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January/February 2016 // PUBLIC GAMING INTERNATIONAL //

63

Has FDJ ever dealt with a breach of security

or sports-betting manipulation?

T. Pujol:

In 2012 we detected suspi-

cious betting patterns concerning a match

in the French Handball Championship.

Suddenly, within the course of one hour, a

high amount of wagers had been taken on

the outsider team with a specific bet. The

bet was based not on the outcome of the

match, but on the half-time result of the

match. Analysis revealed that the betting

anomalies were all occurring in a very small

number of retail shops, only 15 retailer

shops out of 25 thousand. And these 15

shops were all located within the district of

the favorite team. The player was eventu-

ally convicted of match-fixing. Of course,

we had to react instantly to suspend wagers

and prevent the fraud to continue.

That brings us to the other pillar of ef-

fective security: crisis management. In the

Handball case, all operational, technical

maintenance service, internal and external

communications, and all top levels of the

company had to be pulled together im-

mediately to enable this instant response.

Then, the response to handle the immedi-

acy of the fraud was followed by the need

to communicate with the public about

what happened.

That is the other crucial aspect of cri-

sis management: Communications and

brand management. Data and reports

are constantly being analyzed to detect

fraud and vulnerabilities. Hopefully,

fraud is not occurring and so none is

found. But if or when it is found, like

it was for us in that 2012 Handball

match, it becomes immediately public.

Transparency, as we have said, is critical

to the preservation of public trust and

confidence. And the breach becomes ap-

parent to the directly impacted parties

immediately anyway. That is why every

lottery should have a comprehensive

crisis management plan in place. We

are living now in a global sphere that

broadcasts information instantly, so we

need to respond instantly to the public

response to a breach of security.

It seems that government-gaming operators

are held to a higher standard than commer-

cial gaming operators. In all areas of opera-

tion for that matter. But let’s focus on this

issue of security and integrity of operations.

What can Brand Lottery do to get recogni-

tion of that from our political constituents?

More specifically, why don’t government-lot-

teries get more consideration from legislators

for the fact that they achieve a higher stan-

dard in the operation of games-of-chance?

T. Pujol:

There are two aspects to your

question. First, there should be standards

of security that apply to all operators of

games-of-chance. There should be mecha-

nisms to evaluate and assess the difference

between the standards of government

gaming operators and those of commer-

cial e-gaming operators. But there is also

an aspect of Public Relations. We need to

ask ourselves if we are effectively commu-

nicating the importance of integrity for the

games-of-chance industry, and the impor-

tance of holding all operators to the high-

est standards of performance. It won’t likely

change the fact that government-lotteries

will always be held to a higher standard.

After all, government-lotteries need to earn

the right to hold onto their monopoly sta-

tus. But we can certainly try to make sure

that all licensed games-of-chance operators

comply with high standards of security and

integrity. And we can make sure that all

of our stakeholders are aware of our own

commitment to these principles.

Why couldn’t lawmakers be convinced to

apply the WLA standards to all games-of-

chance operators?

T. Pujol:

WLA and EL standards apply

only to the world-wide community of lot-

tery operators for right now. But we are

proposing to make it a public resource and

international standard. We are working on

that including sports betting, but it will

take several years. The name of this process

is IWA—International Working Agree-

ments 17. It will be updated in due time,

with more information about operations,

security and integrity requirements, and

made available to gaming organizations.

Currently, this is an internal initiative that

is being continuously updated and im-

proved. The facts and truths of today will

not stay the same for tomorrow and com-

ing years, so we have to be sure that our

controls for both the technical and human

parts are adapted to an evolving landscape.

The European Union Commission is

also organizing different working groups

that include both state and private op-

erators. These workshops are designed

to help regulators and legislators create

standards based on information from the

broader gaming industry.

Legislation that applies to all games-of-

chance is an area in which there are sig-

nificant cultural and public policy differ-

ences between jurisdictions. That is why

EU member states have made clear their

position that the authority to determine

regulatory policy should reside with the

state. The European Union Commission

may choose to respect that position, or it

may choose to push a conflicting agenda.

That is an ongoing topic of debate.

The WLA has developed a Certification

program to equip all of their members with

the knowledge and expertise to ensure that

they meet the highest standards of security

and integrity.

T. Pujol:

That is the whole purpose of

the Certification process that the WLA

(World Lottery Association) developed

for its members to apply and learn from.

The WLA is constantly updating and im-

proving its security standard, particularly

in sport betting, online, and privacy con-

trols. A new standard will be completed by

the first quarter of 2016 and fully adopted

by the general assembly of the WLA at the

World Lottery Summit in Singapore in

November 2016.