Study on the Sharing of Information and
Reporting of Suspicious Sports Betting
Activity in the EU 28
A study for the DIRECTORATE-GENERAL EDUCATION AND CULTURE, Directorate Youth and Sport,
Unit Sport
By Oxford Research, Denmark
Objective of the study
Overall objective:
“to provide the European Commission with an overview of the existing frameworks
applicable in the 28 EU Member States and the rules/practices of stakeholders
regarding the sharing of information and reporting of suspicious sports betting
activity”
Specific objectives:
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Describe the role and tasks of key actors in detecting match fixing
Map regulatory and self-regulatory frameworks in EU 28 countries
Identify barriers for sharing of information at national and international level
Recommend necessary and appropriate EU action
Methodology
• Background
information
• Specific
objectives - 15
questions
28 country
studies
• 8 case countries
• 20 overview
countries
Study
objectives
Study output
• Desk research
• Questionnaires
• Interviews
Diverse set of
methodologies
Tools for collecting information:
• Desk research
• Questionnaires – to betting regulators and betting operators
• Interviews – betting regulators, law enforcement, betting
operators, sport governing bodies (national and international)
• Cross country
analysis
• Final study report
Today’s agenda
1.
How is suspicious betting patterns detected by betting operators?
2. What is the role of betting operators, sport and public authorities in
detecting suspicious betting patterns?
3. What does the law say about the possibilities for sharing of information?
4. National frameworks for collecting information and reporting suspicious
betting patterns?
5. Barriers for sharing of information?
6. Possible role for the EU going forward?
How is the existence of suspicious
sports betting activity determined by
betting operators?
How is the existence of suspicious sports betting activity
determined by betting operators (regulators if proactive)
Important distinction: Unusual versus suspicious betting activity
No common definition of what constitutes “suspicious betting
activity”
Betting operators monitor customers closely – “know your customer”
Detection approaches – market level:
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Sudden unexpected activity on a particular market
Bet sizes or volumes not typical for the type of market
Price changes do not effect demand as expected
Market trading volume deviates from than would be expected
Activity polarise around a single specific outcome
The market price becomes significantly out of line with traders’ assessment of
where it should be
Large price movement
Price movements that do not reflect the action on the pitch in an in-play market
Unusual performance based on the historic records of the teams or participants in
the match
How is the existence of suspicious sports betting activity
determined
Detection approaches – account level:
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An account, or a group of linked accounts, risked or won far more than is the normal
behaviour for the account(s)
Customer staking markedly more than normal
An account has been specifically opened to bet on a suspicious market
One account, or a group of accounts, won a large percentage of all winnings in the market
An account that has a bias towards betting for/against one of the teams suddenly
switching
Match fixing can also be detected by sport itself or public authorities
Role and tasks of national authorities,
sports betting operators and betting
operators
Role and tasks of national authorities, sports betting
operators and betting operators
Betting Operators:
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Access to customers and accounts – betting patterns, individual bets, total volume, history, etc.
Can suspend betting on matches and void bets
Often best placed to detect suspicious betting patterns
No sanctions
Sport Governing Bodies:
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Direct access to athletes, matches, tournaments, etc.
Can sanction athletes, officials and clubs – also where public authorities don’t
Can introduce requirements in players contracts and for clubs to take part in tournaments etc.
Public Authorities:
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Grant licenses to betting operators
Regulate betting operators
Can have direct access to customers and bets
Law enforcement and investigation
Sanctions – larger cases
Commercial betting monitoring companies
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Compare across operators, including Asia
Compare actual odds to statistical odds
Monitor matches, leagues, players, referees, clubs to detect suspicious persons or organisations
Actors have complimentary roles – detection is most effective if key actors work together
Sharing of information
Sharing of information
Important distinction:
• Non-personal information versus personal information
• Who is the information shared with? Law enforcement or private organisation?
What information can be shared?
• In general it is not problematic to share aggregated market level data – like odds
movements, market volume, etc.
• Sharing of personal information is tightly regulated
The European Union Data Protection Directive 95/46/EC of 1995 sets the conditions for
sharing of personal information
• allow the free sharing of personal information within the EU
• protect the fundamental rights to privacy with respect to the processing of
personal data
How to evaluate if personal information can be share?
• Has the subject given his/her consent?
• Legal obligation?
• Justified?
• Proportional?
• The only option?
• Shared with organisation able to handle information?
Frameworks for collection of
information and reporting of
suspicious sports betting activity
Frameworks for collection of information and reporting of
suspicious sports betting activity
Most countries who have revised their betting/gambling regulation recently
have some sort of obligation to collect and/or share information
Important distinctions to understand different approaches:
• Collection of information versus reporting of suspicious betting activity
• Direct versus indirect approach
• Proactive versus reactive approach by regulator
Collection of
information on
suspicious betting
patterns
Reporting of the
information
Frameworks for collection of information and reporting of
suspicious sports betting activity
Categorisation of frameworks to collect and share information:
Neither the betting regulator nor the betting operator has an obligation to collect or share
information – typically countries that have not revised their gaming act recently
The betting regulator is obliged to collect information on suspicious betting patterns
(proactive)
The betting operators are obliged to collect information on suspicious betting patterns
(reactive)
• It might/might not be specified how this obligation should be fulfilled
• Not all betting operators who are obliged to collect information are also obliged to
share the information.
The betting operators are obliged to share information on suspicious betting patterns with
authorities (reactive):
• It might/might not be specified how markets should be monitored to enable the betting
operators to detect suspicious patterns and share information – often it is not
• It might/might not be specified what constitutes suspicious betting patterns and when
betting operators should be informed – often it is not
Frameworks for collection of information and reporting of
suspicious sports betting activity
The proactive approach:
• France – Arjel has access in real time to to all transactional data generated
• Italy – ADM has access in real time to to all transactional data generated
The reactive approach
• The UK – betting operators are obliged to report suspicious betting activity to the
Gambling Commission (direct obligation)
• Spain – betting operators must be able to answer information requirements of
the Spanish gambling regulator => must collect information (indirect obligation)
• The Netherlands – Upcoming law requires betting operators to have betting fraud
detection system capable of identifying irregularities
• Schleswig Holstein, Germany – operators shall work with two independent
monitoring systems
Frameworks for collection of information and reporting of
suspicious sports betting activity
Even in the absence of regulation all – at least medium or large
- betting operators will collect information on betting activity
Voluntary Frameworks:
Both national lotteries (ELMS) and some of the large private betting
operators share information internally (ESSA)
MoUs - If betting operators share information with sport governing bodies
they do it through Memorandums of Understanding (MoUs)
Commercial betting monitoring companies also collect information on
suspicious betting activity – like SportRadar
Little variance in what is shared and when from sport to sport
Sharing of information - barriers
Sharing of information - barriers
As explained the Data Protection Directive sets certain boundaries for sharing of
information - the right to privacy – but certain issues complicate it further:
Most cases are unique - Judged on a case by case basis
Little precedent from previous cases to provide guidance
Directive is implemented differently in different countries
insecurity -> causes actors to be cautious
Police/prosecutors are reluctant to inform private organisations – betting operators
and sport governing bodies
It differs within the EU if betting operators can share personal information with sport
governing bodies – due to differences in implementation and interpretation of law
• Permission to share information found in most betting operators Terms and
Conditions have never been tested
Sharing of information - barriers
Practical barriers to sharing of information:
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A cross border phenomenon - which sport governing bodies and public authorities to
contact in other countries?
Difficult to have MoUs with all sports governing bodies in all countries
Potential receiver of information might not have appropriate information handling
procedures
Unit in possession of information might not want to share information
A pan European law for data protection is currently being drafted –
expected to be important step in the direction of harmonisation
between countries
Possible role for the European Union
Possible role for the European Union
Encourage MS to ratify and implement the Council of Europe Convention
on Match Fixing
Support MS’ implementation of the convention on match fixing – i.e.
national platforms
Evaluate need for coordination platform to improve coordination of
efforts, cooperation between national platforms and information sharing
at EU level
• Facilitate sharing of non-personal information
Address uncertainty and stimulate exchange of personal information within
the limits of the data protection directive
• Bring more clarity to what personal information can be shared and under what
circumstances?
• Secure that new pan European law for data protection allow for an appropriate
degree of sharing of personal information in cases of match fixing
Thank you – questions?
Morten Larsen – mla@oxfordresearch.dk