Gibraltar may be a tiny territory in terms of its size (just 2.5 square miles) and population (just under 35,000), but when it comes to the international gaming it is a giant. Gibraltar has been a primary hub for online gambling for over a decade now and currently oversees 60% of all global online gaming. It is now the largest and the most successful centre for gaming governance in the world.
Initially the gaming industry started out with betting-by-phone but, thanks to precise legislation enacted by the Gibraltar government and its highly competitive tax system, it was perfectly positioned to capitalise on the explosion in online gaming at the end of the 1990s. There are now over 38 online gambling companies in Gibraltar, many of which are listed on the London stock market. The gambling industry employs 3,500 people in Gibraltar and contributes about 25% to Gibraltar’s GDP.
Gambling is regulated under the Gibraltar Gambling Act 2005 and the government operates a selective licensing policy that has resulted in several major UK facing online brands being located in the jurisdiction, including GVC (Ladbrokes/Coral brands), William Hill Online, 888, Bet Victor, Betfred and Bet365. And due to the presence of these major B2Cs, some 15 B2B – mainly games suppliers and aggregators – are also located and licensed in Gibraltar.
As a result, it is estimated that at least 75% of UK online betting takes place in or from Gibraltar, with a significant but lesser percentage of UK online gaming also taking place. UK facing operators are uniquely subject to a dual regulatory regime by the Gambling Commission of Great Britain and the Gibraltar Gambling Division, and Gibraltar is the only jurisdiction that has secured specific guaranteed access to the UK gambling market in a post-Brexit environment.
Gibraltar’s regulatory regime requires operators to have social responsibility measures in place and for operators to comply with the Gibraltar Proceeds of Crime Act 2015. It is currently in the process of updating its gambling legislative framework to include a more flexible enforcement regime and the adoption of regulatory best practice from the UK.
One of the main advantages for Gibraltar, in terms of regulation, is the proximity of the regulator to the operators. This has aided an understanding of the industry without undermining the integrity of the regulatory regime. Emerging issues can be dealt with quickly and there is scope to pursue common objectives with the UK, including the protection of vulnerable persons, under a regulatory framework that is broadly similar.
Gibraltar has publicly supported the UK’s National Harm Reduction Strategy and Gibraltar-based operators are leading on technology developments to identify markers of harm and in commitments around funding and other harm reductions measures. Coordination between online operators is essential in terms of sharing best practice and discovering what works and what does not.
To this end, the Gibraltar Betting & Gaming Association (GBGA) took a pivotal step last year by setting up and funding a new Gibraltar Gambling Care Foundation (GGCF) as a registered charity. The primary aims and objectives of the GGCF are to fund research into areas that will provide consumers, gaming industry leaders and government regulators with usable empirically based knowledge about how to minimise gambling harm, reduce the impact of gambling disorders and protect at risk consumers.
But Gibraltar has gone further, believing that objective academic research with access to industry data is an essential part of the process. The University of Gibraltar has set up an Academic Chair to lead a faculty – the Centre of Excellence in Responsible Gaming (CERG) – on research into problem gambling and provide training on responsible gambling best practice for individuals working in the industry. Gibraltar operators have provided funding guarantees and made commitments in respect of the provision of data, which will be made readily available to the wider academic community.
GBGA chief executive Paul Foster urged the industry to get on the front foot and stop being reactive to regulatory change. “Responsibility is at the centre of gambling today and as a jurisdiction, Gibraltar, wanted to drive the responsibility agenda and make a real difference. Given there is a concentration of gambling companies and therefore related data, the opportunity to work with an independent body at the University of Gibraltar was a clear opportunity.”
The GGCF has raised over £2.5 million from Gibraltar gaming companies to fund the setting up of the CERG and fund its research for, initially at least, the next three years into areas such as:
- The impact of problem gambling on individuals, families and society and the means of mitigating negative impacts
- The prevalence of gambling addiction or other problematic behaviours and mitigation factors to prevent such adverse impacts from gambling
- Practical solutions that gambling operators can implement to minimise the harm associated with problem gambling
- Standardised identification, monitoring and measuring criteria for problem gambling and responsible gambling measures implemented to avoid problem gambling
- The creation, co-ordination and management of a database of online gaming industry information that can assist with research into problem gambling and responsible and safer gambling measures.
“Discussions are ongoing about how this programme can be integrated into the wider UK harm reduction strategy,” said Andrew Lyman, Executive Director of the Government of Gibraltar’s Gambling Division. “This process will not only benefit the UK but have impact on consumers in the wider gambling markets offered by Gibraltar operators. It would be a wasted opportunity if this level of integration with the UK did not take place.”
CERG is now in the process of establishing an online course for people working in the gaming industry, to increase their understanding of responsible gaming and its implications for the organisation that they work for. The course is designed to introduce and improve awareness of the warning signs and early stages of how a player develops gambling problems, as well as to provide an introduction to iGaming and an understanding of regulatory topics such as anti-money laundering.
The measures now being taken in Gibraltar are in fact putting the words of former chief executive of the UK Gambling Commission Sarah Harrison into practice. “We want to see you harnessing the same innovation and tools that are used to determine customer profitability, to drive customer protection. There is perhaps no better way to demonstrate a drive to raising standards than through a genuine and public commitment to meeting your social responsibilities,” she said.