMO.

Other than that, there's no reason to test anything, the game is working fine and as advertised.

The issue is that Finsoft RIGGED the card game to return 96%.

This is actually extremely serious, because the game appeared by its design to have zero edge, and obviously such a game in theory you can play indefinitely without any expected lost.

It wasn't that they offered two RTPs, it was, as explained by Betfred, that they offered two versions of the game, one honest one, where the advertised payout was changed to reduce the RTP, and one dishonest one, where the chance of winning was less than it should have been, which not only was not disclosed to the player, but has no place in an online casino at all.

Betfred CHOSE, by their own admission, to go for the dishonest game that appeared to be a completely game, but in fact was a rigged one.

 

[Mousey]

I receive a magazine for southen gamblers called Southern Gaming. On page 21 or 22 there is a full page ad for folks to join up to a gaming opinion/advisory group (I thought about joining after seeing ad in previous issue but never got around to it)... Anyway... at the bottom right of the page it says Spielo International. Is this the same group/company we're talking about in this thread??

The

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, but I can't link directly to the page so here's a screenshot...

 

[manuels58]

The issue is that Finsoft RIGGED the card game to return 96%.

This is actually extremely serious, because the game appeared by its design to have zero edge, and obviously such a game in theory you can play indefinitely without any expected lost.

It wasn't that they offered two RTPs, it was, as explained by Betfred, that they offered two versions of the game, one honest one, where the advertised payout was changed to reduce the RTP, and one dishonest one, where the chance of winning was less than it should have been, which not only was not disclosed to the player, but has no place in an online casino at all.

Betfred CHOSE, by their own admission, to go for the dishonest game that appeared to be a completely game, but in fact was a rigged one.

It was because of this that I suggested members to not take premature decisions about who was guilty, and who wasn't.

Bear in mind that Betfred stated their version of the process and their choice, but Nordicbet didn't.

We may ask why was Nordicbet running the rigged version?
If we hypothetically assume they have also been put in face of a choice (the guys from Finsoft most probably have offered the two versions to more casinos, besides Betfred) and they chose the rigged version, are they different from Betfred?
What we know anyway is that Betfred gave us their statement on what they based their decision on (something that has played against them, actually), but Nordicbet didn't. Why?

 

[ChopleyIOM]

As per the end scene from 'Wargames', I've reached the conclusion that 'the only winning move is not to play'.

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[Balthazar]

The issue is that Finsoft RIGGED the card game to return 96%

I know that, that's what I'm saying. People were talking about the need for casinos to test the games, which is irrelevant to what happened. I give the casinos the benefit of the doubt for using the wrong help file, but they knew what they were doing when they were running the rigged games. That was the point I was trying to make.


I think this thread has reached an impasse at this point. It looks like the casinos won't make any more statement and will stay accredited, Finsoft will keep making games and everything will go back to "normal". Virtually no consequences for everyone involved.

 

[manuels58]

I know that, that's what I'm saying. People were talking about the need for casinos to test the games, which is irrelevant to what happened. I give the casinos the benefit of the doubt for using the wrong help file, but they knew what they were doing when they were running the rigged games. That was the point I was trying to make.


I think this thread has reached an impasse at this point. It looks like the casinos won't make any more statement and will stay accredited, Finsoft will keep making games and everything will go back to "normal". Virtually no consequences for everyone involved.

Unfortunately and sadly, I must agree with you.

 

[sapit222]

As long as members/people in here & on other sites continue to write about this & similar "accidents" (cheats?) it will never go away!
Its only been a few weeks since it came to light about this. Surely there is more members in here & elsewhere that can investigate or post/write more on this site & other sites?

 

[manuels58]

As long as members/people in here & on other sites continue to write about this & similar "accidents" (cheats?) it will never go away!
Its only been a few weeks since it came to light about this. Surely there is more members in here & elsewhere that can investigate or post/write more on this site & other sites?

I can also agree with this (ref. to my post #458) but, quoting Balthazar again, virtually no consequences...

 

[ChopleyIOM]

Every single player has a very powerful weapon in their armoury.

They can stop playing.

 

[manuels58]

Every single player has a very powerful weapon in their armoury.

They can stop playing.

That's indeed a valid solution, but the long term one and the radical/final one, as well

 

[ThePOGG]

Virtually no consequences for everyone involved.

I think that may be jumping the gun slightly - we have both the GRA and the UKGC now investigating various license violations and i think we should follow that process through to the end before we start saying that there's been no consequences.

 

[Jufo]

As per the end scene from 'Wargames', I've reached the conclusion that 'the only winning move is not to play'.

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Off-topic, but ah the nostalgia. Here is another version of this same message along with a good song:

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[asianeyes]

As per the end scene from 'Wargames', I've reached the conclusion that 'the only winning move is not to play'.

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B&m's are the best way to go for fairness. Look for "openshoe" Blackjack & roulette are safe to play. However, in light of the likes of Spielo G2, i would avoid all slots and any of the new dealerless electronic blackjack and roulette tables that "any" B&m's have. Everything electronic should be considered suspect.

Another big plus is you get paid straight away and no BS T & C's.

 

[Richas]

I know that, that's what I'm saying. People were talking about the need for casinos to test the games, which is irrelevant to what happened. I give the casinos the benefit of the doubt for using the wrong help file, but they knew what they were doing when they were running the rigged games. That was the point I was trying to make.


I think this thread has reached an impasse at this point. It looks like the casinos won't make any more statement and will stay accredited, Finsoft will keep making games and everything will go back to "normal". Virtually no consequences for everyone involved.

The need to test is absolutely central as to whether BetFred have broken the law in Gibraltar and it is one thing the GRA should be investigating.

Either the GRA the UKGC or both could yet impose serious sanctions on Finsoft and BetFred for this. They have committed breaches of their licence conditions AND broken the criminal law. They should face regulatory sanctions and be prosecuted both in Gib and the UK. As yet we don't know if this will happen but it should.

The rest of this post is long and dull about why the testing is central to the GRA complaint and breaking the law in Gibraltar so quit now if that stuff bores you...

The casinos are always keen to say that they have a certificate that their software has been tested. They make a big deal of this and BetFred even named the two firms that had supplied certificates for this software (It has to be one of seven approved test facilities -ATFs). Well they use this as a sort of job done stamp in terms of dealing with their customers. I suspect that they are half convinced themselves that this is all they need to do...it really isn't. There is a whole raft more they need to do but they are aware of this bit because certification is a specified requirement in the 2005 Gib Act:

(3) In accordance with the following provisions of this section, a licence
holder shall furnish to the Gambling Commissioner at such intervals as are
referred to in subsection (5), a certificate that the integrity of any computer
equipment used to facilitate the carrying on of the activities authorised
under the licence has been properly tested by a body approved by the
Minister in consultation with the Gambling Commissioner, the Licensing
Authority (if not the Minister) and after consultation with licence holders.
(4) A certificate furnished to the Gambling Commissioner for the purposes
of subsection (3) shall contain the following information−
(a) the name of the owner of the equipment;
(b) the name of any company or individual who carried out the
testing;
(c) a declaration that software forming any part of a random
number generator is fair and reliable; and
(d) such other information as the Gambling Commissioner may
from time to time in writing specify.

Now BetFred have said they had such certification. The trouble is though that their game as it performed for the OP fails that test. The Remote Technical and Operating Standards that they must follow under the act specify what the certification requires:

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11.1 RNG and Game Randomness
(1) Licence holders should be able to demonstrate the fairness and randomness of all
games to the Gambling Commissioner without any undue delay.
(2) The output obtained through the use of the RNG in games shall be proven to:
(a) Be statistically independent.
(b) Be uniformly distributed over their range.
(c) Pass various recognised statistical tests intended to demonstrate a) and b) above
and the absence of patterns.
(d) Be unpredictable without knowledge of the algorithm, its implementation, and the
current seed value (all of which should be secure).
(e) be random and distributed in accordance with the rules and expected
probabilities of the game.

So we have to ask ourselves - how come they have a certificated game operating that fails the certification requirement? Now maybe the two independent ATFs who signed off this RNG don't like being approved testers and wish to exit the business or the software they certificated was not what was deployed on BetFred.

This is surprisingly likely given the Technical standards. this is what thy say about the certificates:

12.2 RNG testing
(1) Prior to the commercial use of a new RNG in the provision of remote gambling
facilities, a licence holder shall furnish the Commissioner with a certificate from an
ATF confirming that the output of the RNG passes recognised statistical randomness
tests confirming that it meets the randomness requirements in section 11.1(2).
(2) The Commissioner will also consider other forms of certifying the fairness and
randomness of RNGs used, such as source code testing, as long as the licence
holder and ATF can demonstrate that it meets the underlying objective that the
gambling is verifiably fair to the customer.
(3) Where appropriate, the Commissioner will recognise RNGs that are tested and
certified in accordance with the requirements of other jurisdictions that licence and
regulate remote gambling consistently with the Gibraltar regulatory model.
(4) Where appropriate, the Commissioner may also recognise prior ATF certification
undertaken on behalf of a software supplier.
(5) For the certification to remain valid there must be no changes to the RNG. Any
changes to the RNG previously certified, needs to be re certified before it is
reintroduced to the live environment.

I suspect number 4 is the problem here -The certificate Finsoft have put up for this software could have been knocking around from ages ago, it could refer to software pre their tweak, to software that is 100% RTP. They haven't just put in the wrong help file for this deployment - the certificate does not match the software deployed either!

(Pogg - BetFred should give you a copy of both the certificates - they are required to under section 11.4 b of the Technical standard).

Unfortunately for BetFred even though they have certificates they don't match the observed performance of the software. They have broken the law on the certification even if it was Finsoft's fault they have failed..... even on the explicit testing certificate that casinos like to talk about.

It gets worse though. There are a number of other testing requirements beyond mere certification that are in the technical standard and so enforced by the 2005 Gib Act. this is a big problem for BetFred as the game ran for years

12.4 Ongoing monitoring
(1) Further to ATF certification of the RNG and game engine prior to being used in the
provision of remote gambling, periodic reviews of the game engine‟s output should
also be undertaken as part of a licence holder‟s arrangements to ensure the ongoing fairness and integrity of its game engines:
(a) A licence holder may perform the following reviews in house on the condition
that:
(i) the in house monitoring methodology has been previously reviewed
and certified by a qualified third party approved by the Commissioner;
(ii) the licence holder has demonstrated to the Commissioner or
Licensing Authority that its practices and outcomes in product
development, change control and testing are reliable and meet
appropriate standards; or,
(iii) the game engine‟s outcome is certified annually to verify the results of
the licence holder‟s quarterly assessments.
(b) Where a game engine has a theoretical RTP (e.g. slot games) a licence
holder should employ reliable and audited means to perform quarterly RTP
analysis of the game engine‟s output.
(c) Where a game engine does not have a theoretical RTP (e.g. poker), a licence
holder should employ reliable and audited means to perform quarterly
statistical analysis of the game engine‟s output including its distribution to
certify that it is in accordance with the theoretical outcome probabilities of the
game engine.
(d) All such reports are to be made available to the Gambling Commissioner on
request.
2) Licence holders should complete a system-wide regression test at least annually.
3) The financial data log files should be reconciled to movements on the accounts to
ensure accuracy and completeness of data used in final result output-based payout percentage and RNG testing.

I know the above quote is long but go back and reread it............ You now know more about the testing requirements than roughly 99% of remote casino staff working for Gibraltar sites and it does not make pleasant reading for BetFred. They need to have documented annual regression tests of this game, quarterly RTP reports, maybe annual new ATF certificates and lastly they have to show that they regularly checked how much money this 100% RTP game was making for them - reconciled against how much it should be making for them!

If they claimed to have done this testing in house and so not need the annual ATF renewal it would be odd indeed if the GRA lets them do that again given their comprehensive failure.

There are other bits of the technical standard where BetFred and Finsoft have clearly failed to meet the standard all of which the GRA should be crawling all over. Here's an example:

12.6 Software development and maintenance
(1) A development methodology for software and applications should be defined,
documented and implemented.
(2) All documentation relating to software and application development should be
available and retained for the duration of its lifecycle.Change control procedures should be implemented in line with the change management policy and should cater for the following:
(a) Approval procedures for changes to software.
(b) A policy addressing emergency change procedures.
(c) Procedures for testing and migration of changes.
(d) Segregation of duties between the developers, quality assurance team, the
migration team and users.
(e) Procedures to ensure that technical and user documentation is updated as a
result of a change.
(f) Procedures to ensure that security control requirements are specified for new
information systems, or enhancements to existing information systems.
(4) The development and test environments ought to be isolated physically and logically
from the live operational systems.

The jury says.....FAIL.

7.2. ‘Play for Free’ Games
(1) Play for free games for no prize are not gambling but should accurately reflect any
„real-money‟ version of the game, and should not be used to encourage those under
18 to use licensed gambling facilities.
(2) In particular, such games should not be designed to mislead the player about the
chances for success by, for example, using mappings that produce different
outcomes than the cash game. Licence holders should be able to demonstrate this
equivalence to the Gambling Commissioner upon request.

The Jury says - FAIL

It also turns out that in my last post I was wrong - software suppliers do need to be approved by the GRA, it isn't just that the GRA can ban them they do need to approve this sort of partnership.

13.4 Other joint ventures
(1) Whilst white label and platform partner arrangements are the most common forms
of joint ventures, any contractual arrangement to share the licence holder‟s
licensed facilities with a third party, such as those whereby a software supplier‟s
games are installed and executed or accessed from the licence holder‟s gaming
platform/infrastructure, amounts to a joint venture requiring authorisation by the
Licensing Authority.
(2) All „gambling software‟ suppliers should be approved by the Licensing Authority.
Whilst the breadth of „gambling software‟ is not being defined, the Gambling
Commissioner would regard any customer facing software used by a licence
holder on which customers could be expected to place significant trust when
making gambling decisions, or seeking gambling transaction information, to be
„gambling software‟, for which the supplier should be approved.
(3) Licence holders should contact the Licensing Authority for guidance on an
application for the approval of a joint venture. A description of the proposed
functionality and the supplier(s) involved should be provided at the outset.

What odds does anyone want to offer me that Finsoft and BetFred failed to get this relationship pre authorised?

This post is again far too long for what is such a simple case. Here is the principle that they broke again and again and again

Principle 7.b (Generic Code 13.1) – “Licence holders are required to use
equipment, software and services that are compliant with the Commissioner‟s
Technical Standards document and take responsibility for any failures in these
arrangements.”

The GRA really has no choice - it has to act and impose tough sanctions if it hopes to remain a credible regulator. BetFred and any others who have the same issue need to get their act together - fess up and do some pretty good disaster management PR work. This case is so blatant, so totally outside of the law and the regulations that

Virtually no consequences for everyone involved.

really means the death of regulated remote gambling, in Gibraltar at least. Other firms who did not do this should be telling the regulator to Act in order to protect their reputation as sites regulated by Gib.

Casinomeister - you have relationships with most of them - why not point this out to them?

Given the complete failure to do the ongoing testing, the software change control, the financial reconciliation and much much more how can it be that a site gets to go back to "approved"...they need root and branch change across multiple departments to get even close to meeting the regulatory standard. They must have ongoing failures in monitoring and control across the whole range of the games they supply or this "mistake" could not have happened for these games - the simplest game of the lot.