Dr Jack Garnham: Reducing the burden of responsibility for iGaming operators with outsourced compliance solutions

May 13th, 2021

Whilst regulators are keen to protect players, a fine balance is required to discourage customers seeking out unregulated grey and black-market operators, which may appear more attractive to players due to their lack of limits and constraints. This leaves us with a regulatory framework environment that in some cases requires stop-gaps in place to mitigate risk and fraud, and an ever-changing landscape for operators to keep track of.   

Operators can choose to mitigate their risk in a number of ways. Whilst they could develop their own in-house solutions and throw more resources and people power at the problem, this is often not a viable solution as these resources are deployed elsewhere in the business and even mission-critical regulatory updates become impactful in terms of day-to-day operations if operators change the focus of the internal team. This is compounded by the fact that these are often deadline-driven by the regulator.

With the above in mind, it is now becoming increasingly interesting for operators to outsource compliance and regulatory matters to expert third-party providers who can improve efficiency and whose total focus is on the changing landscape of compliance. Such providers can effectively offer numerous solutions to operators, particularly those operating across multiple regulated markets.

These solutions/providers reduce the burden of responsibility and the potential for human error from internal compliance teams. This moderates the potential threat of regulatory fines whilst simultaneously enabling the operator to demonstrate their commitment to compliance, a growing determinant for attracting and retaining both players and staff.

Many operators are now choosing to integrate new, previously underutilised, outsourced solutions and products to effectively manage their compliance risk. In the UK, this has been driven by the revised guidance coming from the UKGC and is being mirrored in a number of new markets – such as the Netherlands, Germany, and Greece – which are currently going through regulation. As a result of the increased interest in such outsourced compliance solutions, more companies are continuing to enter this space, offering platforms that can be adapted to multi-regulatory environments.

As part of our work assisting operators across numerous regulated markets, most notably in Europe and North America, we at the Rokker Research Labs have assessed numerous third-party providers. This typically involves us offering our rapid-fire research service to provide operators with objective and unbiased insight into specific third-party services, solutions, and products, enabling them to make more informed strategic decisions that best meet their needs.

Whilst in most cases we have tended to evaluate third-party games studios, aggregators, and platform (PAM) providers on behalf of our operator clients, more recently we have seen a growing interest from operators as to how they can outsource their compliance solutions by using third-party providers, especially as more and more markets regulate.

As a complete overview of the outsourced compliance solution landscape would be beyond the scope of this review (although we are happy to provide one for those that would like to see this!), we have highlighted three companies that we have independently evaluated and identified as offering interesting and viable compliance services and solutions, ranging from data vault technology to identity platforms and Responsible Gaming, and all of whom represent this new wave of outsource compliance offering.

Data Vault Technology – Domino (Pretty Technical)

With regards to the data vault technology market, Pretty Technical have recently announced their entrance with their Domino platform. This platform has been developed off the back of their teams’ previous experience running platforms in the Spanish iGaming market, which was one of the first regulatory markets that pushed for data vault requirements. The new product however takes a step forward both commercially and technically. This is illustrated by the number of serious European operators that have already signed up to use the platform.

This product was developed after Pretty Technical identified a strong market need for a more flexible approach to data vault provision. Markets, such as the Netherlands, Spain, Greece, Portugal, Colombia, etc., all require robust vault solutions covering functional requirements, such as data integrity, eligibility, continuous validation, and monitoring, but which also take a modern approach to integration and scalability and that’s where Pretty Technical has focused their attention.

Pretty Technical recognised that operators want to keep it simple in terms of engagement but also identified a level of support that is in advance of a simple design and build partner, where they not only supply the platform but can also help operators optimise their own data sets. Indeed, strong outsourced compliance solutions and services offer a level of support that is above and beyond standard SLA coverage, but are also ready to work with platforms to integrate their clients efficiently, as well as supporting operators that are not data warehouse ready.

Launching the Domino data vault in 2020, Pretty Technical built a Dutch-ready CDB for operators that are looking to be first movers in the newly regulated market. They are now extending this service to support additional emerging markets across Europe and Latin America where a data vault (aka SAFE) is a mandatory requirement.

Global Identity, Risk & Fraud decision platform – TruNarrative

The TruNarrative platform has been built to be agile and enable operators the ability to make rapid strategy changes in-house. These include adapting & building new rules, adding new data sets, managing changes in volume, and building in resilience. Their solution delivers something formerly unavailable to operators: a single end-to-end player onboarding and monitoring platform.

The TruNarrative platform offers operators unique customisable orchestration, decisioning, and behavioural monitoring capabilities. This service offering is achieved by aggregating and combining a host of pre-integrated data suppliers and compliance services through a single API. These include document verification, device intelligence, and open banking amongst many others. Collectively, this service enables risk officers to manage all aspects of their customer checks without having to sift through the multiple levels of compliance across markets and find themselves still wanting.

Responsible Gaming – Mindway AI

The Mindway AI platform empowers operators to be proactive in terms of identifying problem gamblers. Based on neuroscience and artificial intelligence, their AI technology has been developed by taking into consideration the areas of the brain involved with addiction.

Their GameScanner technology uses algorithms based on numerous parameters and the interrelation between these parameters to get a 360-degree view and understanding of gamblers and thus identifying at-risk and problem gamblers. This technology has been independently validated and verified by GLI for its ability to identify problem and at-risk gamblers to a level of accuracy comparable to assessments by clinical psychologists.

By intervening with at-risk and problem gamblers at the appropriate times, the Mindway AI platform enables operators to develop a more sustainable relationship with their players without attracting the potential negative publicity associated with such players.

Operators’ commitment to such Responsible Gaming initiatives have been demonstrated in recent announcements, such as the Kindred Group’s plans to generate 0% revenue from harmful gambling by 2023, as well as Entain’s Advanced Protection and Care (ARC) customer protection strategy.

Mindway AI have also developed their own gamified self-test solution, known as Gamalyze, which has attracted attention from the Dutch market where customers, such as Holland Casino, are conscious of meeting the regulators’ requirements of a self-test as of 1 April 2021 and policy of preventing gambling addiction.

The Gamalyze solution analyses the players gambling behaviour to identify key characteristics associated with problem gambling. This test then provides specific and tailored feedback and advice to the player.

In summary, the outsourced compliance solutions highlighted above are good examples of companies who can empower operators to effectively respond and adhere to changing and emerging regulations, many of which will likely be accelerated in response to the Covid-19 pandemic as the requirement for tax revenue grows.

Such outsourcing is an interesting option when the market is dynamic and changing, or where an operator has resources focused on existing roadmap tasks. Good outsource compliance partners should be able to adapt quickly to multiple markets and regulatory requirements by inherently understanding how testing and regulation work. There are many valuable and viable emerging commercial models offered by outsourced compliance partners which make this service something worth investigating.

If you wish to find out more about such outsourced compliance solutions or the wider landscape, contact Jack Garnham at [email protected].