Public Gaming International May/June 2020
82 PUBLIC GAMING INTERNATIONAL • MAY/JUNE 2020 F or many years we have been advocating for a regulatory approach that will allow Lottery operators to react swiftly when confronted with disruptive market developments. Unlike illegal operators, who can embrace new technologies and strategies without regard to regulatory constraints, lottery operators must comply with costly and time-consuming processes to ensure compliance with regulatory regimes. And when a new technology or marketing strategy is not directly covered by existing regulations, lottery operators must wait for regulators to catch up to the market while illegal operators use whatever tools and methods are available until they are explicitly outlawed. is puts illegal operators in the position where they are causing serious harm to regulated markets. Robust mitigation and preventative measures to protect the consumer and ensure security and integrity have become part of our daily existence. ese measures have inevitably caused commercial disruptions that make it very di cult for lotteries to operate e ectively within prevailing regulatory infrastructures. Legal lottery activities have slowed down signi cantly. is diminished role has created a void, an opening for illegal operators to increase their market share even further. Sales channel solutions of the Lottery operator are shackled and consumers are left without a strongly controlled, acceptable and legal alternative. In an article for Public Gaming Magazine (“Protecting the Future of Lotteries”) we mentioned the need to address new gaming developments and digital challenges to enable “the lottery operator to actively channel the gaming desire into a fair, low risk and attractive o er that is properly advertised and bene ts society.” Today the lottery operator is faced with the closure of POS (pandemic lockdown measures), the suspension of sport betting activities (cancellation of sport events), an inability to conduct lottery draws in accordance with existing regulatory frameworks (lockdown and social distancing), and the di culty to publicize draw results. It faces real problems to address customer demands and to respond to prize pay-out issues. And its ability to respond to these challenges is further impaired by regulatory frameworks which inhibit the introduction of new games or alternative systems that may address these problems. Illegal operators are ourishing in this environment of regulatory uncertainty and confusion. And the anonymity of the Internet gambling world provides the perfect cover for their activities. Illegal operators do not contribute to good causes, do not embrace measures to promote responsible gaming and have no appetite to employ industry best-standards like the World Lottery Association’s Security Control or Responsible Gaming Standards. Turbulent and uncertain times give rise to re-purposing of manufacturing resources to meet the pressing and immediate demands – in the current case to produce essential medical tools, devices, and other products. Researchers across the world are joining forces to jointly search for solutions to detect, cure, and prevent the serious problems caused by the COVID-19 pandemic. Today, whilst respecting precautionary principles, regulatory authorities in the medical sector are providing expedited approvals, and trade and competition authorities understand that relaxation of strict compliance rules will bene t society and consumers. Solidarity, trust, transparency, integrity and support have in most sectors become essential tools to ght the devasting consequences of the pandemic. Values that focus rst on the welfare of society have always been embraced and promoted by lottery regulators and operators. Now they have become very relevant in all spheres of life as we live it today. Yet, as I write this blog, the disruption of the pandemic is serving the interests of illegal operators while impairing the e orts of authorized lotteries to channel the demand to safe and secure gaming outlets. e result is potentially a crippling blow to government-lotteries as illegal operators increase their share of the market-place. Regulators and shapers of public policy know that the time will soon come to rebuild the economy. ey need to be informed of the pressing need to reverse the advances made by illegal operators, and the need to restore the important role performed by authorized lottery operators. Regulators and shapers of public policy will likely protest that they face a multitude of pressing problems and that Lottery is not necessarily a priority in this time of crisis. We need to encourage LOTTERIES IN THE COVID-19 CRISIS: THE URGENT NEED FOR A MULTI- DISCIPLINARY LOTTERY TASK FORCE TO SUPPORT TECHNOLOGY-DRIVEN SUSTAINABILITY By Philippe Vlaemminck 1 , managing partner and Dawid Muller 2 , advocate – Pharumlegal 3 Continued on page 81
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