Playtech rigged slots?

[Richas]

You have no legal expertise, so it is pointless going on about EU/UK Law because Playtech are not bound by them anyway (as you point out). I don't see a problem with having a shared database of fraudsters or any other undesirables.

Playtech is listed on the London stock exchange and is a FTSE 250 company. It is without any shadow of a doubt subject to UK law. They do have obligations to comply with the data protection act and if the database was as described, even if held by an overseas subsidiary and they used it and denied to the person in it that it existed then there is little doubt that they broke the the law and a complaint to the ICO would be upheld.

 

[Nifty29]

Playtech is listed on the London stock exchange and is a FTSE 250 company. It is without any shadow of a doubt subject to UK law. They do have obligations to comply with the data protection act and if the database was as described, even if held by an overseas subsidiary and they used it and denied to the person in it that it existed then there is little doubt that they broke the the law and a complaint to the ICO would be upheld.

You made my point for me.

I'm not a lawyer, so I was echoing what VWM said about PT not being subject to UK law. I didn't know either way.....either did he as it turns out.

I'm sorry if this has been asked already richas....are you a lawyer specializing in this kind of thing? I'm not being a dick....I'm genuinely interested as much of what you say makes sense.

So, why has nobody taken action regarding such a grievous breach of UK law? Seems odd, given that these databases are common knowledge. How would one prove that PT holds information about a player other than that required to create an account? What if it is run by an unrelated entity in another jurisdiction? What would constitute an "illegal database"? If a player is banned, and told he was on a 'fraud" database, what exactly does PT have to tell them? How about a "bonus deny" database such as Rival has across the whole platform.....if it just simply says "deny" and it is automatically done via a logarithmic process in the backend using data from all casinos, and is done within the scope of the privacy terms at each casino, is that illegal? Does PT have to reveal exactly how they work it out? After all, bonuses are not an entitlement under any law I've ever heard of, so isn't it just a business choosing with whom it wishes to do business?

 

[Richas]

I'm sorry if this has been asked already richas....are you a lawyer specializing in this kind of thing? I'm not being a dick....I'm genuinely interested as much of what you say makes sense.

So, why has nobody taken action regarding such a grievous breach of UK law? Seems odd, given that these databases are common knowledge. How would one prove that PT holds information about a player other than that required to create an account? What if it is run by an unrelated entity in another jurisdiction? What would constitute an "illegal database"? If a player is banned, and told he was on a 'fraud" database, what exactly does PT have to tell them? How about a "bonus deny" database such as Rival has across the whole platform.....if it just simply says "deny" and it is automatically done via a logarithmic process in the backend using data from all casinos, and is done within the scope of the privacy terms at each casino, is that illegal? Does PT have to reveal exactly how they work it out? After all, bonuses are not an entitlement under any law I've ever heard of, so isn't it just a business choosing with whom it wishes to do business?

I'm not a lawyer but I did get stuck with the job at my work of dealing with the data protection act when it was introduced OMG that was the 1994 one, I am getting too old. At the time I played a sort of sweeper role on all sorts of stuff. Once you have had to dig into something you tend to try and keep up with any changes.

There may be some way to outsource the operation but It does not absolve the UK company of their responsibilities and of course it is not just using a 3rd Party database that is the issue. The sites are sending information overseas even if it is just the name for them to check. This is the ICO page on that

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Having the database overseas does not get them off the hook. Indeed that may be the bit where they have broken the rules most clearly.

As described I can't see any way that it would be legal. Try this page - the example on a blacklist is fairly explicit (do find blacklist on the page)

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In the real world this is the closest example I know of

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As for why the ICO has done nothing about it...maybe they don't know. I am unsure that just being refused a potential bonus would constitute "damage or distress" and when you apply you likely give permission to basically do whatever they want with your data so it is possible that a single company using just their own database could do this but sharing and effectively blacklisting you with other companies would be hard to justify. Again I don't know the detail but as described it looks like they are breaking the rules.

My experience of contacting the ICO has been fairly positive. If you are on such a list or want to make a complaint about it to them I would say contact them, they are surprisingly helpful but I would also say spend a bit of time exploring their website first - it is a remarkably well put together site.

 

[binary128]

First of all, I'm sorry for the late response. I realize that this is not in context with the current state of the thread. However, this thread is moving faster than I can.

The minor corrective actions from the audit are the sort of thing I would have expected. It does suggest the close detail involved in the audit and does tend to suggest that what we have had reported here is in a different league to that sort of corrective action.

Yes, I would have to say that the Audit analysis of all of our games was very detailed and thorough.

I received daily status reports on their (SQS) progress. I believe that there were two SQS people (technicians) assigned to the analysis of our games. The daily status reports typically included results on 4 games. Thus, 1 technician was analyzing 2 games per day.

We would not have been approved for AGCC accreditation until all of the Minor Corrective Actions had been addressed, confirmed and accepted. Therefore, regardless of whether a specific Corrective Action had been given the weight of Critical, Major or Minor, approval by SQS/AGCC would have been denied while these issues still existed in the product.

I also agree that all of the issues which have been raised in this Playtech slots thread and in the Finsoft/Spielo G2 thread would have certainly resulted in "Corrective Actions", and it is my opinion that these Corrective Actions would have been weighted Critical or Major.

The re-certification examples in game operation that you have were very visible changes. They were important but they altered the defaults on entry or introduced new options - highly visible but not really a different game or a change in the likelihood or game operation. I can see that the cost of re-certification for these would seem (well be) burdensome for what in other industries would be a standard user interface enhancement.

The examples that I provided earlier for re-certification:

The Slot's "min coin amount, min coin count, max line count" and the Video Poker's "min coin amount, max coin count" - None of these changes modified the game's performance in any way. However, they did impact "Player expectations", specifically on entry into the game. Also, this new "default on load" system was documented in the Help files for all of the games (in the "How Do I Place a Bet?" section), so that also had to be verified. (These changes did not take a lot of time to re-certify.)

However, the changes to our slot console for available bet options, introduced here, were significant functional change to the entire bet system interface. That is, if I select the .25 chip and a chip count of 3 (for a payline bet of 0.75), do any/all payline win amounts accurately reflect the win multiplier in the paytable times the 0.75 payline bet? (These changes took 2 days to re-certify.)

As for the RNG re-certification of October 3 2011, this was done long before the AGCC/SQS Audit. In this case, re-certification fell under the requirements documented by iTech Labs.

I provided this in my post as an example of a "hidden change". No one else on the planet was aware, nor would ever be aware unless we told them, that we changed the "background cycling system" of the RNG process.

However, rather than viewing re-certification by iTech Labs as just some "procedural bullshit", I viewed it as an important "final inspection and approval" step. So I ponied up the buckazoids and sent the new system off to the lab for a full set of tests.

I'd like to mention - I also view our monthly game analysis, with RTP report, from Certified Fair Gambling (CFG) in the same light. This is not just some "procedural bullshit" that we go through for the sake of satisfying some certification requirement. I view CFG as an important part of our Quality Assurance systems.

Yes, as thePOGG has pointed out, it is a "paid for analysis". But if I had an employee on staff doing the same thing each month, then:

1. I would also pay them for the work.

2. Anyone I might hire for this work would know a hell of a lot less than CFG on what to do and how to do it.

This leaves me thinking that there is a high cost in time and money to recertify and so there is a big incentive to not recertify for less visible but potentially far more significant changes to the game play and rtp. If the help file is unaltered and if the game play looks the same then not recetifying is attractive. This also seems to provide an incentive to have less helpful help files - the less info they have in them the less likely they are to change and so make some other change visible and thus more clearly requiring the expensive recertificaton.

If this speculation has some truth to it then we have a perverse incentive driven by the regulatory recertification cost to provide as little game description as possible, to avoid visible change and avoid informing players of changes to the gameplay, rtp and potentially optimal strategy not so much to deceive players as to avoid triggering recertification.

A valid, although really cynical, point. Regardless, it's far too late for us (although we do have the possible out that very very few people read what we publish).

Is there any guidance (beyond touching the RNG) on when recertification is required?

Yes, there is extensive "guidance" here. If you re-read what I've written above, you'll see that re-certification is required for some relatively minor things. I can guarantee you that re-certification is required for anything further up the scale in terms of game changes (both visible and not visible).

Again, I don't view any of this as just "procedural bullshit" - a waste of time and/or money. I view it as an important part of our Quality Assurance systems, protecting the Player, the casino and the software provider.

Chris

 

[Richas]

A valid, although really cynical, point. Regardless, it's far too late for us (although we do have the possible out that very very few people read what we publish).

Yes, there is extensive "guidance" here. If you re-read what I've written above, you'll see that re-certification is required for some relatively minor things. I can guarantee you that re-certification is required for anything further up the scale in terms of game changes (both visible and not visible).

Thank you again for your time in responding to this. I do try to fight down my cynical demons but what you have said about the extensive guidance about when recertification is required only makes me more confident that the problem here is not really about play games differing from real - even though that is a clear regulatory breach both for it existing and how it got there (poor change control/quality control). That is a symptom of other failures. To me it is about

1) changes to games that should involve recertification but where recertification is avoided
2) a common industry practice of failing to describe the game and likelihood of winning as already required that makes 1) easier.

Players should be told if the game changes. That really is not a demanding regulatory or ethical requirement.

I don't buy that there is some conspiracy to defraud/deceive - cock up is always more likely than conspiracy but we have had weeks of accepted and certain cock up. Even without full disclosure I am impatient enough to be looking at solution mode and for me that is the regulator enforcing some reasonable disclosure on likelihood of winning an how the game determines winners and the regulator making changes to game play and likelihood of winning certain requirements of recertification (which to be honest I think they are anyway but some avoid it).

To me it looks like increased insistence from the regulator on these issues would have zero impact on how Galewind operates.

I don't demand blood on the floor over breaches in regulation but this is looking more and more like a systematic failure of recertification made possible by a systematic failure to describe game play and likelihood of winning/determining the award of prizes - something that is supposed to be required.

To me it looks like an industry where today most providers are cocking up and time for the regulator to kick butt on the issue to restore confidence.

 

[binary128]

I don't buy that there is some conspiracy to defraud/deceive - cock up is always more likely than conspiracy but we have had weeks of accepted and certain cock up. Even without full disclosure I am impatient enough to be looking at solution mode and for me that is the regulator enforcing some reasonable disclosure on likelihood of winning an how the game determines winners and the regulator making changes to game play and likelihood of winning certain requirements of recertification (which to be honest I think they are anyway but some avoid it).

I don't demand blood on the floor over breaches in regulation but this is looking more and more like a systematic failure of recertification made possible by a systematic failure to describe game play and likelihood of winning/determining the award of prizes - something that is supposed to be required.

To me it looks like an industry where today most providers are cocking up and time for the regulator to kick butt on the issue to restore confidence.

I think that at least part of what we're seeing here is the natural and expected confusion that arises as a result of "fundamental changes to the way things work".

Casinos, software providers and Regulatory agencies are going to have to get used to the fact that at some point they'll actually need to do what is documented in all of these standards.

Obviously, eCOGRA led the way here, and as I understand it eCOGRA continues to provide (extensive?) consulting services to these newer Regulatory agencies.

Experienced consulting input is a great help in generating a Regulator's "Battle Plan". However, it is up the Regulatory agencies to "put, and keep, trained troops in the field to implement that Battle Plan". Otherwise, this Plan is just words on paper, and nothing has really changed.

In a previous post I was talking about the advantages of working with Certified Fair Gambling because Eliot Jacobson comes from the Casino world.

About CFG I had this to say:

You're not force fitting some generic Quality System Standard (ISO 9000 and their ilk) onto the very special case of online Casinos. I really can't think of any other market where some (many?) of the businesses are actively trying to steal money from their customers, and some (many?) of the customers are actively trying to steal money from the businesses.

I think that unless you approach that market, and the auditing of that market, with that perspective, and the detailed knowledge and experience required to deal with it, well then you're just attempting to shoehorn the same control systems onto online gambling as one might apply to the manufacture of door hinges.

Given that the history of this industry is ...

- non-disclosure as Standard Operating Procedure.

- the software providers generally do not have any responsibility for their licensees.

- the software providers generally remain hidden behind those licensees.

- game performance information is limited to what you can find on reference web sites (like the WizardOfOdds).

... I'm sure that one of the biggest challenges in writing up these new regulatory standards was dealing with the question - "Given what we're starting with, just how far do we go?" Shooting for the stars is well and good, but a more Earth-bound target has a higher probability of being hit.

So some of the language is not crystal clear and definitive, leaving all parties with a little bit of "wiggle room".

I'll end as I started - I think that at least part of what we're seeing here is the natural and expected confusion that arises as a result of "fundamental changes to the way things work".

Chris

 

[ThePOGG]

I don't buy that there is some conspiracy to defraud/deceive - cock up is always more likely than conspiracy but we have had weeks of accepted and certain cock up. Even without full disclosure I am impatient enough to be looking at solution mode and for me that is the regulator enforcing some reasonable disclosure on likelihood of winning an how the game determines winners and the regulator making changes to game play and likelihood of winning certain requirements of recertification (which to be honest I think they are anyway but some avoid it).

To me it looks like increased insistence from the regulator on these issues would have zero impact on how Galewind operates.

I don't demand blood on the floor over breaches in regulation but this is looking more and more like a systematic failure of recertification made possible by a systematic failure to describe game play and likelihood of winning/determining the award of prizes - something that is supposed to be required.

To me it looks like an industry where today most providers are cocking up and time for the regulator to kick butt on the issue to restore confidence.

I don't buy this as a conspiracy either, but i do think that it goes beyond cock up well into the realms of wilful negligence (or burying your head in the sand for a less emotive turn of phrase).

Over the two separate issues, separate but convergent problems arise. With FinSoft you have a huge game supply company that has made no effort what-so-ever to familiarise itself with the basic principles of online gambling or the licenses' of its clients.

With Betfred (and others to one degree or another) you have a group that has actually shown a fair level of contempt for its players. I'm sorry Aaron, this is in no way intended as a personal attack, but the last statement released was actually appalling. In refusing to acknowledge evidence not gathered by 'supplier approved' testing they've both demeaned the hard work of the people involved in gathering evidence and instilled an obvious conflict of interest. The company who's integrity is being investigated are the same body being allowed to decide which evidence is admissible - this certainly appears to allow aspects of this situation that are inconvenient to be ignored. Case in point would be the Aladdin's treasure game, where in a half hour of testing by anyone at their end would be enough to prove the issue and given the attention it's received if the supplier were in any way interested in acknowledging this issue they would have demanded testing by this point. But instead this breach of license has been ignored as the original evidence wasn't submitted by a 'supplier approved' testor.

Then we have Playtech. If you fundamentally change the game away from the standards it was originally meant to meet, then of course you are going to need to get the game retested. It's fairly straight forward stuff - if i put my new car design in for emissions testing, then i change the way the engine works, of course i'm going to have to have the emissions testing done again.

But the truth of this is that all of these points are convergent in one area and that is a lack of discipline. If as a teacher i allow my class to call me 'Mr T' or swear this week trying to get them to stop next week is far more difficult than simply having not let it happen in the first place. The GRA have maintained a good reputation as online gambling regulators go for showing greater commitment to handling player complaints than their peers (for which they should be commended), but they haven't been enforcing all the terms of their license, making these rule about testing, real devices and free play games rules in writing only. They are now left with an unenviable choice; they either have to find a way to enforce their terms as written, not just to the parties involved, but across all their licensees or allow themselves to appear to be just another regulator in name only. And both of these may have largely unpleasant consequence. If they decide to enforce these rules it will undoubtedly create a massive additional workload in the short term making all of their licensees aware of the new standards and putting in place all of the procedures to ensure they remain in place. In fact i would suggest this may be a massive additional workload in the long term as well, on a government department that is likely small. Alongside this, retesting games when changed and meeting the other regulatory requirements is likely to cost their licensees a substantial amount when they could just move to another regulator that has not started enforcing these terms. Taking a harder line could potentially dramatically affect the GRA's client list. If they choose the other route, that of non-enforcement, they lose credibility with players making their license less valuable to their licensees and ultimately may also face some political backlash.

To sum it up, the GRA's slow manoeuvring in this case is likely due to the fact that they don't have any 'good' choices. When no good options exist, it's human nature to be far less decisive.

 

[binary128]

I don't buy this as a conspiracy either, but i do think that it goes beyond cock up well into the realms of wilful negligence (or burying your head in the sand for a less emotive turn of phrase).

With all of these documented regulations being brought before our eyes by Richas, I think it's obvious that all business parties currently under discussion have indeed "buried their heads in the sand." But I also think that's just a "standard bureaucratic response" to change - you only do what you need to do when you need to (or are forced to) do it. Until that time, you just ignore it, or pay it lip service.

I made a post on another forum, but it's worth repeating here. There is a Wikiquote page on Politics. On there, under the label "Government bureaucracy",

You do not have permission to view link Log in or register now.

:

Politics is the art of postponing decisions until they are no longer relevant.

---

Over the two separate issues, separate but convergent problems arise. With FinSoft you have a huge game supply company that has made no effort what-so-ever to familiarise itself with the basic principles of online gambling or the licenses' of its clients.

I think that's a general truth of the current state of the industry. In the (new) 3-legged stool that represents the public interface of online casinos (Players, Casinos, Regulators), the only one that really knows what's going on is the Player. And I think the reason that the Player knows what's going on is because the Player NEEDS TO KNOW what's going on.

I confess, however, that I was surprised at the following post:

Our investigation of the two games in question (Ugga Bugga and Ocean Princess) shows that there was a difference in the RTP between the real play version and the free-play version. We have raised this with the supplier, Playtech, and they agree with our analysis and are deploying a fix, estimated for this coming Monday.

The implication of these 2 sentences is that Betfred needed to do work ("Our investigation ...") in order to get the Software supplier involved in the problem. A simple phone call wasn't enough. (Yes, these 2 sentences may have also been "tactful phraseology" on the part of Aaron (aka, "spin"), and a phone call was all that was actually done.)

In refusing to acknowledge evidence not gathered by 'supplier approved' testing they've both demeaned the hard work of the people involved in gathering evidence and instilled an obvious conflict of interest. The company who's integrity is being investigated are the same body being allowed to decide which evidence is admissible - this certainly appears to allow aspects of this situation that are inconvenient to be ignored.

Or, if you'll pardon the crude reference, it could also just be your "standard bureaucratic CYA response" in the face of a possible "shit storm" on the horizon.

---

But the truth of this is that all of these points are convergent in one area and that is a lack of discipline.

I said in my last post - "I think that at least part of what we're seeing here is the natural and expected confusion that arises as a result of 'fundamental changes to the way things work'." Change is always tough in any "bureaucratic system". Once change stops, the "new way" simply transforms into "the way things are done". In this instance, one of the ramifications of these new regulations would certainly require the application of more discipline.

Re:

The GRA have maintained a good reputation as online gambling regulators go for showing greater commitment to handling player complaints than their peers (for which they should be commended) ...

Have you got any data for that? I would be very interested if you do. I've exchanged a number of emails with a "Gambling Monitor" (I think that's a position title) of the Gibraltar Gambling Commissioner. They've indicated that these sorts of things (complaints, their existence, their details, etc.) are not considered "public records" of the Gibraltar government, available on just a simple request. All of this stuff is considered "private records".

They are now left with an unenviable choice; they either have to find a way to enforce their terms as written, not just to the parties involved, but across all their licensees or allow themselves to appear to be just another regulator in name only. And both of these may have largely unpleasant consequence. If they decide to enforce these rules it will undoubtedly create a massive additional workload in the short term making all of their licensees aware of the new standards and putting in place all of the procedures to ensure they remain in place. In fact i would suggest this may be a massive additional workload in the long term as well, on a government department that is likely small. Alongside this, retesting games when changed and meeting the other regulatory requirements is likely to cost their licensees a substantial amount when they could just move to another regulator that has not started enforcing these terms. Taking a harder line could potentially dramatically affect the GRA's client list. If they choose the other route, that of non-enforcement, they lose credibility with players making their license less valuable to their licensees and ultimately may also face some political backlash.

Agreed, it is a tightrope. Then, in thinking about it for a bit, the expression "tangled web" crossed my mind.

---

To sum it up, the GRA's slow manoeuvring in this case is likely due to the fact that they don't have any 'good' choices. When no good options exist, it's human nature to be far less decisive.

Agreed. I think all of the answers to all of the public questions (and I'd hazard a guess that answers to questions which have not yet become public) - I think all these answers are already available, and I think that all of them basically suck. Multiple deployments of "gaffed games" going back for years, multiple deployments of Play-for-Fun != Play-for-Real going back years, and so forth.

This is also the type of thing that has the potential for a "Snowball Effect". Players with their bits of data, otherwise standing on the sideline, suddenly bring those bits of data to light. Old complaints that went nowhere at the time are suddenly resurrected. And so forth.

Chris

 

[ThePOGG]

Have you got any data for that? I would be very interested if you do. I've exchanged a number of emails with a "Gambling Monitor" (I think that's a position title) of the Gibraltar Gambling Commissioner. They've indicated that these sorts of things (complaints, their existence, their details, etc.) are not considered "public records" of the Gibraltar government, available on just a simple request. All of this stuff is considered "private records".

Ah you caught me! lol

I have absolutely no evidence to support that claim, it was simply a heuristic judgement based of the lack of complaints i've seen and the general good reputation they seem to have with players. For me this seems to be the first time they've really be tested, so when (if?) they come to a conclusion and publish it, i'll be very interested to see.

 

[binary128]

Ah you caught me! lol

I have absolutely no evidence to support that claim, it was simply a heuristic judgement based of the lack of complaints i've seen and the general good reputation they seem to have with players. For me this seems to be the first time they've really be tested, so when (if?) they come to a conclusion and publish it, i'll be very interested to see.

thePOGG,

That wasn't really a "gotcha" question. I'm thinking that if the (new) Regulatory agencies are requiring greater transparency from those casinos/software providers that they certify, then shouldn't the Regulatory agencies also provide a certain level of transparency?

I don't exactly know, because I've never looked, but I'm pretty sure that my local police provide a lot of information on things they do, complaints to which they respond, cases that they investigate, and so forth.

It seems to me that the GRA, AGCC, and others should provide at least summary information for each of the companies that they certify. The number of Player complaints, the amount of money involved in that complaint, a brief summary (100 words or less) about the complaint, the resolution of the complaint, and a brief summary (100 words or less) of the logic that was used to make this decision.

The certified companies are public if for no other reason that they are listed on the GRA (or AGCC) web site. The Players are not "public", therefore it seems to me that there would be neither justification nor value in disclosing any information about them.

Who certifies the certifiers?

Chris

 

[Casinomeister]

Just to chime in here real quick. I do not appreciate how a number of members are coming to conclusions without all of the evidence. This is called speculation. I don't mind people speculating because that's a normal part of a conversation or debate. But speculations are not facts - don't treat them as such. Just because you think something is so - doesn't mean that it is true.

Feel free to debate, but if you attack igaming reps (like Betfred), then you've crossed the line. And if you are doing this to undermine their company - or to damage their company making false statements, you can be held liable. Do not abuse this forum by pushing personal agendas.

@vwm - I have not a clue what you're talking about when you say that Playtech lied to me. I have a relatively good relationship with this company; if you are making comments like this, I'd appreciate a bit of tact because what you said is groundless.

 

[Nifty29]

thePOGG,

That wasn't really a "gotcha" question. I'm thinking that if the (new) Regulatory agencies are requiring greater transparency from those casinos/software providers that they certify, then shouldn't the Regulatory agencies also provide a certain level of transparency?

I don't exactly know, because I've never looked, but I'm pretty sure that my local police provide a lot of information on things they do, complaints to which they respond, cases that they investigate, and so forth.

It seems to me that the GRA, AGCC, and others should provide at least summary information for each of the companies that they certify. The number of Player complaints, the amount of money involved in that complaint, a brief summary (100 words or less) about the complaint, the resolution of the complaint, and a brief summary (100 words or less) of the logic that was used to make this decision.

The certified companies are public if for no other reason that they are listed on the GRA (or AGCC) web site. The Players are not "public", therefore it seems to me that there would be neither justification nor value in disclosing any information about them.

Who certifies the certifiers?

Chris

Who certifies the certifiers of the certifiers?

At some point, the buck has to stop.

The only way it is going to stop is if players vote with their cash, stop playing online, or only play where there is a solid, government-regulated regime in place. Unfortunately, not nearly enough people give a toss enough to bother. You only have to look at the couple of threads here like this one, where it is really only a comparative handful of members who are really interested and passionate enough about regulation etc to participate, and most likely don't read past the first page or the first post, particularly if there are 27 other pages to read.

It's sad, but it's the way things are.

No regulator or operator is ever going to change anything until it starts costing them real money, save for a few ethical ones who can see the bigger picture.

We can debate it until we're blue in the face, but at the end of the say we are a tiny ripple in a gigantic pond that only a handful of people are watching closely enough to see.

 

[ChopleyIOM]

Who certifies the certifiers of the certifiers?

At some point, the buck has to stop.

The only way it is going to stop is if players vote with their cash, stop playing online, or only play where there is a solid, government-regulated regime in place. Unfortunately, not nearly enough people give a toss enough to bother. You only have to look at the couple of threads here like this one, where it is really only a comparative handful of members who are really interested and passionate enough about regulation etc to participate, and most likely don't read past the first page or the first post, particularly if there are 27 other pages to read.

It's sad, but it's the way things are.

No regulator or operator is ever going to change anything until it starts costing them real money, save for a few ethical ones who can see the bigger picture.

We can debate it until we're blue in the face, but at the end of the say we are a tiny ripple in a gigantic pond that only a handful of people are watching closely enough to see.

Unfortunately Nifty, I think you're absolutely right.

I suppose gamblers are, by definition, not necessarily always the most rational and objective bunch of people - and the rogue element of the casino industry knows that, and plays on it mercilessly.

 

[vinylweatherman]

Just to chime in here real quick. I do not appreciate how a number of members are coming to conclusions without all of the evidence. This is called speculation. I don't mind people speculating because that's a normal part of a conversation or debate. But speculations are not facts - don't treat them as such. Just because you think something is so - doesn't mean that it is true.

Feel free to debate, but if you attack igaming reps (like Betfred), then you've crossed the line. And if you are doing this to undermine their company - or to damage their company making false statements, you can be held liable. Do not abuse this forum by pushing personal agendas.

@vwm - I have not a clue what you're talking about when you say that Playtech lied to me. I have a relatively good relationship with this company; if you are making comments like this, I'd appreciate a bit of tact because what you said is groundless.

I will clarify.

During a debate regarding Playtech, you stated that you had visited Playtech's offices in the Philipines. You then corrected this after being told that Playtech had no offices there, and never had. You semed to have been told this by Playtech via an intermediary. Playtech claimed that you had merely seen the offices of one of their operators. In fact, Paragon International Customer Care was NOT an independent operator, but part of Playtech itself. It merely had a company structure designed to put distance between Playtech itself and it's white label operation. The company reports filed in the UK show the facts about the relationship. Paragon International Customer Care was initially set up by the majority owner of Playtech, but was in effect wholly controlled by Playtech through voting rights and board membership. Playtech also had the option to take formal control by buying out the other shareholders, mainly Playtech's founder and part owner. This eventually happened.

This debate arose from various tales from players that made it clear that many supposedly independent Playtech operators seemed to have full access to players' personal information across the entire software platform. This would never happen in a truly competitive environment, it would be like 32Red having details of players at All Slots, and information at a level that would enable them to determine the potential revenue from that player before they had even placed their first bet. Paragon also operate the notorious "abuser database", which seems to be populated by operators sending information that a specific player is of "negative worth" because of their playing style, which other operators can use to decide that a new player they attract might as well be given the boot. This has now been confirmed as fact by the Grand Duke rep.

The other obvious indication was the stream of complaints from players who were asked to send their documents to this Philipines company directly, NOT to the offices of the operator concerned. In the request, the company was not named, but if pressed, players were told that they were sending the documents "to Playtech" rather than the operator as this is where the security checks were done. This stuck out like a sore thumb because the operators involved showed no signs of being connected to an operator in the Philipines. Some that asked players to send documents to the Philipines were licenced by the likes of the GRA, and had well known UK brands. Players were obviously alarmed because the company was not named, it was in the Philipines rather than where the casino was licenced or ran it's support centre, and of course Playtech has not, and never has had, offices in the Philipines.

I identified the name of the company because they put a recruitment ad on the internet - in English, looking for local staff, presumably in Manila.

It would appear that Playtech actually have an operation similer to that of Rival, running a large number of branded skins as white labels from the Philipines. Despite being advertised to players as independent, like the Rival white labels, they are not, they are one big operator, and players are actually playing at a number of casinos in the same group. The problem is one of dishonesty. Players are told the skins are independent, but they are then "punished" because they are treated as though they are playing at a single group, and somtimes get winnings confiscated for effectively having "too many accounts with the group", similar to the problems players have with the Cassava skins, and the Bonne Chance Rivals.

I suspect that the Paragon setup is designed to allow Playtech to be an operator, not just a software provider, but like Rival, uses subsidiaries to hide the connection. Unlike Rival, who also use the setup to hide the ultimate owners, Playtech have to be more open because they are listed on the stock exchange, so have to publish the details in their annual report. It is not a document that the vast majority of players will read, so they can publish something there, yet players may have no idea about it for some years. It seems the connection between Playtech and Paragon appears in company reports from around 2004, long before any of this became an issue in the forums.

I call it a lie because what Playtech said was carefully worded to deceive players who wanted answers to the questions about the "abuse" database and the reason for all their documents ending up in Manila.

"Playtech don't have offices in the Philipines" is technically correct, but substantively a lie. It's because they use a subsidary holding company with a different name, rather than running the operation as a department of the parent company.

"Playtech does not operate an abuser database" is also technically correct, and for the same reason - they run it under the name of their subsidiary.

This does not alter the fact that despite various denials, this abuser database exists, and is freely available to all Playtech operators. For the documents issue, Playtech would have been better off admitting that this was a Playtech office in the Philipines, and that players were merely having their documents checked "in house" by the software provider, rather than the individual operators.

This does not prove that vast numbers of their slots are rigged, but it shows that they intentionally mislead end users as to the true nature of who the operators they are dealing with are, who is having access to your personal information, and how it is being used. It implies that we shouldn't take their word for it over this issue, as they are not suddenly going to change the habit of a lifetime and give a full and transparent account of the matter. They will only want to give out what they feel they can get away with.

 

[Nifty29]

I will clarify.

During a debate regarding Playtech, you stated that you had visited Playtech's offices in the Philipines. You then corrected this after being told that Playtech had no offices there, and never had. You semed to have been told this by Playtech via an intermediary. Playtech claimed that you had merely seen the offices of one of their operators. In fact, Paragon International Customer Care was NOT an independent operator, but part of Playtech itself. It merely had a company structure designed to put distance between Playtech itself and it's white label operation. The company reports filed in the UK show the facts about the relationship. Paragon International Customer Care was initially set up by the majority owner of Playtech, but was in effect wholly controlled by Playtech through voting rights and board membership. Playtech also had the option to take formal control by buying out the other shareholders, mainly Playtech's founder and part owner. This eventually happened.

This debate arose from various tales from players that made it clear that many supposedly independent Playtech operators seemed to have full access to players' personal information across the entire software platform. This would never happen in a truly competitive environment, it would be like 32Red having details of players at All Slots, and information at a level that would enable them to determine the potential revenue from that player before they had even placed their first bet. Paragon also operate the notorious "abuser database", which seems to be populated by operators sending information that a specific player is of "negative worth" because of their playing style, which other operators can use to decide that a new player they attract might as well be given the boot. This has now been confirmed as fact by the Grand Duke rep.

The other obvious indication was the stream of complaints from players who were asked to send their documents to this Philipines company directly, NOT to the offices of the operator concerned. In the request, the company was not named, but if pressed, players were told that they were sending the documents "to Playtech" rather than the operator as this is where the security checks were done. This stuck out like a sore thumb because the operators involved showed no signs of being connected to an operator in the Philipines. Some that asked players to send documents to the Philipines were licenced by the likes of the GRA, and had well known UK brands. Players were obviously alarmed because the company was not named, it was in the Philipines rather than where the casino was licenced or ran it's support centre, and of course Playtech has not, and never has had, offices in the Philipines.

I identified the name of the company because they put a recruitment ad on the internet - in English, looking for local staff, presumably in Manila.

It would appear that Playtech actually have an operation similer to that of Rival, running a large number of branded skins as white labels from the Philipines. Despite being advertised to players as independent, like the Rival white labels, they are not, they are one big operator, and players are actually playing at a number of casinos in the same group. The problem is one of dishonesty. Players are told the skins are independent, but they are then "punished" because they are treated as though they are playing at a single group, and somtimes get winnings confiscated for effectively having "too many accounts with the group", similar to the problems players have with the Cassava skins, and the Bonne Chance Rivals.

I suspect that the Paragon setup is designed to allow Playtech to be an operator, not just a software provider, but like Rival, uses subsidiaries to hide the connection. Unlike Rival, who also use the setup to hide the ultimate owners, Playtech have to be more open because they are listed on the stock exchange, so have to publish the details in their annual report. It is not a document that the vast majority of players will read, so they can publish something there, yet players may have no idea about it for some years. It seems the connection between Playtech and Paragon appears in company reports from around 2004, long before any of this became an issue in the forums.

I call it a lie because what Playtech said was carefully worded to deceive players who wanted answers to the questions about the "abuse" database and the reason for all their documents ending up in Manila.

"Playtech don't have offices in the Philipines" is technically correct, but substantively a lie. It's because they use a subsidary holding company with a different name, rather than running the operation as a department of the parent company.

"Playtech does not operate an abuser database" is also technically correct, and for the same reason - they run it under the name of their subsidiary.

This does not alter the fact that despite various denials, this abuser database exists, and is freely available to all Playtech operators. For the documents issue, Playtech would have been better off admitting that this was a Playtech office in the Philipines, and that players were merely having their documents checked "in house" by the software provider, rather than the individual operators.

This does not prove that vast numbers of their slots are rigged, but it shows that they intentionally mislead end users as to the true nature of who the operators they are dealing with are, who is having access to your personal information, and how it is being used. It implies that we shouldn't take their word for it over this issue, as they are not suddenly going to change the habit of a lifetime and give a full and transparent account of the matter. They will only want to give out what they feel they can get away with.

So, "technically correct" means "lie" when you want it to, but other times "technically correct" is "absolutely correct".

You're a man who insists on precision and "the law". If it is "technically correct", then it IS correct, and hence NOT a lie/deception. More speculation.

FWIW, here is an excerpt from a few PT casinos terms and conditions:

We may disclose (and you agree that we may do so) your personal information to any subsidiaries or associated companies and selected third parties with whom we have contractual relationships (including but not limited to suppliers and service providers).

So, what's the problem? If one doesn't want their information shared, they should not create an account....or are you going to tell me it is all "illegal" and that "the courts would never allow it" etc etc.

You stated PT lied to Bryan. It's a very serious accusation, and nothing you have said supports it.

 

[maphesto]

Some things here! An important question, where can we read about Playtech's denial of office in Manila? I have searched a lot now. What we do now is that there is an office in Manila and that Playtech owes it 100%.

From CM Newsletter feb 2007:

Pacific Congress on I-Gaming It's being held at the Mandarin Oriental Hotel in Macau 26-27 February. I heard that the catering is supposed to be pretty good, so I'm flying out there tomorrow to see if this is true. Actually, I'll be in Hong Kong for a couple of days beforehand to get my sea-legs. And after the conference, I'll be checking out the Playtech offices in Manila. So this means you, my dear ${token2}, can anticipate a bitchin' report on Casinomeister's Asian trek. Stay tuned for that one.

From Newsletter mars 2007:

The following day I was given a tour of the Playtech "live games" office in Manila. A number of you readers may have played these games - playing Blackjack, Roulette, or Baccarat with a young attractive female dealer. These girls are positioned at each table with a camera recording their card action and wheel spinning. It's one thing to see them in action online, but to actually be there behind the scenes was impressive. It's very interactive with the girls being able to "chat" with their players (when traffic isn't so heavy) and there is constant monitoring and supervision going on. I could see how this could be stressful for the girls; they have to smile all the time and look perky, so they are afforded frequent breaks. It must be a nice job though, since players are able to tip the dealers if and when they win. I'm sure this is most appreciated.

From Aug 2011:

Eh!

I was "set straight" about this, and so was Bryan. We were told that this was NOT Playtech, but a different company. The address the OP was told to send documents to comes back as "Paragon Intl Customer Care Limited", rather than "Playtech".

So, if Playtech say "we don't have access to Player's data" - it's a load of bollocks - it is all at "their office in Manila" that they don't have

I don't blame you, this is Playtechs bullshit.


If Playtech still claim not to have an office in Manila, they are calling plexrep a liar.

A chance here for Playtech to cut the crap and tell the truth, as well as stop pretending they have no influence over rogue operators because "we only supply the software".

From sep 2012:

It was "revealed" in a prospectus (related to them being upgraded to the London Stock Exchange's main market) document published in June or July this year, that this company is owned by Playtech.

Paragon is listed as 100% owned by Playtech on page 114 in that document with this info:


Paragon International Customer Care Limited - British Virgin Island and branch office in the Philippines

100% English customer support, chat, fraud, finance, dedicated employees services to parent company

Especially this quote from VWM is important:

I was "set straight" about this, and so was Bryan. We were told that this was NOT Playtech, but a different company.

 

[Richas]

It seems to me that the GRA, AGCC, and others should provide at least summary information for each of the companies that they certify. The number of Player complaints, the amount of money involved in that complaint, a brief summary (100 words or less) about the complaint, the resolution of the complaint, and a brief summary (100 words or less) of the logic that was used to make this decision.
Chris

I am not that bothered about this sort of disclosure re complaints. Stats on that sort of thing are easy to abuse and difficult to present fairly. In addition individual complaints might involve confidential information.

The UKGC requires that a licenced site appoint a third party, independent, arbitrator with some expertise. This body has to be approved by the UKGC. This approach seems to make more sense re complaints and disputes than summarising numerous complaints and their resolution. A zero cost (to player) independent arbitrator seems far better to me than complaint publication requirements.

The goal is fairness to the customer and a fair process with binding outcomes on the site. Publishing the data on fair resolutions whilst maybe interesting is not the main event. Today failure to deal properly with this sort of thing is a good flag on sites to avoid but far better to rise the standards of all sites to make that measure moot.

 

[Casinomeister]

Talk about splitting hairs. These were the offices of Playtech operators - and a company that provided a few Playtech operators their live games. I really can't be bothered with this. You have way too much time on your hands. I wish you spent it doing something else.

 

[binary128]

My phrase "Who certifies the certifiers" was a play on words. The phrase to which it refers - "who polices the police" - was in the title

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from April of 1965. (The phrase could go back further than 50 years - I only did a quick search - but it has certainly been used many, many times since then.)

When used, this "police phrase" was not spoken facetiously or pedantically (as in overly concerned with unimportant details). Indeed, quite the opposite. It was typically spoken at those times when significant police corruption was under investigation. (The 1965 Time article dealt with civil rights abuse. To quote: "The fuss is about ... a series of Negro complaints about mistreatment by white policemen")

In addition, neither the question nor the need for an answer was ignored. Police departments created Internal Affairs divisions. The Time magazine article I referred to concerned a "civilian review board". And so forth.

So, in short, the question "Who polices the police" was seriously asked, and its asking was not considered rhetorical or superfluous (as in unnecessary or more than required).


As to the potential impact of this thread, or other Casinomeister threads, on the issues at hand - I'm reminded of something that Bryan said earlier:

"I'm not about to put this site in jeopardy to appease those few who want blood."

I believe that Bryan makes it very clear here (and in his earlier post from today) that statements or conclusions, even speculation or extrapolation, about these subjects represents the potential for (serious?) harm to this, Bryan's, web site. That strikes me as some major damage from a tiny ripple.


From dictionary.reference.com:

- The definition of jeopardy (within a legal context): "the danger or hazard of being found guilty, and of consequent punishment, undergone by criminal defendants on trial."

- The definition of speculation (as a noun): "the contemplation or consideration of some subject", with synonyms: supposition, view, theory and hypothesis.

- The definition of speculating (as a verb): "to indulge in conjectural thought", with synonyms - think, reflect, cogitate, conjecture, guess, surmise, suppose, theorize.

- The definition of extrapolate (as a verb): "to infer (an unknown) from something that is known; conjecture", with synonyms - deduce, foresee, hypothesize, "make an educated guess", project, theorize

I am not that bothered about this sort of disclosure re complaints. Stats on that sort of thing are easy to abuse and difficult to present fairly. In addition individual complaints might involve confidential information.

The UKGC requires that a licenced site appoint a third party, independent, arbitrator with some expertise. This body has to be approved by the UKGC. This approach seems to make more sense re complaints and disputes than summarising numerous complaints and their resolution. A zero cost (to player) independent arbitrator seems far better to me than complaint publication requirements.

The goal is fairness to the customer and a fair process with binding outcomes on the site. Publishing the data on fair resolutions whilst maybe interesting is not the main event. Today failure to deal properly with this sort of thing is a good flag on sites to avoid but far better to rise the standards of all sites to make that measure moot.

My suggestion on published reports by the Regulatory agencies was said in the context of trying to get "hard data", objective data, on their performance. That is, thePOGG opined that "The GRA have maintained a good reputation as online gambling regulators go for showing greater commitment to handling player complaints than their peers ..." So I asked "Where's the data?" (thePOGG - I do not repeat this to "throw it back into your face", but only as an example to make my point.)

And I don't think that it is the number of complaints that they (the Regulatory agency) receive that is the best indicator of that performance. As I believe I said in an earlier post, mistakes happen and problems arise. I proposed that (in certain circumstances anyway) it was the response to the problem that was a "better indicator" than the occurrence of the problem.

So, if the response to problems is a highly indicative value for use in determining the "competence" of a Regulatory agency, then how, and to whom, does that response data become available? At the moment apparently the answer to this question is - nobody.

---

Casinomeister uses the Jurisdiction as part of the Accredited Casinos Ratings System. I confess I just took a look at it. I'm sorry, but I had to laugh when I saw that Costa Rica was 1.) even on the list, and 2.) was the only jurisdiction that was rated low.

Bryan has written that the minimum requirement for a Jurisdiction is that it "is responsible for its licensees". Costa Rica could (IMO justifiably) be given the heave-ho on this one, since it apparently is responsible for nothing, and technically does not have any "gaming licensees". (Casinomeister's Spot the Rogue says - "Where are they licensed? If they claim to be licensed in Costa Rica or any other place in Central America, you can be sure that they are unlicensed - in other words, they do not have a gaming license but only a business license.")

That opens the list up to the (perhaps more standardized) High, Medium and Low. (Otherwise, all we have is Highest, High and Medium, which sounds a bit like the roadside stand that sells soda in sizes Large, Larger and Largest. )

For High we have the UK, the Isle of Man and Alderney. For Medium we have Gibraltar and Kahnawake. For Low we have Malta, Curacao and Cyprus.

(The above paragraphs are in absolutely no way a suggestion that Casinomeister's Accredited Casinos Ratings System be changed. I simply rearranged it a bit to see it in a somewhat different light.)

---

I asked "Where's the (objective) data?" concerning the performance and competence of Regulatory agencies. I'm aware that some rating systems, or at least parts of some rating systems (restaurant reviews, for instance, or movie reviews) are intrinsically subjective. I'm not sure that the rating system for Government Regulatory agencies should be, or needs to be, as subjective as that applied to a stuffed pork chop dinner.

So, I'm happy to discard the suggestion of reports published by the Regulatory agencies. But the question(s) remain: "what, and where, is the data?"

Chris

 

[ThePOGG]

Just to chime in here real quick. I do not appreciate how a number of members are coming to conclusions without all of the evidence. This is called speculation. I don't mind people speculating because that's a normal part of a conversation or debate. But speculations are not facts - don't treat them as such. Just because you think something is so - doesn't mean that it is true.

Feel free to debate, but if you attack igaming reps (like Betfred), then you've crossed the line. And if you are doing this to undermine their company - or to damage their company making false statements, you can be held liable. Do not abuse this forum by pushing personal agendas.

I'm assuming this is in reference to a post i made a little further up - i apologise if you feel i've crossed a line here CM and feel free to pull anything that you feel is a threat to this site. I would like to clarify however that at no point was the previous statement intended as an attack on Aaron - the Betfred rep or indeed were they intended to imply improper intent by Betfred. In fact the post was made to emphasize the fact that i feel many parties involved are trying to get to the right path but that we need the GRA to step forward before the other parties can.

For the time being i'm going to withdraw from all conversation on this topic.

 

[Richas]

It seems to have gone very quiet on this issue. Hopefully the GRA or Playtech/BetFred will update us soon.

With the UK regulatory changes ongoing the GRA and the Gibraltar Betting and Gaming Association have been submitting evidence to the DCMS select committee which shows how important the remote gambling industry is to Gibraltar:

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This sector directly represents approximately 12% of all employment in Gibraltar and contributes employee earnings of some 17.5% of total gross earnings. The total direct, indirect and induced effects of the online gaming industry on the economy of Gibraltar is £209.7M income, 4,020 jobs, a total output level of £344.2M and contributes overall to total Government revenue by £70.5M (which we have been able to establish having regard to Gibraltar Government published information, represents over 15% of
annual Government receipts). This is thus a significant component of an economy that has a
total GDP of £1,207.5M and just over 22,000 jobs (Fletcher Report (2011).

The impression I get from the GRA input is not just that they are hostile to the UK change to point of consumption regulation but that they feel threatened by it. Their case is that any additional UK licence is unnecessary as consumers are already protected.* Similarly the GBGA seem very upset. Their input is almost rabidly hostile to the proposal and threatens legal action via the EU. Apparently UK consumers are fully protected by the first class existing regime so the UK actually regulating for UK consumers is unnecessary.

It seems to me that if the GRA wants to be considered first class and the GBGA want to assert that we are protected already then action and transparency on this issue is urgently required. We have serious issues here going beyond the alleged software failures - underlying questions about enforcement of the regulations on game disclosure/description and the testing regime and to date we have pretty much nothing from the GRA - no official statement, no clarification of the rules on game description, nowt.

Now I try to be patient but if the GRA want to be taken seriously in their evidence that the UK regulator for UK consumers is unnecessary then action is required pretty much now. This case is bound to be sent to the DCMS select committee as part of this round of legislative review. There are big pressures on the GRA right now but stepping up on this (and Finsoft allegations) is the best option. Ignoring/delaying in the hope that it does not get too serious is unlikely to work out well.


*no mandatory regulator approved arbitration body (though there is a complaint process to the regulator) potential lack of ability to enforce payment, no mandatory cheating reporting, no mandatory UK sports integrity/suspicious betting reporting but in general yes the GRA regime is very similar.

 

[binary128]

The impression I get from the GRA input is not just that they are hostile to the UK change to point of consumption regulation but that they feel threatened by it. Their case is that any additional UK licence is unnecessary as consumers are already protected.* Similarly the GBGA seem very upset. Their input is almost rabidly hostile to the proposal and threatens legal action via the EU. Apparently UK consumers are fully protected by the first class existing regime so the UK actually regulating for UK consumers is unnecessary.

I

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(Note: PDF) the other day published by the AGCC. Their public stance is that they support the new UK legislation. They reference an easy "transition path" for current AGCC licensees, but it was in "Registrar Speak" and not "Human Speak" so I confess I didn't understand it. But I was at least comforted by the existence of the words.

It seems to me that if the GRA wants to be considered first class and the GBGA want to assert that we are protected already then action and transparency on this issue is urgently required. We have serious issues here going beyond the alleged software failures - underlying questions about enforcement of the regulations on game disclosure/description and the testing regime and to date we have pretty much nothing from the GRA - no official statement, no clarification of the rules on game description, nowt.

Now I try to be patient but if the GRA want to be taken seriously in their evidence that the UK regulator for UK consumers is unnecessary then action is required pretty much now.

The sad thing is that the forum posts (CM and others) have been saying "action, or response, or a communique or ANYTHING is required now" for quite some time. "Now" is just a day count that hasn't stopped its upward climb.

Chris

 

[Richas]

The sad thing is that the forum posts (CM and others) have been saying "action, or response, or a communique or ANYTHING is required now" for quite some time. "Now" is just a day count that hasn't stopped its upward climb.

Chris

True.

I shall be more explicit then. My email summarising the issues raised as well as I can and including my views on the lack of response and serious regulatory failures highlighted by the case will be drafted and sent this time tomorrow. It will go to every DCMS committee member, their email addresses are all available on the House of Commons site.

I was a bit annoyed by Philip Brear (the Commissioner) saying in his evidence

The issue of confused customers has been grossly overstated. Where confusion arises it
is often because the brand is a UK ‘High Street’ name, or simply because the language
used is English and the customer has failed to read or react (click) to the information on
the webpage indicating the relevant regulatory body. Additionally, it is universally the
view amongst regulators that the large majority of complainants are remorseful losers
seeking to recover losses, or customers who have knowingly breached terms and
conditions in their efforts to obtain free bets and other bonuses. When these bets win,
the win is declined as the customer has ‘cheated’. The customer then complains.

There may be truth in this bolded bit but it shows a terrible attitude to consumers in general. It also explains why the UKGC goes for mandatory third party arbitration on individual disputes and so is free to deal with regulatory complaints alone. It is also a casual dismissal of confusion in the UK market. of course people betting online with Ladbrokes and William Hill think they are UK regulated.

Ladbrokes saying in their written report to the DCMS select committee

There is no evidence that operators based in Gibraltar have any regulatory failings—nor have
we seen any evidence relating to the other territories where most operators are based.
However the biggest impact of this legislation will clearly be in imposing UK taxation on a place
of consumption basis—something not considered at all in the Regulatory Impact Assessment.

merely made me laugh.

 

[Richas]

Well my email has been sent to all the DCMS committee members and copied in to the UKGC Chief Exec. The recent oral hearing by the committee seemed to make it more relevant so off it went, after all no news seems to be forthcoming from the regulator we have now.

Is anybody else in the EU south west region and so in the same constituency as Gibraltar for their MEP?

 

[binary128]

Well my email has been sent to all the DCMS committee members and copied in to the UKGC Chief Exec. The recent oral hearing by the committee seemed to make it more relevant so off it went, after all no news seems to be forthcoming from the regulator we have now.

Is anybody else in the EU south west region and so in the same constituency as Gibraltar for their MEP?

I truly applaud your efforts here. If, as I've noted at thePOGG, we have the "Industry" to the left and the "Players" to the right, then the (new) Regulatory agencies are in the middle.

Yes, I think we all agree that there is "Player fraud" (in a variety of different forms and manifestations). But the issues being raised here, and in many other threads, demonstrate that there is also "Industry fraud" (also in a variety of different forms and manifestations).

I think there can be little doubt that the "Industry" is a continuous presence in the offices of the Regulatory agencies (or vice versa). I would not be surprised if some members of the "Industry" had employees whose job it was to provide that continuous agency presence (aka lobbyists). The only voice for the Players are forums (with Casinomeister as Commander in Chief of the largest "army"), and efforts such as yours.

So, I give you a "thumbs up" for doing all of the work that you have done here.

Chris