57 PUBLIC GAMING INTERNATIONAL • SEPTEMBER/OCTOBER 2023 legal obligation under international law to implement serious measures and policies to fight illegal gambling. Opening a market up to multiple gambling licensees as Finland is not an effective way to combat illegals. Instead, the intense competition will end up stimulating consumer demand and even creating a fertile market for illegals to operate in. In light of the peculiar nature of gambling, the Court of Justice of the EU and its Advocate generals affirmed several times already since 1993 that free and open competition in the market of games of chance can have severely detrimental effects. The general approach of free-market competition, as applied to most other services in the internal market, benefits the consumer in terms of quality and price. The EU wants the competitive market to drive the positive feedback cycle of increased production which reduces cost which in turn increases demand and so on. That underling dynamic does not apply to a sector like gambling or Lottery where the goal is not to maximize consumption. Multiple operators of games-of-chance competing with each other inevitably results in increasing consumers’ expenditure on gaming as well as their risk of addiction. The positive benefits of the alternative to liberalization is easy to establish. Governments and regulators should take regulatory actions, particularly in relation to: • Implementing a strong monitoring system to identify the actual illegal market. There are systems available in the world that utilize anti-terrorist software, adapted to the gambling world, enabling governments and operators to get an exact vision of the illegal market in a territory. • Geo-blocking: One aspect of channeling players from illegal operators over to the legal operator consists of preventing players from accessing these illegal operators in the first place (by geo-blocking illegal operators). This can be done in the gambling sector because Regulation (EU) 2018/302 of 28 February 2018 on addressing unjustified geo-blocking does not apply to gambling and thus permits geo-blocking for gambling services. • Law enforcement: Fighting illegal gambling is a legal obligation under EU law (to maintain a consistent policy on gambling according to the CJEU) as well as in application of the Council of Europe Macolin Convention against manipulation of sport events (Article 11), where the fight against illegal sports betting is defined and established as an obligation. A modern policy looks at the way to bring financial institutions, ISP’s and media agencies under the umbrella of the fight against illegals. This requires strong legislation and cooperation. • Reinforcement of regulatory regimes that support state lotteries, well controlled sport betting and safe land-based casinos: even more, governments should explore ways to provide more room for an attractive legal offer of games in a controlled manner. The Court of Justice of the European Union (‘CJEU’) refers to this as “controlled expansion”, namely bringing attractive products with an appropriate form of advertising, and where necessary by using new distribution channels with an extensive range of games. Instead of organizing the first conference on gambling in Finland, we may set up a simple course of European case law for the Government authorities, combined with an independent risk and economic viability assessment. The legislative pathway forward might then evolve towards recognition of the many advantages of the monopoly of Veikkaus, along with the numerous beneficiaries of the Lottery, the general public and the players, and Finnish society. n Implementing a best-of-breed growth model continued from page 53 to confirm to the same base rule of what is an instant game. However, the player experience in all these examples has evolved significantly, with entertaining features and visuals that simply did not exist in the past. iGaming stakeholders should hopefully recognize this reality, support regulatory change that enables iLottery as well as iGaming, and embrace a future that maximizes options and the gaming experience for players. Constraining the consumer and the marketplace from going where it wants to go has never worked well and now it’s a total non-starter as a business strategy. So where do you see us as an industry going from here? What are the next innovation areas that we should be focused on? It’s a very interesting question because it is indeed in an ever-evolving state. Holistically, we should focus on improving three areas, apart from content which we discussed already. The first is omni-channel. We have been leading the space for a while with supersuccessful solutions that our customers have launched. Whether it is remote ticket cashing that has boomed in Virginia, or omni games launches across retail and online, this includes not only retail games having an online version but also pure “online-born” games which go into retail, as we have done for example in New Hampshire and Virgina. Seamless loyalty programs that run across retail and online are an important part of the mix, with retail cash-out of online wins and online claim centers. We have invested significantly in delivering all such programs to our customers and their importance will grow. The second area is serving content to players. The portal and apps need to be personalized real-time in their approach. In a world where each of the lotteries will have more than 150 active games, you need to seamlessly segment and suggest them to players. NeoGames serves its customers with a huge mountain of data that can be learned from, not only in their own operations but also others. Pariplay as a content hub, for example, allows us to learn tastes and preferences on a vast global scale as well as locally within states, through our NeoCube BI suite that feeds into the lottery to personalize. We have apps and portals that we provide to iGaming customers and we see the effect of this content personalization approach in an operator environment that sometimes has more than 1000 games. And the third element which maybe connects it all is real-time marketing. We have the player’s attention when they come to visit our “store” and we should engage with them right there and then. Sending emails is an after-the-matter thought process and is less and less effective as a sole tool. It needs to be augmented with real-time marketing that segments players and interacts, engages and offers them exclusively what they prefer. Our NeoEngage engine which we have implemented across our customer base in Europe as well as in North America is one such example, but this is only the beginning. Beyond these three areas, which are already in play but will enhance in the next few years, we will start to see the introduction of AI. AI already plays a role in automated and smart customer service solutions, but it will move into all areas of operations sooner than we think. I believe it will ultimately boost the evolution of all product and service areas in ways we have not yet thought of. n
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