Road to Safer Gambling Week: The Game Studio Journey


Dangerous/Safe

As we continue our journey on the road to Safer Gambling Week (17th – 23rd October), we make our last stop off with the game studios. A brilliant opportunity to get the perspective from some our industry’s leading content providers.

Once again, iGamingFuture has brought together some of our industry’s most forward-thinking and influential stakeholders to examine the current state of responsible gambling in our industry and most importantly, discuss what iGaming studios can do to further support the ongoing industry campaign for responsible gambling, whilst still pushing industry growth.

Speakers include:

  • Tony Plaskow, Founder of Pixiu Gaming
  • Bryan Upton, Founder, Lucksome
  • Mark Taffler, CCO at Green Jade Games

To what extent do you have to consider responsible gambling as a game studio? Or do you see it as more of an operator concern?

Tony

We have worked very closely with all the Canadian Provincial Governments to supply them with content for many years, so player protection and responsible gaming are a critical element of those partnerships. Moreover, Pixiu, independently, is a staunch believer in fair and responsible practices, in all we do.  We believe our whole industry’s ecosystem will be negatively impacted if we fail to take player protection and responsible gaming seriously. Neglecting such things can only be negative for all of us.

Bryan

We always have to consider it.  We have regulations to think about from our various global markets but of course if our operators have concerns over this then we will as well. This does indeed affect how we design games at a very fundamental level and is a red thread in the evolution of the industry.

Mark

We consider RG hugely in everything we do.  From game design to ensuring we support operators in their pursuit to comply with all necessary localised gambling regulation.  It’s a very important aspect of the industry, one, which, let’s not forget, is in place to protect the player.  The reason regulation exists is so that players (or any supplier for that matter) are protected from unscrupulous casinos taking the money and running.

How do regulations impact the design and development of games? Do they curtail creativity?

Tony

Obviously, there are certain regulatory requirements that games need to adhere to in order to get certified. Those change from jurisdiction to jurisdiction, but we don’t feel they should curtail creativity in any way. in fact, we would suggest that they engender and accentuate creativity because it provides natural challenges to the design process. A key issue is when regulations are too stringent, or limiting, to make it too hard to monetise content effectively and which may push players ‘offshore’ to unprotected service offerings.

Bryan

The clear impact is the increase in the complexity of games development, as obviously not all markets have the same requirements.  Curtailing creativity?  I would argue that it can increase it, but it depends on how involved future regulations will come into game design.  If this happens then we may face they opposite effect to how creative, we can be going forward.

Mark

They don’t, really.  If we weren’t able to design a game that is compliant, we should most likely think of another path! I think we have showed how little creativity is curtailed by the introduction of our Arcade Lobby.

On the whole, are regulations clear or are they too open to interpretation? Would you like more support

Tony

I would say that the industry’s regulators are starting to become more in tune with the companies they licence over time. However, that is an iterative process and new regulations can often be unworkable and/or self-defeating to what a government or regulator is trying to achieve. In general, though, we are finding decent clarity and the North American regulators we deal with are supportive and understanding.

Bryan

It depends on the jurisdiction and the way regulator expresses their wishes, some write them as guidelines, and some write them as requirements.  Some regulations are of course open to interpretation, and it seems reasonable for the industry as a whole to expect clear support and decision making from regulators.

Mark

As with any ruling or law, there are set guidelines which should be followed.  We do a gap analysis on any new regulated market we look to enter, to ensure we are able to adhere to the localised ruling prior to entry.  One territory which provides a slight lack of clarity is Germany.  The whole sub 90% RTP thing is not regulatory, merely a tactic employed by Casinos to overcome the 5% turnover tax.

Is the industry heading in the right direction with responsible gambling requirements? Is there a risk of over-regulation?

Tony

It really depends on where you are talking about. Certain European countries seem to be over-regulating which is pushing players to the black market and hindering the chances for effective progress for everyone in those countries. Marketing bans and overly stringent player/play limits, therefore, might seem appropriate on paper but are leading to a negative impact on both tax income and player protection if it forces players to play on unlicenced sites etc. The other end of the scale is being seen in the US where there is a clear lack of responsible gaming – in New Jersey ow you can collect over $15,000 in what is essentially free money from new-account offers. Aside from the fraught economics of such offers for the operators there is clear danger in allowing players to have ‘bets’ much larger than they would normally place. Thankfully the US is waking up to this quite quickly, but the last few years have not been ideal from a responsible gambling perspective.

Bryan

In general, yes, player protection and AML drivers are always improving based on improved technology and data analysis as they should but placing high barriers of play for players may have the opposite effect of boosting black market play subverting intended goals of regulation.  Over-regulation isn’t a new issue, it has happened in many industries, going through phases of over-regulation and de-regulation – I don’t see our industry as any different.  It is part of our evolution with the heavy influence of the geo-political stage in the world today, creating lots of change for all.  The hope is the over-regulation will soften as more evidential research and consolidated industry dialog comes to the fore.

Mark

You can’t apply a broad brush as the ‘Industry’ stops being one entity when it comes to localised regulation.  Some of the more established markets such as Italy see no issues, everyone knows the rules.  Greece has recently updated some of its regulations which is helpful for the supplier and operator without being detrimental to the player.  Quite a lot of the regulations are aimed at Casinos – no advertising, no bonuses, no VIP’s etc, which obviously has an impact upon the casinos ability to entertain the player to the same extent.  I don’t think over regulation is an issue, more standardised regulation.  The EU is a potential location for all countries within it to fall under similar regulations, however, the elephant in the room is taxation.  When a country is open to receiving a windfall of tax payments it becomes harder to find a balance.

How can we not lose sight of the fact that gambling is entertainment while still protecting vulnerable players?

Tony

This is a challenge that many entertainment products have such as alcohol, tobacco and maybe even food!!! I think it is a very difficult balance to strike between being overly regulated and controlling in a ‘free society’ whilst also providing protection for vulnerable people. After many years of learning, and some mistakes and issues, I think recent surveys show the UK is doing a decent job of it, with problem gambling staying level, or dropping over recent years (shout to Regulus partners for educating us all here!). the key here is that decisions, and regulations, are based on data rather than emotion or opinion – the direction in the UK recently is towards draconian measures for players and operators which, as I state above, might simply drive players to the black market and exacerbate problem gambling with data we may not have access to discover. A hard ship to sail!

Bryan

The key word is sustainability.  If you want the industry, you’re in to last, you have thought long term.  It’s not about maximising profits at whatever cost short term.  It’s about the idea that gambling is a form of entertainment that people can participate in regularly like any other without the causing harm to the vulnerable. This is a deep collaboration from all sides of the industry, governments, regulators and players, which a clear evidence-based approach to ensure that the vulnerable are identified quickly and protected, creating sustainability and industry transparency.

Mark

I still think affordability checks solve some of the potential problems.  If a billionaire wants to bet 10 million a week, the chances are they can afford it.  They should be free to choose what they bet in safety – e.g., not having to use an unlicensed casino. I see various statistics, but the percentage of problem gamblers is still low – maybe sub 3% in some markets. This should not be taken lightly at all, but problem gamblers just as addicts of any substance will find a way to get their fix be it online or at the track.  We need to continue to offer entertaining content to players via regulated casinos.

Editors’ note:

From speaking with these industry leaders, it’s really encouraging to see that the content providers have a firm grip on what’s needed to create a safe gaming industry whilst still keeping it fun. Regulation is not curtailing creativity, which is great to see. The only issue is the effect regulation has on the whole industry in general, which will affect everyone. With increased collaboration between the different groups of stakeholders, we hope to see this improve going forward.

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