eGaming round table report by business editor Duncan Foulkes.
Around the table were:
Mark Robson, head of eGaming, IoM Government
Chris Hall, chairman of the eGaming strategic advisory board
Jennifer Houghton, managing director, Annexio Ltd
Joerg Hofmann, president of the International Masters of Gaming Law and senior partner at Melchers, Heidelberg, Germany
Bill Mummery, executive director, Celton Manx
Archie Watt, head of eGaming, KPMG
Paul Davis, CEO, Counting House (IoM) Ltd
Russell Kelly, Director, KPMG
eGaming is a success story in the Isle of Man.
A lively round table discussion was held at KPMG’s Athol Street base the day after the company’s sixth eGaming summit was held at the Villa Marina, Douglas.
Mark Robson, head of eGaming at the island’s government announced at the gathering that the industry now represents 16.7 per cent of the island’s economy with £168m worth of growth in just one year - a rise of 32 per cent. He said there was no sign of the ‘fantastic’ growth abating.
The round table discussion touched upon a whole range of subjects associated with eGaming including the island’s skill shortage, the Isle of Man’s excellent reputation with player protection and issues surrounding the social nature of gambling.
But the gathering, with eight important business figures, including one from Germany, kicked off with a look to an area that could be big in the future - so-called eSports and fantasy games. KPMG’s Archie Watt said it was a subject that had raised its head at the previous day’s summit and he wanted to know more.
He asked Mark Robson: ‘Do we consider this to be the next [big thing] in eGaming?’
Mr Robson replied: ‘It’s a difficult one, depending on people’s motivations. Are sports betters going to become people who bet on digital games?
‘Within the industry, participants are known as digital athletes.
‘Are they going to turn into gamblers? ... doubtful
‘Is it good for a jurisdiction to be at the forefront of that sector ? . . .Absolutely.’
Mr Robson said tournament organisers had reported up to 140 million views online just this year.
‘And they get an average of 30,000 participants at each of their events, with many multiples of this number streaming events to their devices.
‘So obviously the audience figures are staggering. The lifetime of the players is incredible, we are talking years, decades. And this is because the games reinvent themselves.
‘At a world championships in Germany a few weeks ago an arena was packed out. [with people attending a live fantasy games event].’
Mr Robson, who took over as the government’s eGaming supremo earlier this year after years working in the private sector, said the players’ games evolve over time as new weapons and new maps are released along with new lands, new superpowers, characters and so on.
As people mature and get better at the games they are always being improved and the games improve with the people.
‘So you grow with the games’.
But Bill Mummery of Celton Manx said he thought it was a ‘very interesting’ concept but still at an early stage.
‘We as a jurisdiction need to do, as it were, an audit, first of all to understand the demographics of these people and we also need to look to see if there are any social responsibility issues’.
Mr Mummery raised the question of age verification. He suggested this would be high on the list of issues.
‘If we were aiding the development of the processes as a jurisdiction, whilst we were not responsible for people’s behaviour there is an argument [over]the amount of time people devote to playing these games and there’s an issue about isolation, and the social issues.’
Mr Robson replied that eSports are essentially about people participating in sports online. Team games with people competing in fantasy worlds to capture someone else’s castle, for instance.
He likened it to ‘paintball online. Capturing land and that sort of thing. People immerse themselves in fantasy worlds and outwit others to capture land and so on’.
Chris Hall, chairman of the eGaming Strategic Advisory Board said it is ‘a very interesting market segment where the island has a good proposition.’
Mr Robson: ‘It’s grown virally. Things like ease of access has boosted popularity.’ He said the main games revolved around Lord of the Rings style games, league of legends and so on.
Russell Kelly, director, audit and advisory, KPMG, asked the gathering: ‘How can the Isle of Man benefit from this?’
Mr Robson replied that he used to be a semi-professional internet poker player. This sector has experienced controversy, and in certain competitor jurisdictions, ‘there were all kinds of issues.’
He said: ‘I want to make sure that when it comes in [eSports and fantasy games] it comes in in the best way it can. Both for the benefits of eSports and for the benefit of the gaming industry.
‘A lot of it is unlicensable activity.’ Before eSports it was called network gaming.
Mr Robson said the Isle of Man has a ‘fantastic reputation’ from a player protection & KYC [know your customer] perspective.
He said that it would have to be a ‘belt and braces’ job to ensure things were done properly.
Bill Mummery said: ‘My concern is that people make their own business decisions
‘We are all legitimate stake holders in jurisdictional reputational risk.
‘It’s not about whether it’s
right or wrong as a product, we are legitimate stakeholders - it’s the same as with bitcoin which I’m agnostic about.
‘Perception and accusation that it is a channel being used to groom the next generation of betters. I can see this as a perception that would jump out.’
Mr Robson replied: ‘eSports do have age verification on their sites. And the average age of players at tournaments are in their 30s.’
Mr Mummery: ‘Someone signs on - how does one know that it’s not a whiz kid 14-year-old driving the controls?’
Mr Robson answered back: ‘This applies to all products within eGaming and for an online betting site, it is imperative you have your own kyc and age verification.’
Mr Mummery asked: ‘What’s the conclusion’?
Mr Robson replied: ‘That’s something the GSC [Gambling Supervision Commission] are looking very closely at the moment. As far as they are concerned anybody that signs up to anything is going to have to be 18 and over.
‘There is a lot of collaboration going on and there is a whole raft of issues we have to overcome’
Mr Mummery pointed out: ‘It’s right that we look at it but we should proceed with caution’
Mr Robson agreed with this.
Paul Davis of Counting House Ltd pointed out that daily fantasy games are becoming popular in the USA.
Jennifer Houghton of Annexio Ltd said she had recently been to a conference in London where the future of fantasy sports was discussed.
Mr Robson stressed his department was ‘proceeding with caution, with happy anticipation shall we say’.
Joerg Hofmann, from Melchers in Germany, and who was also representing the International Masters of Gaming Law, pointed out that sports betting is regulated and it is important for regulators to define the goals and for there to be best practises.
He said those who love to get involved in fantasy sports enjoy the combination of entertainment and skill - with new players and new trends in the industry.
Paul Davis said there would be ‘opportunities in the offshore world.’
Mr Mummery said potential investors could take some comfort from the fact that we are a jurisdiction that will work with companies through problems.
The discussion then turned to something that was touched upon the previous day at the seminar by Dr Jonathan Parke in a talk entitled ‘Gambling, Leisure and Pleasure: ‘Exploring psychosocial need satisfaction in gambling.’
Mr Kelly asked the group where they see the trends going.
Mr Robson said that every company he had worked for in the sector were all concerned with player habits and activity.
And he said Dr Parke touched upon three reasons why people play: For financial gain, for personal satisfaction/ the euphoria of winning or just to kill some time.
‘One of the things I’ve seen historically is that if one of those pleasures was not satisfied they would feel cheated by that game’.
He added that Dr Parke had talked about how you could ensure maximum pleasure with minimum harm.
Mr Robson added: ‘There is continued development into enhancing the games and there will always be new players entering that gaming market’.
He did not think anybody had the ‘silver bullet on how you can maximise pleasure and minimise harm, but that was something every company was working towards.’
Bill Mummery then raised the aspect of significant cultural differences between punters.
He said his major market in the eGaming world is the Asian market.
He said: ‘Their approach is radically different to gamblers in the West. They operate on much lower margins and can calculate value just like that, they are not going for the life changing experience.
‘They are looking for the two to three per cent edge and their behaviour is totally different [to people in the British Isles]’
He said their style of gambling is so different, they are informed and the way they calculate things, you could not apply the same sort of norms.
Mr Robson said: ‘It does frustrate me when people categorise recreational participants as just gamblers.
‘A poker player could wager hundreds of thousands of pounds every week but never actually spend a single penny because he won the money in a free roll and he is a really good player and he’s building his bankroll and he’s never lost anything in that point of time.
‘Also [look at slot players], a less sophisticated style of gambling. I could spend a pound on a slot machine and think: ‘‘That was a waste of money, I hate it. Someone could spend £100,000 but if they have got £6million in the bank, who are we to say you can’t afford it and that’s a problem. For them that might be like spending a pound.’
Archie Watt said: ‘In discussions I’ve had with the UK gambling regulator I have tried to make that point to them. It’s not the size of the stake that dictates the problem.’
Mr Robson pointed out: ‘Absolutely not’. He said he would raise the question of ‘predatory practises’ - such as in the cashing out procedure for punters. He referred to firms who give a 72 hour pending period before they process the cashing out. ‘And in that period they send emails offering bonuses if you don’t cash out.
‘Is that something a regulator should take an oversight of?,’ he asked. ‘I would say that’s a predatory practise. It’s not a soft hurdle’.
Bill Mummery said: ‘It’s entirely reasonable that the regulator looks at [these] barriers to withdrawal’.
Mr Mummery said it was important for the sports bettor to have trust with the firm he bets with.
And speed of payout when the game has finished was vital.
‘He wants his winnings back in his account. Withholding those winnings after a game is an encumbrance.
‘It creates an unfairness and sometimes the time firms take to settle events and make available the funds to the player are entirely unreasonable. It’s his decision then what he [the punter] wants to do with those.
‘For me it would be obscene for anybody to put that sort of barrier in front of withdrawal.’
Mr Robson referred to ‘smoke and mirrors’ when people talk about mechanisms that have been adopted by unscrupulous operators as a mechanism of delaying payouts. Unfortunately legitimate controls have been known to be used to this end e.g. ‘know your customer’ – KYC
‘That’s indefensible’ replied Mr Mummery.
However Mr Mummery went on to stress one material and important difference between the Isle of Man and other jurisdictions and that was in the level of player protections.
He said: ‘How can you possibly say that a consumer is better protected under a UK licence than an Isle of Man licence when the UK, in my view, did not deal with the issue of player segregated funds. That single item that’s unique to the Isle of Man is a major differential in the level of protection
‘Therefore an operator that has chosen to come to the Isle of Man has got his head around the need to deal with segregated funds.’
He said operators who come here have to realise they have to ring fence player funds and that they cannot use player funds as working capital.
‘Someone who comes here and realises they have to do this are far more receptive. They would be far more receptive to mechanisms that deal with things such as false barriers of cash out. It is the biggest sign of commitment that they have signed out to an agreement to segregate’ [player funds].
Mr Robson said: ‘People do recognise the Isle of Man’s reputation.’
Mr Mummery: ‘We need to be precious about any new opportunity.’
Jennifer Houghton, managing director of online gaming company Annexio, had the day before made a presentation on the multi-jurisdictional licensing process at the summit.
And she told the roundtable that ‘there are misunderstandings even as close to home as the UK over multi-jurisdictional licensing’.
She said the fact the Isle of Man has segregated player funds certified as medium risk, to other jurisdictions, when asked questions about it, they did not know how to classify it .
Mr Robson said there were organisations that ‘we [the IoM government] have refused to take forward to a licence because of the issues that they have with the segregation of player funds.’
‘It’s tough when someone says they will bring 200 people here and they will relocate here, and say they will commit millions but our reputation is worth more than that.
‘You can’t buy a reputation you have to earn it.’
Mr Hofmann: ‘You can lose it [reputation]quite quickly’
Mr Robson: Absolutely.’
‘The thing is that reputation is, a lot of the time not based on fact but on perception. If someone believes something then to them that is the fact.
‘And there are still some people who believe in something called the ‘‘doom switch’’. They think there is a big red button which is used if someone is winning too much.’
Chris Hall: ‘It’s a very tight knit industry. Reputation and relationships are important’.
Joerg Hofmann: ‘It’s also in the interests of the operators themselves to have these systems in place to run a proper know your customer system to care for proper payment processing because nobody wants to lose their players. It’s the same in the land based business.’
He said that in Germany the lack of regulation for licensed online gambling offers reminds him of a ‘ghost ride on the German autobahn as its result is that players often choose to go to firms that do not offer the right sort of protection’.
Mr Mummery pointed out: ‘The relationship here in the island with the licensed operators and the regulator, it’s not something you can put on a poster but I think that across the industry it’s well known and it is part of our USP. [unique selling proposition]
‘People know we are a premier jurisdiction and people know that quite rightly the bar is set high and they also know that if you are licensed here you have a very constructive positive relationship with your regulator which is not always the case in other jurisdictions. I do think that is a significant USP for us.’
Mr Robson referred to the fact that Steve Brennan, chief executive of the Isle of Man Gambling Supervision Commission, is due to take over as chairman of an international gaming body. He said this could only enhance the island’s reputation even more.
Jennifer Houghton was asked by Archie Watt about her secondary lottery model with multi-jurisdictional working. ‘Do you find that your model the secondary lottery model, do the other regulators understand what it is you’re delivering and how well governed it is?
Jennifer: ‘Quite frankly no, based on the questions I get asked.’
She said there was a ‘lot of unknown and nervousness about the model of her business which is based around people being able to place bets on the outcome of lotteries around the world.
‘When they realise it is actually in a jurisdiction with full player protection and the controls we have in place here, strictly regulated, then they will back off or they will ask questions and then they will feel comfortable again’.
‘But the initial reaction is that you get a lot of questions that surprise me which suggests to me they don’t quite understand the secondary lottery business at all.’
She said that offering people the chance to place bets on the outcomes of lotteries was a new concept and a popular one.
‘We have been doing this for about five years.’
‘What I like about the Department of Economic Development and the Gambling Supervision Commission is that they are quick to react with answers to questions in less than 24 hours. It is a very open dialogue. If I’m not sure about something, I will pick up the phone and do that comfortably.’
But she said it was part and parcel of being multi-jurisdictional that her business was challenged on a regular basis about the model they worked on.
There was an issue with secondary lottery markets in some countries.
The discussion heard that Germany is a big market for secondary lotteries
Bill Mummery claimed there was ‘a significant social issue with the UK lottery’.
In his opinion he called it a ‘total disconnect’ that allowed 16 year olds to buy scratch cards.
He thought it was ‘fundamentally wrong that a government [the UK] allows the distribution of lottery products to sit completely outside of and in conflict with the way they manage every other form of gambling product.
‘It’s a legitimate social responsibility issue that government should address.’
Paul Davis pointed out: ‘It’s the why! Why does the United States allow pharmacists to sell cigarettes for example. There is no explanation’.
Joerg Hofmann expanded this theme by pointing out how he met with a famous US lawyer a couple of years ago at an event in Amsterdam.
‘He said to me: ‘‘This is totally weird here in the Netherlands. There are prostitutes in windows, you can smoke marijuana in coffee shops, but they do not provide regulation for online gaming.’’
‘This is it - different attitudes in different sectors.
‘It is really weird. The same is true in the US where you cannot drink alcohol until you are 21 but you can carry a weapon at a younger age than that. There are different values.’
Paul Davis said it was his perception that slot games online have changed and advanced so much from the land based casinos
‘Online is a growing thing,’ he said.
Russell Kelly from KPMG said the biggest thing to hit the land based casinos was a cigarette ban. It proved to be a form of cooling off for punters who had to leave their machines to go outside for a cigarette. It was the same with bingo as well.
Mr Robson, who has worked for various gambling companies, pointed out that in Las Vegas there were still places where you could smoke on the casino floor.
He added that the land based makers of slot machine games are trying to make a more immersive experience by building bigger cabinets and enhancing the game graphics and sounds and they are being very successful at this, but he said it still ‘boiled down to a case of hitting the button and being mesmerised by a representation of spinning wheels.’
And online slot manufacturers, the land based ones, have pushed content online.
Chris Hall made the observation that ‘in this industry, things are moving so quickly aren’t they? With the physical [land based] slots, people must have seen this coming. They are a little bit slow to react.
‘So from the island’s point of view it just shows that we have to keep moving all the time. We have to keep innovating ... we are at the cusp of the wave and not following three years behind everybody else because that would be very bad news.’
Archie Watt said a major American manufacturer called TCS John Huxley were definitely trying to bring roulette tables into the digital age.
Mr Robson said: ‘The behemoths have been acting like supertankers and it takes too long to change directions and the more nimble companies have stolen the march’.
Mr Watt: ‘Should people in the Isle of Man be working more closely with the land based operators to try and bring a better solution?’
Paul Davis replied: ‘We should be lining up with those very fleet of foot developers that are doing the best.’
skills shortage
Mr Davis then turned the discussion to the skills shortage in the island.
Mr Robson emphasised that there were more than 100 vacancies in this skill sector alone.
He said: ‘It’s a case of asking how we get people through the door.’
Jennifer Houghton from Annexio said: ‘We spent a lot of time looking for talent abroad because we struggled to find talent locally.
‘Depending on the department, finance, IT , support, they can be found locally.
‘Affiliate marketing, digital marketing is much more difficult and although we have been successful it has not been without a lot of effort. A lot of time and money is spent looking for talent to bring here.
‘We found the talent in America, Romania, Norway, Poland, the UK.
‘Locally on the marketing side there has been very little because you need experience and when you get to a certain size you want to have people that have contacts.
‘So if you’re training from scratch at a junior level there is excellent talent locally but if you are looking for experience in say, digital marketing, anything like that, we have struggled.
‘We advertise in local papers plus recruitment agencies.’ She added: ‘We have 12 different nationalities from 25 staff.’
Paul Davis asked Mr Robson: ‘Where is the responsibility within government over recruiting staff? Is there an outbound effort from within DED?
Mr Robson: ‘Yes there certainly is. There is a group internally that includes the DED, jobcentre and private sector and we are trying to do whatever we can to try and understand how we can facilitate easier recruitment for the private sector.’
He pointed to recent updates to the work permit legislation and efforts to help spouses to get work here
Chris Hall said: ‘This change has been fantastic because there definitely has been a lot of evidence that it’s more difficult for people to settle if your wife or husband cannot get a job.
‘But I think we now have to move to the next step. We have skills shortages in IT and key industries and we have to be creative and find a way to bring partners into this scenario too. If we are really serious about solving the skills crisis I would love to see this change extended to long-term partners.
[Minister for Economic Development Laurence Skelly MHK pointed out recently that the relaxation in the work permit system will give greater certainty to employers and their prospective employees seeking to take up employment in the Isle of Man and reduce the bureaucracy around applications.]
It will be easier for the spouses or civil partners of permit holders or people who are exempt from work permits to work on the island.
Chris Hall claimed: ‘It is harder for partners since there is evidence that some companies prefer not to interview people who have to apply for a work permit.’
Mr Davis said: ‘We have full employment and yet the service sector is looking for people. I’ve not got any evidence of Manx people being put off jobs by immigrants.’
Mr Hall: ‘We need to grow the working population - as called for by the Chamber of Commerce, so we have the right mind-set. Let’s get the facilitators all lined up behind that strategy so we can get it to happen.
‘Otherwise with a global business it is easy to set up business wherever you want and recruit where the skills are.’
Mr Robson said: ‘The industry globally, there is a skills shortage. Relatively speaking, It is still a young industry so to find people with five years’ experience can still be quite difficult.’
Mr Hall said there were some ‘fantastic studies out there as to why people come here to work.
‘A programmer I met recently, he was working in Europe and wanted to work elsewhere. He did research of every single EU country and ranked every relevant factor. The Isle of Man came out top of all the places he looked at. Publicising stories of why people move will help make people aware that the island is a great place to live and work.
‘If we can move this forward it’s win, win, win for everyone, the employers, the economy and for the [eGaming] sector.’
Mr Robson said that because of the nature of the sector ‘we can’t go out into schools to promote eGaming as a career.
‘We have to wait until people are over the legal age for participation before they can be introduced to some of the elements of the online gaming sector’.
But this sparked Archie Watt to declare: ‘I’m sorry I don’t agree with that at all.’
He said there were all sorts of aspects in the sector including software development.
Mr Robson said he appreciated that point, however it would be difficult to promote eGaming in schools without understanding what gambling is, and that is where risks could present themselves.
Mr Watt pointed out that although it was illegal to gamble in India it was still legal to develop software there for the gaming industry. Chris Hall made the point that there was some great technology associated with eGaming.
Mr. Robson acknowledged these points and confirmed that whilst he was based in Vegas, he had responsibility for development teams in India, but also added there were corporate social responsibility guidelines companies implement and abide by.
Chris Hall thought we may need to think of better ways to get more people interested in the industry.
Jennifer Houghton said there were limitations on work experience.
Mr Robson talked of forging links with the north of England.
There were discussions afoot to work with university students to investigate setting up an ‘incubator’ to encourage them to look at coming to the Isle of Man.
Mr Hall said: ‘There is a lot we could do there’.