14
// PUBLIC GAMING INTERNATIONAL // January/February 2016
port of good causes. Our goal is to forge a
better cooperation with the EU Commis-
sion. It is the strong cooperation between
the EU Commission (which upholds the
principles of the Union) and the gov-
ernments of the individual EU member
states (which protect the interests of its
citizens) that results in the most balanced
and effective regulatory framework.
We are trying to solve the problems
that the current state of confusion that
European regulations and enforcement
has created. We can observe the experi-
ences of those jurisdictions which opened
their markets up early. There are aspects
of their experience which would not be
desired by the political leaders of many
European governments. Gambling ex-
panded quickly and in ways that at least
some EU member states would like to
avoid. It is not the intention of the EL
to prohibit a government from deciding
to choose that kind of open-market mod-
el for itself. It would be our objective,
though, to encourage the EU Commis-
sion to respect the rights of EU member
states to choose a different path. The EL
Association respects the responsibilities
and the role of the EU Commission to
make proposals and take decisions that
serve the entire community of EU mem-
ber states. That is why we are proposing
that the high standard of integrity, respect
for the laws of each jurisdiction, respon-
sible gaming, and player protection estab-
lished by the operators of government-
gaming—that these principles be applied
to all categories of gaming and gambling.
The EL Association is working hard to
assure that the EU Commission provide
a basis of laws that enable the member
states to preserve the integrity of all gam-
bling categories, and i-gaming in particu-
lar, and empower the member states to
enforce their laws and regulations for the
protection of its citizens and the benefit
of society and good causes.
What are some of the obstacles to accomplish-
ing what we need as a community of govern-
ment-gaming operators? What can individual
lotteries do to help our common cause to de-
fend the lottery model on the legal/political/
regulatory front? Or compete in the consumer
market-place?
H. Höltkemeier:
Over the last number
of years, the major obstacle on the Euro-
pean level seemed to be the widespread
belief in the power of a Single European
Lotteries and Gaming market. Regulation
was criticized as being a tool for compa-
nies and states to protect their position
and the money generated by it. Due to
the difficult situation all over Europe
(crises in southern Europe, refugees from
Arab states, etc.) but also as a result of the
experiences in liberalized pioneer-states
where the negative impacts from fraud
and addiction increased significantly
while income to the state from gambling
decreased (or, or at least did not increase
as expected or in relation to the stakes),
there is a real comeback of solidarity as a
basic principle for the community of gov-
ernment-gaming operators, but not just
for those, to follow. We now have a posi-
tive expectation that the EU Commis-
sion will support the rights of its member
states to enforce a stronger regulation of
the entire games-of-chance sector. We are
hopeful! All the evidence shows that a
clear, enforceable regulatory framework is
so necessary to a sustainable path forward
for the Lottery and gaming industry. And
not just for the protection and benefit of
government-Lotteries, but for the entire
games-of-chance sector , and the purpose
of protecting the consumer.
The next objective is to engage the sup-
port of regulators, agents of law enforce-
ment, and lawmakers to protect licensed
operators and consumers against illegal-
gambling offers. Every regulation, even
the most basic ones, needs the support of
all these stakeholders for them to be effec-
tively enforced by regulators and agents
of law enforcement. The EL is working
hard to enlist the full support from ev-
eryone to fight against illegal offers. Ille-
gal operators have much lower costs than
licensed operators because they do not
pay their fair share to the government or
to good causes, and they do not bear the
costs of operating to even modest stan-
dards of consumer protection, security
and Anti Money-Laundering , and integ-
rity. Without effective enforcement of the
law, illegal operators will use their illegal
competitive advantage to deliver higher
prize-payouts, advertise and promote
their product in ways that are prohibited
for licensed operators, and thereby push
legal offers out of the market. That is why
effective law enforcement is a top priority
of the EL Association.
But prevention of illegality in the gam-
ing sector is not our only focus. Govern-
ment-Lotteries are in a market-driven
business. There will be more and more
licensed operators with legal offers com-
peting for the attention of the consumer.
As a specific sector, government-Lotteries
will need to innovate its games and meth-
ods of operation to attract and retain the
interest of its players. The EL has initi-
ated new programs this year, like the new
Innovations Seminar held in Warsaw, to
help its members be the world-class busi-
ness and marketing enterprises that will
succeed in the future and continue to
channel billions of euros to the support
of society and good causes.
The EL has always been such a powerful ad-
vocate for its members when it comes to regu-
latory issues. What is the current state of the
ongoing debate between the European Com-
mission goal of applying common market laws
to gambling and the EU member states goal
of applying member states’ authority (subsid-
iarity) to self-determination of the regulation
and taxation of gambling?
Continued on page 43