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A daily podcast delving into the biggest stories of the day throughout the sports betting and igaming sector.
Charlie Horner (00:01.672)
Regular iGaming Daily listeners will know how much we talk about regulation on the show. One of the biggest storylines of this decade has been the shift to local regulation, which has opened many new markets and the re-regulation of plenty of existing markets.
Mike de Graaff (00:15.0)
No.
Sorry, see a connection issue here.
Mike de Graaff (00:23.078)
All right.
Charlie Horner (00:25.458)
Yeah. Start again. Yeah. I always get a take two. Great.
Charlie Horner (00:32.542)
Regular IGaming daily listeners will know how much we talk about regulation on the show. One of the biggest storylines of this decade has been the shift to local regulation, which has opened many new markets and the re-regulation of plenty of existing ones. With this raft of regulation comes great opportunity for those looking to expand, but there's also great risk and cost attached to that. So how can operators remain compliant in a world of tightening regulations? And where are the biggest opportunities that new markets can offer?
Welcome back to iGaming Daily, supported by Optimove, the creator of positionless marketing and the number one player engagement solution for sports betting and iGaming operators. I'm Charlie Horner and today to discuss all of this with me, I'm delighted to say that we're joined by Mike DeGraf, Chief Compliance Officer at BetComply. Mike, thanks for joining us. How are you doing?
Mike de Graaff (01:25.112)
Good morning my friend. How good, how are you? Happy to be here.
Charlie Horner (01:27.584)
Yeah, I'm very well. Very well, thanks. And yeah, great to have you joining us today 'cause yeah, compliance has been an interesting topic during the twenty twenties. And yeah, it's it's it's great to have your expertise and insights. Y you know, Bet Bet Comply is I think coming up to three years in in business, Mike. what what have you noticed
Mike de Graaff (01:50.53)
Yes.
Charlie Horner (01:52.084)
What have you noticed about that three year period and and how the compliance industry has has been in that period?
Mike de Graaff (01:59.481)
Well it's been a crazy few years from a regulation point of view. Everything is changing, markets are opening, new regulations coming, technical complexity everywhere. there's enough to do, let's say.
Charlie Horner (02:14.815)
Yeah, I'm sure it's keeping you and and your team very busy, that's for sure. But look, w regulations are tightening in markets around the world, not not least across right across Europe. How much pressure do you see now being on operators to keep up with a lot of these stringent new measures and and what are the main struggles that you see people facing?
Mike de Graaff (02:38.99)
So I
I if you asked me this question a few years ago or two years ago, the answer was gonna be different than it's gonna be now because that's how fast this this industry is changing, which is also the core of the issue. We have so many changes, we have so many enforcement actions coming out, things just rapidly changing in an environment that is already fast paced by itself, creates a lot of issues. Now let me unpack that. So if you are
if you're a licensed operator in any local country, you have you you have a bunch of regulations to adhere to. You have your your anti-mund laundering, your responsible gaming, advertising, information security, data protection, the
Depending if you have live studios and offices, there's a whole bunch of other regulation attached to it. It was already an environment where you have a high-risk environment with a lot of regulation that you need like full-time compliance people on to work on.
In twenty twenty six where we are now we the last two years what we have seen is that operators are trying to keep up with changes but wait let me rephrase this.
Mike de Graaff (04:10.23)
No wait, I'm stuck here. I wanted to say something. Can we go back? Sorry.
Charlie Horner (04:14.153)
Yeah, of course we'll we'll be able to edit this, yeah.
Charlie Horner (04:19.359)
Yeah, sure.
So we know that regulations are tightening in markets right around the world and not least across Europe, Mike. How much pressure is now on operators to keep up with a lot of these quite stringent new measures and what are the main struggles that they're facing?
Mike de Graaff (04:36.312)
I think it's the speed of regulation that is changing that is just having its effect on operations as a whole. So it used to be that once every few years or every year or every two years you had a new piece of regulation that you had to attach to your current operation. But now if you're operating in markets like the UK or the Netherlands or or so some some local European markets, you have changes three, four, five, six times a year that you need to adhere to now. So it become it becomes almost a full time job just to keep up with changes.
And then it's not just that you have to make the changes to your operation, then there's also a change management process attached to it, and then that change management might result in that your platform has to get recertified, and then the platform recertified means that you have to issue certificates to your partners in the regulator. There's a whole chain that is behind every single regulatory change that is not to say visible on the front, so it is it can feel pretty straightforward to say, let's have a
We have in the UK coming in now. It's a fairly straightforward thing to propose. Say, we want this because to protect the player. But then what is not visible behind that change is all the changes that I that that that need to happen as well. It's in the product, in the teams, in the policies, in the processes, in the communication. And everything needs to be done on time. And if you miss the mark or if you don't do it right, you either get fined or sanctioned or you do it in such a way that you basically kill your own business.
Commercially. So it is a very tight rope that you're walking, and every single of every other few months you have to jump the rope to another rope and then make sure that you balance that one correctly too. It's while while you're trying to run an entertainment business in the end, right? So it is, and that's a struggle. you're spending a lot of time and resources trying to keep up with changes, trying to follow the regulation while at the same time trying to quote unquote just be an entertainment business.
Charlie Horner (06:38.333)
Yeah, it's it's certainly become a lot more complex in the last couple of years. I just wanna follow up on on one thing that you said there, Mike, which is that this is all, you know, under the under the umbrella of trying to protect players and and keep keep those entertaining environments safe. but do you think that the people who are regulating or setting the the regulations or and making the laws around
around gambling, actually understand some of the complexities involved that that you mentioned there and how difficult it is to introduce and and to amend to those regulations and still have a commercially viable business.
Mike de Graaff (07:17.802)
No, understanding from like lawmakers and and that kind of that side of the aisle, d it's no. it's more you nine out of ten times, maybe even ten out of ten times, it's a wish list that is based on good intentions, right? We want to protect the player, we want to reduce crime, we want to do ABC, but then the solution that they propose afterwards has the exact opposite effect in the end. the
l the the financial vulnerability checks, the ID verification checks, the the constant basically nagging of the player in the sessions of entertainment or or gambling or betting or whatever they they they are doing, creates this friction with the player that you don't want as an entertainer. It's a very
It's very contradicting kind of thing to have in a business, right? That on one side you want to have a a a smoothless UX and like a nice entertainment, n nice playing sessions for players, but at the same but at at at the same time you need to interrupt them after every fifteen minutes, every thirty minutes, ask them if they're still okay in their in in in in ask them if they're still right in their heads, if they're still in control, if everything is okay. maybe are you still the person that you say you were you were six months ago? Give me your ID document again and become
This unnatural way of providing entertainment where at the same time all the players have access to a bunch of other websites that do not have that those kind of friction points that just quote unquote sign you up within 30 seconds and you're playing without any hassle. Now that if you are a player, that it can be very tempting to go onto an unlicensed website or get or or accept a very high bonus offer from an unregulated company.
casino because it looks tempting, it's very easy to use and you're fast in. So it's not easy to stay both compliant and commercially viable nowadays.
Charlie Horner (09:21.053)
Yeah, you mentioned there the players have alternative options and we've seen plenty of campaigning in places like the UK, the Netherlands, Germany and Sweden from trade bodies and operators saying that look, if you in in in introduce, you know, all of this regulation, players are just gonna go elsewhere. and we've seen channelisation rates in some of those markets are dwindling.
Are you seeing this play out in practice and and what can be done to protect those regulated sectors?
Mike de Graaff (09:53.357)
Yeah, yeah, it it's you know it the industry has been saying this a long time, right? We're pushing people to the illegal market with these regulations. It's it's an it's a very old argument nowadays, even. But the numbers are the numbers are there. it's very easy to to verify that it is happening, not to the dollar or to or to the euro, but you can easily see the move of traffic going to unlicensed where regulation increases. now
that now you have the a whole prediction markets angle i as an industry coming up it's it that's a basically an answer to to to the market demand so it think of it like this so Europe
player in a country, UK, Netherlands, name name a local country. And you have this idea of maybe I wanna bet on on a on a match this weekend. you have two options. Yeah you can go to the local license website. you need to verify your whole you verify your identity, they will check your address, they might do a vulnerability check on you. And then if you're ha if if you pass all that you get a what a twenty thirty percent deposit bonus up to fifty quid, something
super capped and then you can bet on your favorite match hopefully. Well at the same time, you have this website that is easy as easily accessible that not just only allows you to bet on the outcome of the match but also on a bunch of other stuff like
Who's gonna who's red cards, corners, throw-ins, the the the options are are are are are abundant, and you get what five free bets and then a 200% deposit bonus on top of your first deposit. and then if you sign up, you're in with 20 seconds. The whole experience for the player feels a lot more tempting to go into. so that so that the money is more easily spent on an illegal operator, on unlicensed operator. Now
Mike de Graaff (11:55.217)
What happens afterwards, well you have no player protection, you have no safety of your funds, all the kind of stuff. You will find out afterwards. But the entrance is shiny on one side with a bunch of options and a bunch of bonuses and a very cool looking product with a very nice UX. And now the other side you have to verify, get give them access to your open banking and then maybe you can bet on the outcome of a match because nothing else you can bet on. It's not a very nice
Competition, right, in that sense.
Charlie Horner (12:27.403)
it it seems like an unfair competition and the the the the licensed operators who are trying to remain compliant are stuck in a pretty difficult position and I I just I'm not sure that this is a fight that can be won from the regulated sector without serious res resources and and and money put into all of the different things that you need to to fight the the illegal sector. What what do you think about that?
Mike de Graaff (12:30.668)
Yeah.
Mike de Graaff (12:56.402)
well I I I've been saying for for years that in order to have a local market thrive they need to be able to compete with what is out what is out there, right? Because because of the choice that that that the players have.
In in our line of work, we we see this by that by the product teams and marketing teams coming to us, to us as consultants and teams and say, we have this product idea that we see in this market, or this feature, or this AI enhanced tool, or they're coming up with all these types of products to compete with the other market. And then we are just trying to navigate, okay, but this this is not allowed because of this, and this is not allowed because of this, and this needs to change this, and then you dress down the whole product or the whole feature.
Or the whole tool down to what is compliant, and now it's not a fun tool anymore. Now it now now beats the whole purpose. And we see that by the increase of ideas and things that are being that are that operators are trying to bring to the market, but are just not able to bring to the market. Because either the the licensing environment or legal framework is written in such a way that if it's not explicitly approved in the framework, then it's not.
Allowed. So some frameworks have like wide interpretation things where you can interpret law in a way that makes a product work in that market, for example. Other markets, the the law is so prescriptive that that if it's not explicitly in there, you cannot bring it to the market. Now, tools, features, products, they change like this. People come up with ideas every week, right? we we see them ever all the time. But having a law changed or a regular piece of regulation changed for a new product.
To be fit into that takes years. That can take one, two, three, four, five years. There's still markets in Europe trying to struggle with approving crash games. I think the market is already almost past crash games in terms of like the trend and the hype and moving into other more and other features. But we're still trying to keep up with the framework in some European markets. And that's just
Mike de Graaff (15:05.176)
That's just creating this whole environment where yeah, i it's an unfair competition from licensed to unlicensed from a product point of view. and that besides the whole financial thing, right? It's very easy to it it's pretty easy to print money unlicensed.
Charlie Horner (15:21.267)
Yeah, absolutely. I think what you're describing here, Mike, is a a situation that is just increasingly complex for regulated operators. That it's it's so hard to remain compliant and commercially viable. and when you're under pressure to deliver, you know, revenue for shareholders and and profits for shareholders, I can imagine it can be quite easy to make mistakes.
And and that can land you with a with a huge fine or you know you you could have your license under review and things like that. So just give us a sense of some of the conversations that you have or some of the struggles that you you see operators have w with regards to this and how easy it is just to make a mistake.
Mike de Graaff (15:54.019)
Mm-hmm.
Mike de Graaff (16:03.906)
Yep. yeah, sure. it it is well very easy to make a mistake, but what what I like to focus on with our clients, what we see in practice for years is the re is the relationship that you build yourself in the environment that you operate in. So you have a regulator to deal with, you have a political landscape to deal with, you have a public opinion to deal with if you are s operating in a certain country. Now
that is already complex to do by itself with a high risk product, but then if we then also start distrusting each other between the regulator and the operator or hiding our cards or
lying to the operator as we have seen in I think of was it two weeks ago the published in the UK an an an a fine issue to one to one operator because they're they're basically lying to them. Now that doesn't help the framework either, right? And what we see in in markets is where operators
that they have a s sometimes a split. You have in in in in local markets like the UK and the and the Netherlands and and and others you have these obligations to r to to report incidents right if something happens within your environment that should not have been happening you need to report it. now what happens when you report it?
You might get investigated, you might get fined. Right? So do you report it? Now that is the question that lives in boardrooms almost every single day. we had a breach in our KYC registration. Someone underage managed to get in, even though we had a very good system, someone managed to get in.
Mike de Graaff (17:48.567)
If you have that situation, you need to report it as an incident. Now we have also seen, and then all operators see that, that even though you report it yourself, even though you've done everything right, even though it's not your direct responsibility because it was a provider that made a tech mistake, etc. etc. etc. Even though you did all the things right, you still get the the fine issued by the regulator. So then then product teams and and tech teams are in the same room saying, Okay, so are we
Going to report this incident. What's the chance of us getting a fine if we report it? What is the chance of us getting a fine if we don't report it? Now, just the fact that that conversation is happening is already showing that the whole relationship is unhealthy. Right? That is that just the fact that we have that conversation shows that the whole relationship is unhealthy. Because what you want as a as a local environment is that you have operators in there that are trusted by the regulator because they've proven themselves in the application process, in the search.
Certification process to be capable of operating in this environment, knowing that mistakes can happen, right? And then you want to create this environment where you have where you talk to each other when something happens. Okay, a mistake was made here, we fixed it in this way. And not just when mistakes, but also with ideas and and what on the on the on the
Subjects that we touched earlier on product innovation and competing with the with the with the sector. I know, for example, that the DGA in Denmark is quite open to this. When you have ideas as an operator that that don't fit in the direct regulation of bonuses and sales, that you can at least speak about your idea to the regulator. Hey, can we do this or is this possible? You want a relationship where you can talk to the regulator and the and where the operator can talk to the regulator and be more transparent about the operations without being
Charlie Horner (19:46.59)
Yeah, absolutely. It seems like there's a a lack of trust that that definitely needs ironing out in the in the months to come. But Mike, let's take a a very short break and we'll come back and we'll talk about some of the opportunities and the new markets that the industry can take advantage of.
Mike de Graaff (19:59.012)
Yep.
Charlie Horner (20:03.539)
Welcome back to iGaming Daily. Now, Mike, the first half was you know, it was it was it was tough. It was there's a lot of compliance, there's a lot of, you know, regulation and things that people need to be aware of so they don't get fined. But let's not forget that compliance also brings with it opportunity, because there's new markets that people can take advantage of. And I just wanted to highlight three markets in particular that either have recently opened or are set to open.
in in the coming months. first of all, just last month it was Alberta over in Canada that that opened. What's some of the main things to consider for market entry there and what sort of level of interest have you seen in that market?
Mike de Graaff (20:49.35)
demand I think pretty high, you know. we have about what is it a bit over twenty five to thirty or life now in Alberta, I think. It's five million population, it's quite substantial. the framework is very similar to Ontario. so that if if you are licensed to operating in Ontario it will feel very similar. there's even some some expedited processes possible if you are licensed in Ontario.
So it is a I think it was a fairly good fairly good opening. it's nothing special. I expect I expect similar growth as in Ontario. It's a good value value market. Now the thing that Ontario has that that a lot of people speak about on the floor is that breaches happen more
often because the fines are very low to local operators. Now that's a weird thing for me to say based on the the the previous topics that we had. But if you have massive breaches and then you get a fifty K fine, no that's a budget talk that is that is
over in in two minutes, right? That's a risk. if you if you have a 50k risk for a certain breach versus in the UK where you can get a few hundred or even a few million K fine for s for the same type of breaches. That no those conversations are different. But that's a different topic. Alberta is is a very interesting market. But it's not there's there's not much special there that I would like to discuss. I think there's other markets that have some some developments that I think are worth
Discussing. I think Finland and New Zealand are are interesting ones. Because I get the question quite a lot. because we also help operators go into Finland and into New Zealand. But I'm I'm not so optimistic at all anymore about those about those markets. I think Finland is dead on arrival. yeah, there's I don't see how
Charlie Horner (22:27.849)
Sure.
Charlie Horner (22:49.087)
Tell us a little bit about that. Why what what's What is it about the Finland system that makes it dead on arrival?
Mike de Graaff (22:56.206)
Well.
Mike de Graaff (22:59.904)
If you just look at the numbers where you see the amount of applicants that we have right now in there versus the population that is in there. that that's just a easy sum. There's not not even half of them are gonna survive that commercially. but then we have some of these
regulations like the the ban on affiliate marketing, which is if you design something like that up front, you you you're you you're dead on arrival. The affiliate market in for Finnish players, and for anyone that has been longer in iGaming than two weeks knows that Finnish VIPs and Finnish gamblers and Finnish affiliates are massive. They generate a lot of traffic.
If you s ban affiliates, it doesn't mean that the affiliates are gonna quit their job and find something else to do. You know? They're not gonna switch careers. They're gonna stay affiliates, but they're not gonna channel towards license. They're gonna channel towards unlicensed. They're gonna find another way there to divert the traffic because that's what they do. And if you allow if you keep them controlled within the environment, like Bulgaria's trying to do now, a bit late to the party by you know
re mandating supplier and licensing for even affiliate, but allowing them.
Then you help the then the affiliates help you with your channelisation. Like I said, it's not that if you st ban affiliates that they stop working, they will work against you because they will continue to work. So that is just gonna be a massive pain, besides the whole bonus restrictions and all the duty of care and and technical complexity that we see in other markets that they copied for Finland. That besides all that, just the fact that you're banning affiliates from the start.
Mike de Graaff (24:49.324)
Already shooting yourself with a shotgun in the foot. and then having that many applicants in there competing for the same small population, it you need to have a very good marketing plan, very good brand awareness plan, because you're not gonna be able to do this on bonus acquisition or a video, some some some aggressive strategy that you're used to in other markets. So you need to have very deep pockets, a very good plan for the marketing and and endurance because we're like
Hold your breath because you're gonna need to sit it out if you wanna survive. So that's Finland. No, no, I think the the unlicensed environment will have you know they will keep printing money and they will have the affiliates for them, working for them because they don't need to channel to licensed.
Charlie Horner (25:24.285)
No small feat then. So
Charlie Horner (25:38.441)
Absolutely. Well you don't seem so optimistic about New Zealand either, Mike. So what what sense are you getting about the framework in New Zealand and and why are you a little bit more pessimistic about that market as well?
Mike de Graaff (25:45.184)
I was.
Mike de Graaff (25:52.867)
Hmm. if you see some of my other publications or interviews from last year, I was a lot more positive about New Zealand actually. Because of the fact that they're doing this closed environment of 15 operators issuing the licenses by auction.
And and I know from in general that New Zealand has quite a liberal advertising regime. It's one of the two countries on the planet that allows pharmaceutical companies to advertise, for example. so I thought, okay, you have a liberal advertising environment, closed system, 15 operators. that sounds like a good recipe for for a local market, you know, 15 viable operators in there, doing their
thing and and and and generating revenue and and pouring back into the country by via contributions in tax okay that sounds good but then if you think about what is actually then going to happen now
What they did not do is the cooldown for offshore operators, for unlicensed operators, or something similar. So, what does that create? Both the operators that currently have the New Zealand players and the and the operators that don't are gonna be competing for the same licenses in an auction. 15 of them, right?
So one side already has the players, knows the exact value of those players, because they have been generating the money. So they know what to bid, how much the license is worth, and if they win the license,
Mike de Graaff (27:36.503)
They just need to make the players aware that they are now licensed and they can re-home them under their database. So the acquisition cost for them is going to be very low, right? for the current offshore operators. Whereas new operators, maybe new local New Zealand companies, for example, they do not know the player value because they don't have these player data from offshore databases. And if they win the license, they have to actually go out there and acquire the players for a higher cost.
So it becomes unfair from the start, and it heavily favors the currently unlicensed offshore operators. Because imagine if you are a new operator, let's say you are a New Zealand company, a local company, you say, we have an online environment coming. I want to start a New Zealand casino online in this environment as a New Zealand entrepreneur, and I'm gonna do this. You're going to compete in this auction. Yeah. What does it say if you win?
If you win that auction, it means that you are paying more for a license that someone that knows the value of the player is willing to pay.
So that means you basically so you're losing. Because if you are paying more than someone that knows the value is willing to pay for, then you basically bought yourself something that is not worth the money. Because otherwise, you would have lost the auction to that person. Right? So I I want to see how this plays out. Because it's not just that you have to win the auction, because winning the auction doesn't mean you get the license. Winning the auction means you get the the right to apply for the license. You can still get denied during application.
Charlie Horner (28:46.207)
So you're already losing.
Mike de Graaff (29:16.048)
Process for integrity or other issues. We'll see how strict they actually are in that process. And if that means that maybe other applicants have a have a chance at getting one of these licenses. But if they don't, what you're just gonna see is the 85% market share that is now being held by by what is it, five, six, seven operators. It's just gonna be divided between the same licenses, but then under a new.
so yeah, I I thought it was gonna be a great model. same with Finland. I thought upfront that Finland that's a massive gambling market. If they localize if they locally regulate that properly, that's gonna be great. But then when they actually start doing it and regulation comes out, people come with ideas and they you see what they wanna do, I lose my optimism.
Charlie Horner (30:08.467)
Yeah. Well after that explanation, it it's no surprise really, and it goes I think it goes back to the conversation we had in the first half as well, where lawmakers and would-be regulators just don't necessarily understand the industry that they're trying to regulate or legislate for. which is a slightly pessimistic note to to be on. But what
What predictions do you have for the direction that the industry is heading in throughout the next couple of years, Mike? It seems to me that you're not terribly optimistic about about the the regulatory landscape that we're in. And I guess as a follow-up to that, what would your top piece of advice be for operators who don't want to face, you know, license suspension, a huge fine, and and just want to be commercially viable in these complex markets?
Mike de Graaff (30:45.731)
Yeah.
Mike de Graaff (30:57.836)
Yeah. well there are again more markets coming. I think Austria is going to to open up which does have the cooldown criteria for for offshore operators, but then
Probably f through other pieces of secondary regulation or requirements they're gonna miss their target again. So I I don't I I don't think Austria will now be the shiny example of we learned everything from everyone else and we're gonna do it great. But let's see. Let's see. We have you know, as Beth complain, we have some we have done openings, market openings for years. You know, we've done we've we've seen Netherlands, Ireland, we've Finland, Alberta, New Zealand,
What we
what we keep seeing is we will probably keep seeing, but what I will what I have been saying, I will keep saying whatever we can do as in our control as the industry, we need to do. Meaning we cannot show up to a regulator unprepared. We cannot show up to a regulator with shitty paperwork. We cannot we cannot hide our cards. We you're operating in a high-risk industry, you
offering a high-risk product everyone is aware do your best and be transparent from the start if you are going into a market that is locally regulated like that
Mike de Graaff (32:31.18)
We have seen it with our clients. You know, none of I've never seen a fine issued for any type of advice that we have given to our operators. We have never seen audits fail for that same reason. Because people are people, a regulator has people working there, a certification lab has people working there, and people work with people. So it's not just a tick box, someone is reviewing your policy.
See, someone is looking at your data, someone is looking at what you give to them or not give to them. so if you don't treat them as people, or if you don't treat, or if you treat them as stupid.
You're gonna get the relationship that you don't want, which is distrust. And as soon as something goes wrong, you get a slap, you get a fine, you get you get a suspension. But if you do this right from the start with the right intentions, be transparent and learn from your mistakes together, then the mistakes that happen result in a small slap on the wrist or an informal warning, but it doesn't mean the end of your license or your operation. And we need to start doing that collectively when we go into markets like Finland or or New Zealand.
Do this right from the start, take it seriously and be transparent, don't hide your cards.
Charlie Horner (33:51.296)
Fantastic. Well, great advice there, Mike. Thanks ever so much for your expertise and insights here. And I think people will be able to reach out and book a meeting at SPC Summit in in Lisbon as well to to, you know, maybe get some of those relationships and and those conversations around trust kicked off.
Mike de Graaff (34:06.36)
So Yeah we'll we'll we'll be there. Happy to to meet up. yeah see ya you can find us in the player protection zone. if you do need any advice going into heavily regulated markets or if there's an issue that needs fixing, you either find me or one of my beautiful team members.
Charlie Horner (34:25.61)
Fantastic. Well, Mike, Chief Compliance Officer at BetComply, thanks ever so much for your time. Thanks to Optimove for supporting the show as always, and to our listeners. Thanks for tuning in to today's episode of iGaming Daily and come back tomorrow to keep up to date with all the latest global gambling news.