Concerns continue to be raised by iGaming stakeholders regarding player protection proposals that are part of the upcoming Finnish commercial gambling market.
Jari Vähänen of the Finnish Gambling Consultants Oy (FGC) believes that the current proposals “undermine” the government’s gambling act.
Vana Lauri OÜ (VL) and Sininauhaliitto ry (Blue Ribbon Association) also voiced their opinions as part of a consultation by the Ministry of Social Affairs and Health’s Gambling Harm Risk and Harm Assessment Group on player protection regulations pitched by Finland’s new gambling act.
Industry stakeholders have until 24 February to take part in the consultation.
Game types and reforms
Vähänen stated in his response that different game types available on the market are not accounted for in the proposals.
He highlighted the varying transaction timings that casino and betting tend to have, with casino money transfers taking place in a single session, whereas betting money transfers may be held in a player’s account for longer and have larger stakes.
“Currently, customers playing Toto games are disturbed by a mandatory time reminder in Veikkaus’s operations. The nature of toto game formats is such that the normal practice is to follow the races and place bets in a continuous session of up to hours, where the length of the game session still does not have a significant impact on the harmfulness of the game.
“The nature of different games should also be taken into account when assessing and limiting the number of games. In the above-mentioned toto games, it is normal for a customer to play three to seven different games during the day. This still cannot be considered to mean an increased risk of gambling problems, as evidenced by the low number of gambling problems caused by toto games.”
Finland’s 2018 reforms were also mentioned by Vähänen, as in less than a decade, the channelisation rate has “dropped to approximately 50%”, previously at 90%.
“Due to Veikkaus’ responsibility practices, active and problem gamblers had switched to playing with the services of gaming companies outside the system. If the unauthorised offering is able to offer a clearly better customer experience than the authorised offering, such a development is inevitable in the future licensing system as well.”
Dropping Channelisation
The proposals also won’t have the desired impact on player protection in the market, according to Vähänen, who believes a decline in channelisation will occur, as players who may be suffering from gambling harm would migrate to the black market.
“The proposal under comment in its current form would mean that problem gambling would move to, or in fact remain in, gaming companies outside the gambling system. Therefore, it is clear that the law’s goal of reducing problem gambling could not be achieved.
“Responsibility measures built into the official gambling system do not affect and are not effective in gambling that takes place outside the system.”
A reevaluation of the proposals is being called for, as well as experts to be consulted.
“The recommendations in the proposal would undermine the basis for the implementation of the objectives of the Gambling Act as defined in the Government Programme.
“In the short term, they would lead to a rapid decline in the channelling capacity and the displacement of problem gambling outside the system and the consumer protection it offers. In the longer term, this would at least lead to an increase in gambling problems and possibly even their spread.
“The FGC believes that the proposal should be returned to preparation and should be prepared in such a way that improving the channelling capacity of the gambling system is also taken into account. The FGC believes that the working group should be supplemented so that the expertise in the gambling business in the group is strengthened.”
Duty of care undefined
Sininauhaliitto stated the duty of care is not defined with “sufficient precision” in the proposals, leaving its definition “too much up to individual companies”. The company added that the suggestions were a good starting point, but more precision is needed, as they are “justified from the perspective of preventing gambling harm”, but it intervene too late.
Loss limits should link to “how many companies within the system it is possible to play at”, not company-specific, said Sininauhaliitto. Stricter gaming restrictions were also called for since the vertical has a higher concentration of problem gamblers.
“The Blue Ribbon Association expresses its concern that the recommendations are not sufficiently binding and that companies are not implementing them. The Blue Ribbon Association believes that their binding nature should be strengthened.
“The Blue Ribbon Association believes that a mandatory and centralised system should be introduced in Finland regarding both consumption limits and the duty of care.”
Restrictions can’t be too strict
One company interested in applying for a Finnish licence is Estonian operator Vana Lauri OÜ, but it believes the proposals are “in conflict with both the newly enacted Gambling Act and the objectives set for the entire reform”. The operator stated that players will go to black market operators if restrictions are too strict, citing Germany and Belgium as examples where a drop in channelisation has taken place.
“When the goals of the gambling system are the prevention of gambling problems and high channelling capacity, it is important to understand that the latter is a prerequisite for the former to be achieved.
“If the system’s channelling rate is low, in practice, the most problematic gambling will always flow outside the system. That is, the very gambling that is being tried to be curbed by the safety net built into the system. The system’s built-in safety net is naturally of no use to players, especially problem gamblers, who play games outside the system.”
VL added that operators who stick to the guidelines would be in a “significantly worse competitive position in the market than those who would not follow them, at least to a significant extent”.
“VL believes that there is no reason to issue recommendations such as the one proposed at this stage, but rather to ensure the creation of a licensing system capable of channelling within the limits set out in the legislation in the first stage.
“As was often emphasised during the parliamentary debate on the law, it is important that the effects of the system change on the amount and quality of gambling problems are actively monitored and that there is a low threshold for being prepared to make changes at least at the regulation level if the development does not meet the goals set for the system reform.”