time control of the irish borders to fit with irelands … technologies.pdf/files...central...

291 River Road, Sault Ste Marie, ON CANADA P6A 5K9 Tel: +1 705 759-1832

The Casino Gaming Control Section

Department of Justice, Equality and Law Reform

2nd Floor,

Bishop's Square,

Redmond's Hill,

Dublin 2

Attn: Dermot Ahern, D.T., Minister of Justice, Equality and Law Reform

November 20, 2009

Dear Minister Ahern,

Re: Making a Fully Informed Decision on Ireland’s Options in Blocking Unauthorized iGaming

Please consider with some urgency the following information in your review of gambling in Ireland. We

have market access control technology for internet gambling (iGaming) that is unlike any previous

‘solution’ for managing the iGaming market.

Our technology system is extremely precise, designed specifically to restore total market control of

iGaming to a government authority. It is capable of page specific URL-blocking as well as blocking

existing play and massive revenue outflows by currently active players in Ireland. It gives the government

central real-time control of the Irish borders to fit with Ireland’s gambling laws and policies.

The result is that with our technology, Ireland is fully in charge of its iGaming framework, licensing

approach, taxation rates and regulatory compliance. In other words, it lets Ireland treat iGaming in

exactly the same way it manages any other form of gambling in the country.

This technology is the turning point for iGaming decision-making in governments. We have presented

the technology to GREF (Gaming Regulators European Forum) and are in discussions with several

European countries for its use in their iGaming models. It is critical that Ireland understands the

empowerment our technology brings to their future iGaming management.

/…2

Furthermore, it is technology that Ireland can put in place immediately. The employment of this

technology right now can establish a foundation for all Irish iGaming planning, including configurable

‘brownout’ periods during the application process for those iGaming operators who have not applied,

and full ‘blackout’ control on those not approved at the end of the process.

The result of employing our system is that Ireland will capture all iGaming taxation revenue, and

approved operators will be rewarded with the full iGaming marketplace in Ireland – no ‘leakage’ of

revenues to unauthorized sources.

Ireland government gaming authorities need to know that there are extreme flaws with other blocking

options traditionally considered. IP list blocking leaves a gaping hole – it does nothing to stop the

wagering activity of existing players that have downloaded an application onto their computer or

mobile. This means IP blocking will leave the vast majority of current iGaming revenue ‘unblocked’, in

essence cheating Ireland out of tax revenues and cheating future legitimate iGaming license holders out

of access to the whole iGaming market in Ireland. Banking transaction blocking is notoriously easy to

get around, as the United States learned with UIGEA. Again, this approach results in a large portion of

the iGaming market remaining uncontrolled, unauthorized, untaxed and unregulated.

Our technology is called EdgeDefinition™ Market Access Control. I have attached for your consideration

four different documents outlining its importance in setting up iGaming. Please refer to our GREF

presentation, the iGaming Blocking Comparison Chart, the EdgeDefinition™ Summary, and the

BlackEdge Technologies White Paper on iGaming.

I strongly believe this technology is fundamental to your future internet gambling framework. I invite

you to explore more of its capabilities with us through a live demonstration and a detailed exchange of

information. Most of all, I urge you to be fully aware of the options available to you in iGaming

management, and to make decisions that fully meet your objectives in managing gaming for full public

benefit and with absolute control over public safety and gaming integrity.

I welcome any opportunity to discuss this further with the Ministry.

Best regards,

Ian Plumley

President & CEO,

BlackEdge Technologies Inc.

Technology Solutions that Empower Legal iGaming Management

www.blackedgetechnologies.com

http://www.blackedgetechnologies.com/

EdgeDefinition™ puts your State in control of its borders for Internet Gaming

It’s your house. You decide who can play.

Product Summary An industry exclusive solution that gives gaming jurisdictions full control over their Internet geographical boundaries. EdgeDefinition™ constantly maintains access control over known and emerging illegal internet gaming sites while enabling those legal in your jurisdiction. Vigilant. Constant. Reliable. Proven

Product Features and Highlights • · Centralized Administration • · Page-specific URL Enablement/Disablement • · Geographical Precision in Access Borders • · Proven multi-million user Installations • · Empowering ‘Conduct and Manage’

Unlike any other gaming software market management solution, EdgeDefinition™ puts gaming authorities in authoritative control of their borders. While Internet gaming began as an unregulated market, its emergence as the fastest growing sector of gaming depends on one thing—the ability of gaming regulatory bodies to regain the full control of their market as specified by law. BlackEdge brings an unprecedented solution. Proven in major worldwide installations, EdgeDefinition™ achieves what has not been done before—real time, full time access management that identifies unlicensed gaming sites while enabling state-sanctioned sites.

Contact Us for a Demo—take control now.

Our team can show you live how this works, and how EdgeDefinition™ addresses all the igaming legal framework needs for your jurisdiction—whether you want to control and licence igaming sites or simply stop millions of dollars bleeding from your economy. Call Ian at (705) 759-1832 or email [email protected]

Find out how we bring the pieces of the igaming puzzle together at

www.blackedgetechnologies.com

iGaming lobbyists like RGA and EGBA, funded from iGaming operator profits, try hard to convince jurisdictions to not use blocking.

Their motivation is clear – to keep all iGaming profits flowing for pure corporate gain, at low or no tax and with little control. They want to preserve an extreme imbalance versus all other forms of Gambling. Their misinformation campaign is well-funded but entirely self-serving.

iGaming can be managed within your jurisdiction.

Within your gambling policy and laws. On a consistent level

with other forms of State-authorized gambling.

At a fair and consistent gaming tax rate for public benefit. With full regulatory and compliance

control to protect your citizens.

EdgeDefinition ™ Access Control Technology is designed

specifically to enable State control of iGaming within State

borders and laws. It is a technology that restores power to the jurisdiction and

dramatically increases iGaminglicensing revenue and regulatory integrity.

Compliance PublicBenefit

Stops

Unauthorized Access by Unlicensed Operators

Empowers Full RegulatoryCompliance & Shutdown

Avoids Overblockingand Unintended Disruption

Enables Licensing Fees Consistent with other Gambling

Protects Consumers and Access to Funds

Rewards LawfulOperators and Eliminates Bank Policing

Geo-BlockingVoluntary Operator-specific self-restriction by ethical or publicly traded companies or as required to obtain a license

IP List Blocking and PortalsState-mandated and enforced IP Address lists

EdgeDefinition™Page-Specific URL Address and iGaming Application Access Control within precise borders with central administration by the State and real-time monitoring and detection

The right blocking technology works. EdgeDefintion™ by BlackEdge Technologies.

Contact us for an in-depth discussion and demonstration of the only technology for pure iGaming market control. Visit www.blackedgetechnologies.com email [email protected] or call +1 705 759-1832

= NO = SOME = YES

March 30, 2009 ©BlackEdge Technologies Inc. 2009. All Rights Reserved Confidential Use Only

512 Woolwich Street, Suite 1 Guelph, Ontario

519 846-1905 www.blackedgetechnologies.com

How to Empower Effective State-Managed Solutions

For Internet Gambling (iGaming)

By: Roger Horbay, Chief Intelligence Officer BlackEdge Technologies Inc.

A BLACKEDGE TECHNOLOGIES WHITE PAPER

http://www.blackedgetechnologies.com/


Contents

The Evolution of iGaming 2

Identifying Issues, Updating Reality 3

European Lessons –

Close, but not Good Enough 7

BlackEdge – Bringing the Foundation

to iGaming Management 9

Licensing Models 10

Summary 11

“I'm shocked --

shocked -- to find

that gambling is

going on in here!'

- from the

movie "Casablanca”

"Gambling is going

on here … Rather

than supporting thousands of jobs,

economic activity and tourism, the federal

ban supports offshore operators and

organized crime."

- Senator Raymond Lesniak D-NJ

The Evolution of iGaming

In the world of gambling, iGaming began

outside of the structure and public interest

controls that have been applied to all other

forms of gambling.

And it evolved rapidly for three reasons:

Initial insignificance in dollar value

Superior interactivity and immediacy

Undefined internet gaming policies

But in the last 5 years of its existence,

iGaming’s importance in the gambling

industry has exploded, mirroring societal

and consumer shifts in e-commerce.

Today, iGaming is poised to become one of

the largest sectors of the entire worldwide

gambling industry. In the midst of the

economic collapse of

many land-based

casinos, pressures on

tribal gaming revenues,

serious viability threats

to the pari-mutuel

industry and stagnation

in traditional lotteries, iGaming continues a

decade-long double-digit growth rate.

It is no longer possible to ignore iGaming. It

is big business, uncontrolled, and in your

State.

The market has been notoriously difficult to

estimate in size – primarily because the vast

majority of revenue, literally billions of

dollars, goes directly to very few, very

private companies in offshore tax havens.

The importance of this estimating problem

cannot be underestimated, because vested

interests will deliberately understate market

size. Unmonitored, unreported and

untaxable gambling revenue more easily

escapes the scrutiny of tax officials in the

…major hotel-casinos in Nevada had their net

income slashed by over sixty five percent in 2008 –

The Nevada Gaming Control

Board


economies from which dollars are

being drained.

The most reliable sources* peg

iGaming at between $18 Billion and

$20 Billion U.S. worldwide in 2008,

excluding sports wagering

And projections over the next 4 years

show annual growth rates of up to

30%, with revenues expected to

exceed $30 Billion by 2012.

Figure 1 - 2008 iGaming Revenues and Projections

Currently iGaming represents 7% of

total gambling revenue. This will

climb past 10% in 4 years and will

approach parity with traditional

land-based casinos’ share within the

decade.

The addition of internet-based sports

wagering makes iGaming a dominant

form of gambling. Merrill Lynch

estimates worldwide internet sports

betting will surpass $200 Billion by

2015.

* (Sources: Washington Post/6o Minutes; H2 Capital

Group; PriceWaterhouseCoopers; GBGC Interactive

Gambling Report)

Identifying Issues, Updating Reality

To date, no single jurisdiction in the world is

satisfied with their iGaming framework.

The balancing act is extremely complex -

interests of state, gaming laws, international

communities, consistency with land-based

gaming, players, public safety and private

operators all collide.

This complexity often leads to a sense of

powerlessness by the State.

But the State is not powerless in iGaming.

Special interests like to cultivate the sense of

powerlessness. And with the sums of money

at stake in iGaming, the management of a

‘can’t be managed’ message is invested in

heavily to protect the status quo. Or more

accurately, to aggressively defend the vast

profits of the few private individuals that

currently own the only sector of gaming

happening outside government management

and policy.

The reality with iGaming is that it is simply

another delivery form of gambling.

And technology has caught up with the

Internet. In this paper States will learn of the

ability to manage gaming transactions,

access and safety within their own

geographical borders.

2006 2008 2010 2012

6.510.3

13.118.25.9

10.611.3

14.7

iGaming Explodes

United States Europe


Literally overnight, Party Gaming gave up its $880 Million (and rapidly growing) U.S.

business – and private companies like PokerStars and Full Tilt Poker stepped in

for extraordinary private gain. The market has continued to grow at rates in excess of

30% per year.

Legislative Flaws, Legal Reality

The iGaming legal landscape has

rapidly come into focus over the last

2 years. The increasing clarity

emerged from flawed high-profile

legislative and enforcement

initiatives:

UIGEA

DOJ

UIGEA, the Unlawful Internet

Gaming Enforcement Act, was a

devious and ill-conceived subset

added to an 11th

hour bill honorably

named the ‘Safe Port Act’.

Ironically hidden among 244 pages

dealing with the security of maritime

shipping containers and domestic

nuclear detection, UIGEA

singlehandedly brought total disarray

to the U.S. iGaming market.

It mistakenly presumed control over

the individual States on gaming,

which is a legislated and delegated

States’ Rights issue. It deputized the

Banks as the enforcement agency for

iGaming policing. And it enshrined

State and Tribal rights to conduct

intrastate iGaming under State Laws.

In its confusion, UIGEA handed the

entire U.S. iGaming market to

private offshore operators. It drove

out publicly traded companies and created

the single richest stream of gaming revenues

for exclusive benefit of those willing to

flaunt government control and those able to

avoid government scrutiny.

The U.S. Department of Justice (DOJ)

exacerbated the illusion of control of the

iGaming market with high profile arrests of

heads of iGaming companies on U.S. soil. It

did little to arrest the galloping growth of the

unregulated, unlicensed and untaxed

iGaming industry, and left U.S. officials in

awkward World Trade Agreement disputes

with suddenly empowered nations like

Antigua and the European Union.

State Prohibition Legislation, passed in

various forms by some individual States,

have added to the illusion of control, in

some cases by criminalizing citizens. Yet in

no cases are these legislated solutions

impeding the accessibility of iGaming.

Legislative ‘solutions’ for iGaming are

ineffective and redundant. Born out of a

misconception that the Internet is beyond the

law and that a national rather than

jurisdictional response is required, these

efforts have had the opposite of their desired

effect – helping unauthorized iGaming to

flourish while clouding the legal mandate

within current gambling laws.


Popular Misleading Legal Arguments

Like a clever card trick, illegal

iGaming operators are using

distraction to extend the inaction of

government gaming authorities in

seizing control of iGaming.

Their best ‘tricks’ aim to instill fear

and indignation among iGaming

consumers and paint government as

pointless bureaucratic interference.

Freedom of Speech - an attempt

to ignore the gaming transaction

Invasion of Privacy – an alarmist

claim that ignores the goal –

criminalize the illegal gaming

provider, not the player.

Game of Skill – an avoidance

claim to exempt poker from

gambling law, in spite of its

management as a casino game in

land-based gaming

Wager is Offshore – an attempt

to ignore where the bet is

physically placed by the player

Government Censorship – a

sensational emotional charge that

ignores government’s established

mandate to manage gambling

exclusively.

The 10th

Amendment of the U.S.

Constitution, Powers of the States

and People, reserves power to the

State of what is not delegated to the

United States. Among what is

expressly a States’ Right is

gambling.

Lawyers and lawmakers trying to understand the law of Internet gambling often make the job more difficult for themselves by starting with two unstated, and incorrect, presumptions:

1. Because the Internet obviously involves communications, it is assumed that gambling on the Internet is controlled by communications law, in particular that is protected in some way by the United States Constitution.

2. Because the Internet allows transactions to take place between individuals located on opposite sides of the globe as easily as on opposite sides of the street, it is assumed that Internet gaming is controlled by international law (or by no law at all), and that it is a problem to be dealt with solely by national federal governments.

Gambling is not a form of speech. When a bettor places a wager by speaking to his illegal bookie by telephone the activity is covered not by communications law, but by gaming law. If actual human speech is not analyzed under the law of communications, a wager placed through computers communicating with each other has no chance of being protected as an exercise of free speech.

The Internet in general and Internet gaming in particular are not sui generis. The ability of large numbers of individuals to easily communicate instantly across borders has been around since the invention of the telegraph. The United States and other federal governments did become involve with regulating the telegraph and similar technological breakthroughs, such as the telephone and short-wave radio. But the control of gambling has always been a matter left up to the states under their police powers. Gambling involves not only the health, safety and welfare of a state’s citizens, but issues of morality. These are almost always questions for state governments to decide. Federal governments are governments of limited power. Their role is to aid their states in implementing state exercises of police power, and not to dictate morality for the entire nation.

- I. Nelson Rose, Leading iGaming Legal Expert


Kentucky – A Different Approach

In October 2008, Kentucky became

the first State to assert its right to

manage the iGaming issue. It

acknowledged the existence of

iGaming and ongoing illegal

transactions under its Gaming

Statutes.

Kentucky confronted the private

operators to stop the economic drain

and safeguard its citizens.

While their initial attempt to seize

domain names succeeded in the

courts, the decision was successfully

appealed and is moving to the State

Supreme Court.

Regardless of the outcome,

Kentucky has re-established the right

and obligation of a State to manage

its iGaming marketplace within its

borders.

The Kentucky approach is extremely

significant in States’ Rights going

forward.

Direct Confrontation –

Kentucky has identified

specific illegal commercial

gaming operations

Independent Authority –

Kentucky has not asked for

Federal permission to

manage its iGaming issues

Existing Laws – Kentucky

has acted on contraventions

of its existing gaming laws

and has not needed ‘special

legislation’

These ingredients are fundamental to

State management of iGaming.

While the battle in Kentucky is just

underway, it is a pivotal point in the

evolution of iGaming management. Private

unlicensed and unregulated interests can be

expected to wage war. But for the first time

since iGaming became a major part of U.S.

gambling, the battleground has moved to fit

the realities of gaming law and States’

Rights obligations to manage gaming.

KENTUCKY STATUTES:

S528.010 – A PERSON ADVANCES

GAMBLING ACTIVITY WHEN, acting

other than as a player, he engages in conduct

that materially aids any form of gambling

activity.

S528.020 PROMOTING GAMBLING

IN THE FIRST DEGREE …WHEN he

knowingly advances or profits from unlawful

gambling activity

"… illegal and unregulated activity is occurring in Kentucky, and … millions of dollars are being lost as a result of (iGaming) activity, a fact that wasn't disputed in Tuesday's ruling... the most appropriate step is to make our case to the higher court,"

– Kentucky Dept of Justice & Public Safety

"Victory here was essential,"

-Patrick O‟Brien, Defense Counsel, KY domains


European Lessons – Close, but not Good Enough

Europe leads the world in attempting

to address iGaming management.

Significant nation-based responses

are evolving as the necessity of a

dominant role for the State in

iGaming management becomes

clear.

Three elements distinguish European

responses from the rest of the world:

1. The existence of iGaming is

openly admitted

2. The need for adherence to

State gaming policy and

public safety standards is

formally affirmed

3. The potential for iGaming

revenue is directly addressed.

Two national models illustrate the

critical mistakes that undermine the

effectiveness of iGaming

management models when i-border

control is absent.

U.K. – White Lists, Empty Coffers

The United Kingdom deserves a

special place in iGaming. The first

major nation to officially

acknowledge the existence of

iGaming, the U.K. established in

2005 a comprehensive framework

aimed at ensuring protection of its

citizens and realization of

appropriate taxation and economic

benefit.

Specific regulations on player

protection, game integrity and

taxation became law.

Unfortunately, the U.K. accepted a ‘White

List’ of current iGaming offshore nations.

This gave status to gaming corporations in

tax havens such as Alderney, Isle of Man,

Malta and Gibraltar.

The White List gaming companies

continued to freely provide gaming to U.K.

customers – but openly refused to pay the

15% gaming tax levy established by the

U.K. in April 2008.

The result - no major iGaming firm is

paying for access to the U.K. market.

In addition, compliance to regulations is

unenforceable. A recent study by the U.K.

Gambling Commission found that 33% of

gaming sites had no control over access by

minors.

Italy – Why „.it‟ Isn‟t All of It

Italy has come close to the optimal licensing

model for internet poker by requiring

operator licensing and taxation payments

and concentrating legal iGaming through a

government ‘.it’ portal.

An upfront licensing fee of 300,000 Euro

and an effective tax rate of up to 33% on

iPoker operators is being realized by the

Italian government through crude,

ineffective blocking efforts that give

legitimacy to those companies playing by

the rules.

Unfortunately several operators continue to

work around the primitive blocking

restrictions. Illegal sites still account for

about half of all Italian iGaming revenues.

Lesson 1: Compel Compliance


Italy is in the process of reviewing

different enhancements to their

blocking efforts, to give them full,

responsive and centralized control of

their iGaming border to strengthen

their overall solution

Europe Still Shaping iGaming Management

Europe continues to improve its

models and responses. From

prohibition-based countries such as

Germany and Holland to proactively

licensing-based countries such as

France and Spain, one thing remains

clear: a technology that constantly

controls and patrols iGaming

borders is essential to success.

Lesson 2: Block Intelligently

Relying on Uncertain

Regulatory Oversight:

Offshore, Out of Reach

The vast majority of the world’s iGaming

companies are licensed in remote offshore

gaming jurisdictions:

Isle of Man (population 76,220)

Gibraltar (population 28,002)

Alderney (population 65,726)

Malta (population 403,532)

Antigua & Barbuda (population

84,522)

In addition, a First Nations Mohawk

reservation south of Montreal PQ licenses

several leading North American iGaming

providers

Kahnawake Gaming Commission

(population 8,585)

In each case, licensee applicants pay some

combination of nominal application fee of

up to $100,000 and /or operating fees of

between 0.5% and 5% of gaming revenues.

The scrutiny of background ownership tests

and initial software testing occurs at a

reasonable level.

However ongoing operations tend only to

be reviewed or audited on an annual basis

or on a situational complaint basis. Actual

standards for gaming integrity, adherence to

underage, money-laundering or problem

gambling are largely left to the licensee

upon reading ‘best efforts’ clauses in the

licensing process.

This fragile framework is wholly endorsed

by iGaming industry lobbying associations

– Remote Gambling Association (RGA),

Interactive Gaming Council (IGC) and

industry consultant eCOGRA.

No outside country can force the offshore

regulators to make their licensees comply

with higher integrity standards or legislated

tax regimes.


BlackEdge – Bringing the Foundation to iGaming Management

Successful iGaming management

necessarily begins with border-

specific control of iGaming activity.

With constant, intelligent, proactive

State-centralized control of iGaming

exclusively within its borders, the

State is empowered to treat iGaming

with the same policies, regulatory

oversight, public interest taxation

approach, and control over integrity

and compliance.

State-specific iGaming border

control is the essential foundation of

State management of iGaming.

BlackEdge Technologies has the

only iGaming Central Control

Technology - EdgeDefinition™ -

designed specifically to integrate

iGaming’s complex legal, political

and operational demands.

Ultra-Precise Boundary Control

EdgeDefinition™ establishes control

of your exact State boundaries.

Every iGaming transaction that is

physically taking place in your

jurisdiction is defined through

EdgeDefinition™. This gives you

total control of your iGaming policy

without impacting other legal

gaming jurisdictions.

Focused on Gambling Activity

EdgeDefinition™ does not overstep your

legislated gaming laws. Sophisticated access

management software identifies and blocks

illegal gambling activity and access to

unlicensed gambling software, without

overblocking non-gaming sites or impeding

on basic 1st Amendment rights.

Real Time Intelligent Filtering

An Artificial Intelligence engine within

EdgeDefinition™ detects new illegal

gaming sites as they emerge and shuts them

down within the jurisdiction gaming policy.

Workarounds and attempts by illegal

gaming operators to modify their website

addresses are constantly thwarted.

Central Administrative Control

Gaming policy for the entire jurisdiction is

managed through a single comprehensive

back-end with full control over every part of

the system. Configurations including deny

page content and messages, time-limited

pass-through permissions for citizens to

complete withdrawal from their iGaming

accounts, new gaming threat reporting and

more reside within a master client panel.

With EdgeDefinition™ the power to

manage iGaming within jurisdiction gaming

law and policy is restored to the jurisdiction.

No Unauthorized Gaming.

Period.

The Essential Foundation: TOTAL COMPLIANCE Access Control Technology – Creating a Pure State-Defined iGaming Market


Licensing Models

iGaming exists. It is a major segment

of gambling. For jurisdictions whose

goal is to establish proper regulatory

and taxation control over iGaming,

EdgeDefinition™ creates pure

revenue growth.

With EdgeDefinition™, the State

can capture iGaming revenue –

without actually expanding gaming.

Licensing Existing Operators

In adherence with international trade

agreements, a jurisdiction can use a

‘brown-out’ approach to eliminating

unwilling or non-compliant iGaming

operators and re-allocating the

market to licensed operators and

State revenue.

Upon installation of

EdgeDefinition™ the jurisdiction

would announce a licensing structure

including prescribed taxation rate

and required gaming standards. A

period of grace to receive license

applications would be followed by a

first phase brown-out, where

operators not submitting an

application are shut down.

Following a licensing review, the final white

list of operators would share the existing

iGaming market while those not passing

review standards or not agreeing to licensing

terms lose access to the jurisdiction.

Under this licensing approach, it is highly

likely that total market revenue grows as

consumer trust accompanies the introduction

of State controls.

The Economic Hand –“Up”

While bailouts and handouts have marked

the latest economic downturn, a licensing

model for iGaming can deliver a hand-up to

ailing legal gaming operations in the

jurisdiction such as the land-based casino or

pari-mutuel industries. These bodies could

be appointed to either directly operate or

oversee existing licensees of iGaming

products such as online poker or online

casinos. Under this scenario, direct

economic benefit from State-authorized

iGaming can be shared within the gaming

industry.

Pre-Licensing

PokerStars

Full Tilt

Cereus

Cake

Licensed

Party

Boss

Full Tilt

State Tax


Essential Pillars for Licensed iGaming

Within the regulatory framework

designed by the jurisdiction, key

essential pillars that must be built on

the EdgeDefinition™ access control

foundation include:

Proactive Player Protection

Real Time Monitoring

Gaming Integrity Detection

Age/Person Verification

Active Money Laundering

Detection

Other Licensing Considerations

Taking control of iGaming is not a

gaming expansion. Existing gaming

management bodies such as a State

Lottery could be asked to add

iGaming to their gaming product

lineup, within the freedom of

existing gaming law.

The key to establishing a licensing

tax rate is to be consistent with other

forms of existing gambling in the

jurisdiction. As the minister

responsible for iGaming licensing in

France, Eric Woerth, stated, ‘you

cannot have a different fiscal

regime for a game played

online and one that is played

in a physical space.’

In reality, the cost of operating

iGaming is significantly lower

than land-based casinos, pari-

mutuel operations or even State

lotteries. As a result, the

potential for gaming levies that

are higher than current State

taxation of other gambling is quite good.

One alternative to a high iGaming tax rate is

to front-load some of the revenue through

license bid payments. These can add

substantially to the immediate return to State

coffers and reward those operators that

choose to participate over the long term.

Summary

Smarter technology. Smarter government.

Stronger protection. Significant Revenue.

The myth that iGaming is unmanageable by

a jurisdiction is false. That myth is erased by

EdgeDefinition™, the advancement in

technology designed to empower the State’s

rightful role in managing all forms of

gambling within its borders.

A State policy of inaction on iGaming is

now socially unacceptable in the present

economic crisis. Millions of dollars are

being drained from State economies due to

inaction on iGaming.

EdgeDefinition™ empowers an effective

State-managed response.

iGaming will be a major part of the future of

legal State-regulated gambling.

EdgeDefinition™ allows a jurisdiction to

make that future a present reality.

BlackEdge Technologies focuses on iGaming

technology solutions for safe, sustainable iGaming

markets.

Built on two decades of gaming and technology

expertise, BlackEdge brings its EdgeDefinition™

solution to today’s iGaming reality.

For a live online demo contact

[email protected]

mailto:[email protected]

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