Do the Finnish proposed marketing rules enable a competitive offering?

I originally wrote this text on http://www.finnplay.com in early September 2024.

The proposal for Finland’s new gambling legislation has finally been published, and stakeholders have commented on it. As many as 130 statements were collected during the public hearing process, and now the authorities are analyzing them and thinking about how they might affect the final content. According to unofficial information, the purpose is to complete the legal package during October 2024 and then send it to the EU notification process. At that stage, we will know even more precisely what Finland’s new gambling system will be like.

However, we can already evaluate the future system at this stage because it is assumed that the “big picture” will not change much compared to the proposal published at the beginning of July. As I have stated in my previous writings, Finland’s goal is to raise the channelization rate of the gambling system as high as possible, preferably close to the 90 % level. This is intended to be implemented so gambling companies get the best possible business opportunities. Still, even so, the number of gambling problems should at least not increase but rather decrease.

The business opportunities of gambling companies are greatly influenced by the marketing they are allowed to do in Finland. My focus in this blog is to evaluate the marketing and sponsorship content of the gambling bill. Will the operators acquiring the license have sufficient opportunities to market their brand, products, and services? Are those opportunities better than illegal companies operating without a Finnish license? Will the channeling ability of the gambling system rise to the desired level, and will the gambling problems remain under control?

Marketing will be allowed but limited

Gambling marketing will be allowed in Finland’s new system. Well-planned marketing regulation helps licensed companies attract customers and gambling into the legal system, increasing the channelization rate and enabling the authorities to regulate as much gambling as possible. Fortunately, the legislation’s drafters have finally understood how this dynamic works.

It is a pity that the starting point for marketing regulation is Finland’s current legislation, which only applies to the monopoly company Veikkaus. This shows that the law’s drafters either do not know or do not want to know the legalities of the modern gambling business. For some reason, the officials don’t understand that the current regulation that significantly limits the operation of Veikkaus is the main reason our gambling system’s channelization rate has collapsed, especially in digital sales channels. Veikkaus has been banned from several activities that offshore operators use daily. Active customers, in particular, have switched to other companies following better offers. The restrictions on the operation of Veikkaus would still be acceptable if they would have reduced gambling problems. However, the opposite has unfortunately happened, i.e., the problems have also grown.

In general, I can say that gambling marketing in mass media will be possible without any significant limitations. Still, in digital media, there would be many restrictions that offshore companies are not used to elsewhere. I am afraid that the restrictions may be so significant that at least some potential companies decide not to apply for a Finnish gambling license.

Finland wants to ban affiliate activity

Based on the bill, only the gambling company is allowed to market gambling. This marketing includes both brand and product advertising. The bill states that a “third party” is not permitted to do gambling marketing. However, the proposal does not define what marketing means in practice. Regarding this limitation, it should be noted that affiliate activity is not possible for the current monopoly company, so presumably, the law drafters have also taken this idea from the current legislation and have not sufficiently familiarized themselves with the operations of other countries.

The proposal aims to prevent celebrities and social media influencers from marketing gambling. However, the current definition also includes affiliate services common in digital channels. These services aim to provide sports punters and casino players with information about gambling content. Although these affiliates often make their income from customers’ gambling losses, these sites also offer valuable information to support gambling.

According to my understanding, the share of gambling companies’ new customer acquisition coming through affiliate operators is very high, in some cases even close to one hundred percent. Affiliate operators are search engine optimization professionals and will undoubtedly continue their activities, even if efforts are made to prevent their activities by Finnish legislation. In this case, the affiliates will serve operators outside the system, which will automatically decrease the channeling capacity of the system. This is not in Finland’s interest. Instead, a solution should be found to allow affiliate activity and bring it within the scope of Finnish legislation.

So, I’m in favor of allowing affiliate activity, even though I wouldn’t say I like it. However, I believe it is a better solution for everyone that affiliates can work in cooperation with licensed operators than that they remain tools of illegal activity.

Bonuses are going to be banned

Another common feature of gambling that I dislike is the offer of bonuses. In my opinion, bonuses are, generally speaking, “cheating” customers. However, I don’t think offering bonuses can be stopped in the world’s gambling business. For this reason, I consider the Finnish bill to be a lousy solution, based on which offering all kinds of bonuses and similar customer benefits will be prohibited.

I believe this proposal also originates from the current legislation, based on which Veikkaus is not allowed to offer bonuses, discounts, free spins, or give customers betting money. Such offers are widely used in the international gambling business. In Sweden, the supply has been significantly limited, but there is no complete ban there either. Gambling companies operating with a Swedish license consider the current bonus restrictions to be the biggest reason why the channeling capacity of the Swedish system is now rapidly decreasing. This happens especially in online casino gaming, where companies with a Curacao license take Swedish customers with bonus offers.

If affiliate operators and bonuses are prohibited, new gambling operators coming to Finland will have significant challenges getting customers. This primarily serves the interest of Veikkaus and possibly a couple of other big gambling companies, which already have many Finnish customers, and distorts the competition. Therefore, concerning bonuses, a way should be found to allow them, at least to some extent, in Finland as well.

I propose that bonuses be allowed so the gambling company can only set a wagering requirement of one round for them. The customer could, therefore, claim the bonus money for himself after he has played that amount in the company’s games once. In this model, it would be much easier for the customer to understand what he is getting than in the current offshore model, where the money has to be played dozens of times before he gets it for himself. From the point of view of the operator, the model I proposed is much worse financially compared to the current model, where the companies practically do not give out money at all.

There will be just few restrictions on mass media marketing

Based on the bill, the Finnish mass media has been highly successful in lobbying. In practice, gambling advertising in the mass media seems to be possible almost without any restrictions. Of course, there will be restrictions and prohibitions for marketing aimed at children and other groups of minors.

If the digital media marketing methods increasingly used by offshore companies are banned, there is a significant risk that the general public in Finland will encounter a lot of gambling marketing in mass media – TV, radio, and newspapers. In Sweden, this has caused public opinion to turn negative towards gambling. There has been far too much marketing in mass media, according to the opinion of ordinary Swedes. Finland should not find itself in the same situation because it is against the interests of all parties operating in the gambling business.

I propose that while digital media’s marketing restrictions are reduced, mass media marketing is tightened. One option to be considered could be a restriction according to which the mass media should only contain brand advertising of the gambling companies, which should not include an order to gamble. In this way, the gambling companies would make their brand known among Finns, but people would not have to face the “play now right now” type of advertising against their will. Operators could give such messages in their betting services when customers come to play.

Sports sponsorship will be possible

One crucial marketing tool, especially related to betting, is sponsorship. The bill allows gambling companies to enter into sponsorship agreements with sports and other parties. Restrictions are proposed for sponsorship to prevent or at least limit exposure to minors.

I have previously criticized proposals concerning marketing, but concerning sponsorship, it must be said that I think the bill is well-founded, and its content seems reasonable. However, in the proposal’s arguments, a model is presented for consideration, namely that the gambling company should not be the so-called title sponsor. If implemented, this proposal would make the current model, where Veikkaus is the title sponsor of the Finnish football league, impossible. I think that would be an unnecessary restriction.

Finnish sports, or at least the most prominent sports leagues, are already excitedly waiting for new revenue streams to open up. However, based on the experiences of Denmark and Sweden, I believe that only football and ice hockey will make up for the larger amount of money in the new model.

The Statement of The Finnish Gambling Consultants about the proposed Finnish Gambling Bill

Background

FGC would like to thank the government for the proposal, which aims to open the Finnish gambling market to competition partially. In the preliminary work section of the bill, the situation is well described to which the gambling system, according to the current monopoly model, has taken the Finnish gambling market. The channeling ability of the system in competing product groups has already sunk too low. When planning a new system, it is paramount that the channeling capacity of the system be restored to a high enough level, preferably close to the 90 % level. The responsibility measures that control gambling activities remain ineffective without a sufficiently high channelization rate because the authorities’ measures are only effective for regulated gambling.

FGC considers that there is a lot of good in the given proposal. The channeling ability of the Finnish gambling system would improve significantly if the new Gambling Act were implemented in the form presented. However, the 90 % channelization rate mentioned above would not be reached by this proposal.

Overall opinion on the proposed bill

The good side of the bill is that it aims to create a gambling system where gambling companies have the opportunity to do business, but at the same time, the number of gambling problems should not increase. The goal of expanding the channelization rate as high as possible is the only correct solution from the point of view of the realization of business and responsibility. However, FGC wonders why the essential solution for reducing gambling problems, moving all slot machines to age-restricted premises, is missing from the proposal.

According to FGC’s view, there are several contradictions between the individual sections of the bill and the overall goals. Products with a high-profit rate for the gambling company (Veikkaus) remain on the monopoly side, which is why the proposal inevitably shows that the real reasons for the presented product division are purely fiscal. Fiscal reasons, however, cannot justify a gambling monopoly according to EU law. In addition, the products, except slot machines, proposed for monopoly do not significantly cause gambling problems.

The apparent inconsistency of the bill is in marketing and operations as a whole. According to the proposal, gambling companies could not use bonuses or third parties, such as affiliates. Still, other marketing and sales promotions would be pretty accessible. This includes a significant contradiction in the pursuit of a high degree of channeling and decreasing gambling problems. FGC believes that gambling companies should be able to compete against illegal offerings specifically in digital channels. From the point of view of increasing the channeling ability, there would be no similar need for the abundant marketing of gambling in physical channels and Finnish mass media because illegal operators are not visible in these media. In the best comparison country, Sweden, gambling advertising in the mass media increased enormously some years before the actual gambling system change and has remained at a very high level after the change compared to gambling advertising in Finland. Due to abundant mass media advertising, the general opinion of citizens towards gambling in Sweden became significantly more negative than before because the media was full of gambling advertising.

Based on the proposal, the Finnish state wants to maintain a dual role, taking care of the legislation and supervision of gambling activities and, at the same time, owning the company involved in gambling activities. There is a high risk of conflict of interest in such a model. State ownership of a gambling company operating in a competitive market is at least a questionable solution. The Finnish Competition and Consumer Authority and the Chancellor of Justice have already raised this same issue in their statements.

In this statement, FGC writes its observations about the Gambling Act and proposes corrective measures and changes to the proposal.

General notes:

General note about potentially incorrect information appearing in the proposal

The material supporting the bill is comprehensive and of high quality. However, there is one very relevant piece of information in the background material that we believe is debatable, if not even incorrect. In the preliminary works, it is implied that the channelization rate of the Swedish gambling system would have remained high in recent years. The Swedish authorities’ assessments of channelization rate are used as justification for this. In Sweden, the authorities’ assessments have been strongly criticized by operators in the gambling industry. The biggest operator in the Swedish license market, ATG, the former horse betting monopoly holder, has independently investigated the system’s channelization rate with more credible methods than the authorities. ATG has analyzed and modeled the observed network traffic and mirrored it to existing accurate gambling and customer data numbers.

The total volume of the Swedish license system has remained practically constant since the end of 2020. However, according to ATG’s research, overall gambling in product groups belonging to the license-based market has increased, and all growth seems to have been directed to gambling companies outside the system. ATG does not present an exact estimate of the channelization rate of the license-based system but implies that it could move around 70 – 82 % level at the end of 2023. The channelization rate of digital casino games seems to be significantly lower than the average, and the channeling rate of betting games is correspondingly better than the average. FGC attaches to its statement a summary (Appendix 1) of ATG’s approximately 30-page research report, which FGC has received permission from ATG to distribute. FGC believes that, if needed, the full ATG research report is available for use.

FGC points out that if ATG’s estimates of the supposed weaker channeling ability of digital casino games are correct, there is a significant risk that the channeling rate of digital casino games in Finland will not rise in line with the goals if the final law is what the Ministry of the Interior has proposed. This would be particularly harmful from the point of view of addressing gambling problems. Based on the data obtained from Sweden, specifically problematic gambling tends to move outside the system more easily than other gambling.

General note on the proposed regulation

FGC points out that the proposal has left significant issues regarding the final implementation of the gambling system behind the regulatory powers. This applies, in particular, to items under section 31. From the point of view of ensuring the functionality of the system and its channeling ability, the appropriateness of the parameters behind the settings can decide the success of the final result. Suppose the parameters given through the settings are adjusted incorrectly. In that case, the success of the entire reform may be at stake, and the result may be the worst possible – a license-based system with weak channeling capabilities.

FGC’s improvement proposal: To maintain the gambling system’s overall objectives, overall control should be maintained when making regulatory-level decisions. The Government, not individual ministries, should issue the final regulations (settings) on gambling.

General note on the tax treatment of unlicensed gambling winnings

The proposal contained in the bill to regulate unlicensed gambling winnings as taxable requires changes. FGC considers the proposed goal of extending taxation to all digital gambling outside the system to be correct and consistent. However, it includes shortcomings and challenges to the fair treatment of citizens. According to the proposal, stakes used for lost games may not be deducted from taxation. This creates an unfair situation, especially for players with gambling problems who gamble outside the system more often than other customers. If a person with a gambling problem loses, for example, 10 000 euros in unlicensed digital casino games, he could, for example, have gambled 200 000 euros and received winnings of around 190 000 euros. About three out of four rounds may have been ones in which the player won nothing, and those stakes are not tax deductible. As a result, a problem gambler who lost 10 000 euros receives a taxable income of around 140 000 euros in this example, in addition to the losses. (Appendix 2 opens up the example case a little more). This unfair outcome significantly worsens the situation of the problem gambler.

FGC’s improvement proposal: Regulated tax penalties should apply to the net winnings generated from gambling during one calendar year. This means all taxable gambling winnings the player has achieved during the calendar year, minus all bets and losses of the corresponding period.

General note on Veikkaus’ group structure from a competition law point of view

Customer base and technology

Based on the bill, the part of Veikkaus that continues in the license-based market may have a competitive advantage due to Veikkaus’s monopoly operation. This cannot be considered an action acceptable under competition law. The draft of the proposal even admits that the chosen solution seeks synergy between the operation that will remain a monopoly and the company that will switch to the license-based side.

In FGC’s opinion, there should be a clear policy on whether Veikkaus’s current customers can be transferred to a company continuing in the license market in a way that it cannot be considered a benefit from customers obtained from the monopoly operations. The calculated value of the customer base is at least hundreds of millions of euros. FGC also points out that if the part of Veikkaus continuing into the license market were allowed to utilize all of Veikkaus’ current existing customer base, Veikkaus’ license company would be given a substantial competitive advantage compared to the operators entering the market.

A company operating in a competitive market may not use the same resources as a monopoly company from the same group in a way that distorts competition. Dividing Veikkaus into several companies includes a plan to establish a separate technology company. The plan consists of the risk that the monopoly company and the license-based company will use common technology, for which, according to the plan, compensation will be paid at the market price. Determining the amount of such compensation will be challenging and, in some cases, even impossible.

FGC’s improvement proposal: To avoid problems with competition law, it would be stipulated that the Veikkaus group companies should not use joint technical solutions related to gambling. That would be the same rule as in Sweden.

The games in physical slot machines

According to the bill, slot machines, which would continue to be thousands all over Finland, continue to be covered by Veikkaus’s monopoly. These machines would have the same casino games developed mainly by Veikkaus, which Veikkaus’s license-based company would offer in the competitive license market. Those slot machines would be a significant marketing channel for the games in question, from which Veikkaus’s license company would also gain a significant competitive advantage.

FGC’s improvement proposal: A single product or game would be offered only in the monopoly or license-based market so that the customer knows which group’s game he is playing. Veikkaus’s monopoly and license companies should not offer the same product or game.

Detailed considerations:

Note on mandatory limits

Based on the proposal, the customer would be forced to set limits on gambling when setting up a betting account, which would aim to prevent harmful gambling. FGC wants to point out that although ideologically, the idea sounds valid, the practical experiences of the gambling industry have been different. In practice, it has been noticed that when a problem gambling customer hits the limits, he rarely stops gambling. Instead, gambling continues either with another official operator or, in the worst case, outside the legal system. Mandatory limits are not a good way to curb problem gambling but an excellent way to weaken the channeling ability of the gambling system.

FGC points out that making gambling limits mandatory was the biggest reason that Veikkaus’s channeling rate, especially in digital casino games, started dropping rapidly at the end of 2018. In the new system, the effect of the obligation to set limits to the channelization rate would not be as dramatic because the customer could continue gambling with the service of another licensed operator. In practice, however, players would be forced to change gambling operators. In connection with such a change, the risk of the customer switching to gambling for an operator outside the system is always tangible.

FGC’s improvement proposal: Setting gambling limits should be suggested to the customer during registration, but setting them should not be mandatory. The Ministry of the Interior should consider implementing gambling limits, for example, according to the Estonian model. In Estonia, the gambling operator must give customers the opportunity to set their limits during the customer registration process, but if the customer does not want to set them, he can, by his active decision, not set the limits.

In this context, FGC would also like to point out that if a solution is decided in the future where standard mandatory gambling upper limits are set for all players, customers should be able to increase their limits if they wish if they can demonstrate that their financial situation allows this. Such a solution ensures that the system’s channeling ability is maintained so that the risk of gambling problems does not significantly rise.

Note on bonuses

In FGC’s view, the categorical ban on all bonuses in the proposal is problematic when considering the system’s channeling ability. FGC agrees with the Ministry of the Interior that bonuses that encourage gambling can increase problematic gambling and, thus, gambling problems. Still, that would be a significantly smaller disadvantage than leaving the bonuses only for operators outside the system and helping channel gambling outside the system.

The importance of bonuses, especially for the customer experience of digital casino games and the profits of gambling companies, is enormous. The more active the customer is, the more critical the customer considers bonuses and other loyalty rewards offered by the operator. In general, the most active customers are problem gamblers or players whose gambling problem is developing. Suppose operators redeeming their licenses are denied all bonuses. In that case, the system’s channeling ability will fall significantly below the target level, as customers who are used to bonuses will move to gambling companies outside the system. It will be especially problematic if the players, who the system should be able to protect, move to play for operators outside the system.

FGC would also like to highlight that at most current international gambling companies, the implementations of bonuses and loyalty systems are often so complicated that not all players even understand how bonuses work and are available. If bonuses were partially allowed in the license-based system to improve consumer protection, it would be possible to demand clarity and simplicity from them so that consumers could understand the structures of the bonuses in detail.

FGC’s improvement proposal: The Ministry of the Interior should consider allowing bonuses in legislation so that bonuses can be given to the player, but their complicated wagering conditions would be prohibited. The bonus recycling condition should only require the customer to play the bonus money he received once through games, after which he could withdraw the remaining money for himself if he wished. With the presented change, the competitive conditions of legal operators would improve against supply outside the system, and the channeling capacity of the system would improve considerably. From the point of view of gambling problems, the legal offering would cause a few more disadvantages than the current one, but keeping customers who gamble especially problematically within the scope of the gambling system would bring a significantly more significant benefit. The society remains informed about possible problem gambling and can target actions to reduce problems only when the customer plays games from a legal operator.

Note on the categorical ban on marketing by third parties

The bill proposes that gambling marketing can only be done by licensed gambling operators. FGC considers that the categorical ban on the marketing of gambling by third parties is problematic and causes significant problems when evaluating the legality of various activities. To some extent, the regulation could be improved by defining illegal marketing more precisely, but such a solution will not completely eliminate the problems.

Affiliate activity – business-like marketing

In the categorical ban on marketing by third parties, problems arise, especially with regard to various affiliate sites. These are typically international online sites that directly or indirectly advertise gambling services. It is not always clear which country’s regulation the affiliate operates under. FGC points out that the gambling legislation of many other countries allows the use of affiliate services.

FGC points out that leaving the entire affiliate activity outside of Finland’s official gambling system poses a significant risk to the system’s channeling ability. Existing affiliate operators already have an extensive customer base of Finnish customers. In Finland, a lot of searches related to gambling are made through search engines, especially Google, which direct people to affiliate sites. People do not stop such searches, and the direction of internet traffic to affiliate sites does not stop, even if affiliate activity is prohibited in Finnish gambling operations. In this case, affiliate operators would direct customer traffic to the pages of gambling companies operating without a license, weakening the gambling system’s channelization rate.

The bill has defined strict boundary conditions for all gambling marketing. If affiliate activities were allowed in Finland, these companies would have to follow the same marketing regulations as gambling operators and media companies. Affiliate activity should become significantly cleaner compared to the current practically completely unregulated situation.

FGC’s improvement proposal: The Ministry of the Interior should look for an implementation method to bring affiliate operators into the scope of official regulation. An alternative to be considered could be, for example, the Romanian model, where affiliate operators are required to have a separate business license, which could be part of the proposed supplier license.

Note on the presented product groups in exclusive and multi-license systems

In FGC’s opinion, the arguments for leaving certain product groups under exclusive rights seem artificial. The reasons given are that there is currently no competition in the product groups in question and that transferring those products to the multi-license system would increase the marketing of these products. This, in turn, would increase the gambling problems caused by these games. However, based on the proposed law, the monopoly would mainly be in those product groups that, according to studies, cause little or no gambling problems. Only physical casino and slot machine operations are an exception in this respect. For example, the inclusion of lottery game operations in the scope of monopoly cannot be credibly justified with these arguments.

In particular, FGC considers leaving pool-based horse betting and digital eInstants within the scope of Veikkaus’s exclusive right to be an incorrect solution, and no credible justifications have been presented for the proposal.

Pool-based horse betting (Tote games)

In the case of Tote games, the existing high channelization rate and the fact that competition could increase the marketing of the products, and thus, the resulting gambling problems are presented as justifications. FGC points out that in the studies of both The Finnish Institute for Health and Welfare and the helpful line, Peluuri, Tote games have been one of the product groups that cause the least harm. Releasing them to the license-based system could increase the marketing of the products, but this could be considered mainly to direct the demand for less harmful gambling. In addition, concerning the channelization rate of Tote games, it must be understood that the high channelization rate is realized only because Veikkaus has a cooperation agreement to offer Swedish horse races with the Swedes in a common pool for Veikkaus’s customers. If the agreement were to cease to be valid for some reason, the majority of existing betting would be transferred to other operators operating without a Finnish license, and the high channelization rate of Tote games would collapse immediately.

Tote games are currently part of the license-based market in Sweden and Denmark. This is the digital sales channel situation in all European countries that have switched to a license-based gambling system. In the Netherlands, only one company can operate pool-based horse betting, but even that has gained its status through bidding. In Denmark, Tote games were initially on the side of the monopoly system. Still, that arrangement was found to be problematic and dysfunctional, as a result of which Tote games were moved to a competitive market in 2018.

FGC would also like to point out that section 26 of the draft law prohibits the organization of betting for gambling events/draws that are used in the monopoly business. In practice, the operating model would mean that operators applying for a business license in Finland would no longer be allowed to offer fixed-odds betting at those races where Tote games would be organized. This can be considered a significant regulation aimed at limiting competition because large international listed companies would apply for a Finnish license, and they compete against pool-based horse betting in Sweden with fixed odds betting products.

FGC assumes that section 26 and its justifications are written mainly from the point of view of lottery games. If Tote games were to be left as a monopoly, the proposal should be supplemented so that fixed-odds betting on the outcome of horse races would be possible. If Tote games are moved to the side of the multi-license system, this definition problem does not exist.

FGC’s improvement proposal: Pool-based horse betting/Tote games will be transferred to a multi-license system.

Digital eInstants

Regarding eInstants, FGC wants to point out that with the proposed regulation, Finland would return to the situation that led to the merger of three gambling companies at the beginning of 2017. The main reason for the merger was the weakening of the differentiation of Veikkaus’s and RAY’s products in the digital channel. The proposed regulation would do the same – not least because the proposal would allow eInstants draws to be made at the time of game purchase (RNG technology), just as in digital casino games. The visual implementation of eInstants and digital slot machines can be very identical. FGC wonders how the separation of these products can be handled reliably and how the consumer has the opportunity to identify which product group’s game he is playing.

FGC’s improvement proposal: eInstants would be included in the category of digital casino games and would, therefore, be moved to the side of the license-based system. Alternatively, eInstants could be arranged to be implemented technically so that their technical and visual implementation would differ significantly from the implementation of digital casino games.

Note on the possibility of the supervisory authority to regulate the activities outside the system

FGC considers it good that the bill aims to give the supervisory authority the means to intervene in the offering and marketing of unlicensed gambling in Finland. However, according to the FGC’s view, it seems that the vast majority of the proposed measures would affect the operations of license companies in particular. However, blocking payment and online traffic (IP) can be a reasonably effective way to reduce gambling outside the system.

FGC does not identify measures in the bill and its explanatory text that the supervisory authority could use to monitor gambling outside the Finnish system. According to FGC’s understanding, gambling outside Veikkaus is significantly more significant than the authorities estimate. It is practically impossible for the authorities to intervene in illegal supply if that supply is not even recognized. Technical systems and services would be available for monitoring and intervening in gambling, which could be used to significantly improve the system’s channeling capacity and increase the state’s tax revenues.

In the bill, great attention is paid to preventing betting-related incidents. At worst, match manipulation and other abuses are a problem for sports comparable to doping, or even worse. The bill says that Veikkaus’s own measures, FINCIS’s (Finnish Center for Integrity in Sports) operations, and ULIS’s (United Lotteries for Integrity in Sports) cooperation are excellent and sufficient measures to prevent abuses. In FGC’s opinion, this is unfortunately not the case. Finnish sports are likely also currently being used to organize illegal activities. Monitoring and preventing match manipulations should not remain the responsibility of the betting companies. Still, the authorities should take a more significant role in the matter than at present.

FGC has requested a description of the benefits of a modern monitoring system from Sportradar, which focuses on monitoring international gambling activities and preventing sports manipulation. That description is included in the appendices to our statement (Appendix 3).

FGC’s improvement proposal: The authority supervising gambling activities would be obliged to acquire technological systems that monitor and supervise gambling activities outside the license system. In addition, the regulator or other separately defined authority should join an international network that could be used to monitor global betting activities and identify possible abuses related to Finnish sports.

Minor notes

The proposed ban on using a credit card for money transfers does not protect those with gambling problems, even though that has been the explanation. In practice, that means the customer first transfers the money from the credit card to his bank account and then to his betting account. In practice, the regulation intended to protect those with gambling problems mainly results in a small additional cost for them. The ban on the use of credit cards, and especially debit cards, causes problems, especially for transactions at retail channels. In addition to the customer, the affected parties are especially retail outlets and Veikkaus, which offers gambling products in the retail channel.

The proposed procedure for lifting the indefinite gambling ban is problematic. When a customer wants to start gambling again after a break of at least a year, he is given the option of waiting three more months or moving to gamble outside the system. FGC considers that a person who hasn’t gambled for more than a year should have the opportunity to lift an indefinite ban immediately. There must be a separate consideration period to cancel short and fixed-term bans. However, if bans are valid indefinitely and have continued for over a year, that three-month consideration period will not accomplish anything other than the player moving to play outside the system.

Sincerely yours,

Jari Vähänen

Partner

The Finnish Gambling Consultants Oy