EEGReport Magazine: The Lithuanian Gaming Law (the Law) which came into force on the 17th of May 2001 has recently received some new Amendment. Which are the key changes in the law and when does it come into force?
Renata Berzanskiene: The amendments of the Law came into force from 1 January 2016. The key changes are related with organisation of online/remote gambling. This was not allowed in Lithuania before. It took nine years to adopt these amendments. The amendments should help to fight with illegal online gambling. The changes are related to licensing, procedural matters, promotion of gambling, gambling establishments, supervision of gambling organisers. The law did not meet reality for almost a decade and the state was losing money as it was estimated that every year the state has lost almost 6m EUR of unpaid taxes.
As online gambling – a relatively new phenomenon that has spread in the world due to new Internet technologies and e-commerce. Respectively sovereign state could regulate the gambling sector with licensing requirements as it is risky to leave this to market self-regulation. Online gambling is not as easily controlled by means of the traditional regulatory measures. Internet has no borders and consumers can easily reach other countries. With the development of e-commerce and electronic payment technologies it has become easier to set up online gambling transactions, thus problem of applicable law arises. For example, US tried to combat this negative phenomenon of blocking websites, banning electronic payments for gambling and online gambling by prohibiting same. However, it eventually became clear that even these measures were not effective enough.
On 2013 the Supreme Administrative court of the Republic of Lithuania banned online gambling in our country as the Law which was passed on 2001 did not provide for a possibility of online gambling.
EEGReport Magazine: As we know there have been added some new restrictions for companies that engage in online gambling. Which are the new restriction and do you think that this will attract more foreign operators to apply for licenses on the territory of Lithuania?
Renata Berzanskiene: There is a requirement to have a branch office in Lithuania, minimum paid share capital requirement and requirement to open a certain number of real-life gambling establishments in Lithuania. These requirements are consider as limitations. The requirements to establish real-life gambling houses and to have a minimum paid share capital are likely contrary to the basic principles of European Union law, such as free movement of services and capital. If you do not meet these requirements, the licence for online gambling will not be issued and the Supervising Authority might stop all financial operations and settlements for those violating the Law.
According to current wording of the Law, it is prohibited to advertise gambling, except for certain specified gambling-related information, such as the names of companies organising online gambling. The amendments introduce a new prohibition – it will be illegal to make gifts to players after they participate in gambling activities. Another new rule is that it will be unlawful to organise contests, lotteries, trial bets and other activities outside gambling houses or outside the organiser‘s webpage.
There are some amendments dedicated to fighting the negative effects of gambling addiction, they include: that gambling organisers are obligated to put up signs warning players or visitors about the addictive nature of gambling and informing them about the legal gambling age. Also players can ask gambling organisers to limit their participation in online gambling activities, eg to limit the maximum amount that the player who made the request can bet. Players participating in online gambling always have to get clear information about the time they have played, their betting amounts and their gambling results.
EEGReport Magazine: What are the key sectors in the Lithuanian gambling market based on niches? Sports betting, casino, poker?
Who are the key operators at the moment and how is the taxing done in percentages?
Renata Berzanskiene: According to the information provided by the State Gambling Control Commission, 15 gambling companies operate in Lithuania. The biggest player is Olympic Casino Group Baltija, which operates in Lithuania, Latvia and Estonia. Other important players are Unibet, TOPsport, others. Sports betting is very popular in Lithuania, as we still are the basketball country.
The last year in Lithuania showed significant signs of revitalization. If during the beginning of economic crisis most of operators were complaining of diminished customer flow as they were trying to save and spend less money. This trend in turn caused significant decrease in turnover, complicated options to regain funds invested into business, these days there is significant revitalization in this sector. Until now the center for entertainment business is Vilnius because of higher number of people, higher salaries, also of tourist concentration, those conditions are more favorable to expand entertainment business there. I think this will attract new players in the market as now we see acquisitions in this sector.
EEGReport Magazine: What advice would you give to potential new entrants considering Lithuania (operators, affiliates, suppliers etc)?
Renata Berzanskiene: Companies that wish to engage in online/remote gambling activities will have to establish: 1 gambling house or 5 betting terminals for horse racing or, 10 machine parlours or, 20 betting shops or 20 totalisator shops. Companies who want to engage in online gambling, should get the licence for remote gambling from the Supervisory Authority. There are requirements set in order to get such licence and the Supervisory Authority might establish new requirements. From our practice we can say that the Supervisory Authority is cooperative.
Companies that wish to engage in online gambling will have to have a minimum paid share capital of EUR 1,158,000. Foreign entities will also have to raise their minimum paid share capital to the required amount, even if the country of origin has not established any requirement for a minimum paid share capital. Such companies will have to either invest in government bonds or hold in bank (or at the company) a fixed amount of at least EUR 72,400 for the sole purpose of paying out online gambling winnings. As regards the bank, it is not clear whether it should be a Lithuanian bank or not necessarily. The law does not specify what bank it should be, so any reputable EU bank should be suitable, keeping in mind that the money does not necessarily have to be in bank. The essence here is that there must be a separate amount for paying out online gambling winnings. So the objective is that there must be a fixed amount for paying out the winnings, so that players do not experience any inconvenience waiting for their payments, etc. In the event that the amount decreases to less than EUR 72,400, the amount must be restored to the required level within two calendar days.
The Law expands the rights given to the supervisory body ie, the Gambling Control Authority http://www.lpt.lt/en. With the introduction of online gambling, the amendments will give authority to the supervisory body concerning online gambling, issuing of licenses for organising online gambling, etc. The main change regarding the supervision is a right given to the supervisory body to order Internet service providers to block access to illegal gambling sites. The right to order ISPs to block access to illegal gambling sites is probably the most controversial provision of the amendments. It has been strongly criticized as superfluous and as establishing Internet censorship. ISPs will have to take on this burden. The rules established by the supervisory authority establish that illegal web-sites should be blocked using DNS and the users will be transferred to information web-site created by the Supervising Authority. This will be done after the court order will be obtained. In practice I presume it might create many problems and in Internet already there are some tips how to access illegal websites.
The tax rate for lotteries and non-remote gambling stays the same – 5% and 15% respectively. For the remote/online gambling, the tax rate will be 10%. Any gambling organized remotely using means of remote communication will be taxed 10% and gambling that’s organized non-remotely will be taxed 15%.
EEGReport Magazine: Since your company consults for more than one market, we would also like to hear your thoughts on Estonia. What is the current situation in the country is what is the current view regarding online gambling for remote operators?
Renata Berzanskiene: In Estonia remote gambling has been regulated since 2010. The market has thereafter been rather stable with one or two new operators entering the market each year. Access to the webpages of non-licenced operators is blocked – currently about 1130 domain names of non-licenced operators are blocked in Estonia and the list is growing.
The process to obtain the licences necessary to operate remote gambling is fairly straightforward once the necessary paperwork and technical solutions are in place. Certain Estonia-specific IT developments are unavoidable for operators that want to obtain the Estonian licences. For example the Estonian regulator (the Tax and Customs Board) maintains a national self-exclusion list, where players can self-exclude themselves from gambling. All operators have to interface their systems to the national self-exclusion list in order to ensure that self-excluded players are not allowed to play. Gambling operators must also connect their electronic recordkeeping and control system with the information system of the Tax and Customs Board.
In 2015 advertising restrictions were alleviated for lotteries and sports betting. Advertising of games of chance is permitted only in certain exceptional cases.
The gambling tax rate for remote gambling is 5% and it is applied on the charges received by the operator for organising the game.
EEGReport Magazine: Looking further afield, where are the major emerging opportunities in Eastern Europe for operators at this moment?
Renata Berzanskiene: I would recommend Lithuania. On December 2015 it was announced by Forbes that
Lithuania has made the biggest progress and is in 17th place, which is better than USA, Estonia and Germany. The last year Lithuania was in 25th place. „Doing Business“ also raised our index and now we are on 20th place. The amendments of the Law and a rise in our economy will give a stimulus to develop business in this sector. From our practice we see that there are already some acquisitions and interest in this sector.
Tom Light -SBTech Interview- (EEGReport – Magazine – Issue2 – February – May 2016)
EEGReport Magazine: Eastern European markets are growing at an incredible rate and I don’t think that anyone can argue about the fact the sports betting is the biggest niche when it comes to online gambling in Eastern Europe. Do you feel that this is accurate?
Tom Light: In most cases yes, we see that in countries such as Bulgaria, Czech, Hungary, Lithuania & Poland, sports betting is accountable for 75%-90% of the Gaming GGR, which includes Sports, Casino, Poker & Bingo. For markets like Latvia, Romania & Slovakia Sports is still a major sector within the gaming industry being accountable for 30%-50% of the GGR.
In play in particular has been a growth denominator in the past years for online sports-betting, allowing the punter roll-over his funds several time during one match.
Beyond the turnover it is important to mention that the margin is much high when it comes to sports betting, as well as the image of sportsbetting, which says that if you are good and knowledgeable you can make money.
We should even see a bigger increase during the Euros coming this June, as many non-punters would start betting on their favorite reprehensive teams.
EEGReport Magazine: Can you maybe give examples of countries where this isn’t happening and casino or other gambling products might surpass the sport betting audience? You can even mention markets that aren’t yet legalized in terms of licensing.
Tom Light: Romania is an example for a country that up to last year had 10% more turnover on casinos then on sportsbetting, I think this is related to regulations and since the new regulations came in to place I’m sure that during 2016 sportsbetting GGR will surpass casino.
To put in perspective, globally, the sportsbetting GGR is bigger than the all the other gaming sectors…Combined!
EEGReport Magazine: There has been a lot of innovation when it comes to sports betting products, and with one of the major European soccer event coming up this June, are you guys busy in the lab trying to bring new technology that will make online sports betting easier or even more attractive?
Tom Light: These days we are simply talking about personalization, which in core is the knowledge the operator has for each of his punters, the more knowledge the more personalized. Data can be gathered via the most common logs of all betting activities, behavior on the website, but even polls and ‘Mark as favorite’ buttons. Mapping this business intelligence is not a simple task, but the operators who are able to do so will have amazing insights on their clients.
Once data is collected and offer must be created via various algorithm and rules, based on many variables such as favorite teams/leagues, past winnings, past losings, trigger-happy cashout, etc… in order to create various offers for example:
“Manchester United did the job for you last time, can they do it again?” (While adding a betting button).
These offers are much more effective and are much more converting then just showing a generic offer to all customers or even to customer segments.
Another way to create offers, is using cross-player data, same as amazon does, with:
“Customer who bought these products, also liked XYZ …”. The likes of Bettorlogic offers this type of service which is taking the betting behavior of punters who made similar bets and are informing the customer which bets he might like. Since this is a more social way of bet recommendation, this might be more appealing to the punter which might not driven from the ‘house’ recommendations, as much as the activities of other partners.
The last part is to serve this offer in a proper matter, which can be targeted ads, SMS marketing, push notifications, widgets / pop-up on the site, or even gentle highlights of bet markets across the page.
EEGReport Magazine: Most of the Eastern European countries have qualified for the EURO 2016, this means that you don’t have to a betting fanatic to bet on your country during such events. Everyone will do it for at list the period on which the tournament is being played. What does this mean for online sports betting operators and especially software providers?
Tom Light: Back in the day, it was very clear, if you are an Italian operator, and there is a game ‘Italy VS Portugal’, you are as much gambling as all the punters on your sportsbook – the risk was one sided, and the results were sometimes amazing but other times destructive.
In today’s world, this scenario cannot happen, the punters are betting 85% of the times on in-play live betting where the bet markets are very liquid, such as fast markets – what will happen in the next one minute, corners, 1×2 rest of the match, etc… all these markets spread the risk around various bet selection making the operator the desired margin instead of a roller coaster.
EEGReport Magazine: Looking further into the future. What are in your opinion the top markets that are going to open up for online gambling in Eastern/Central Europe?
Tom Light: I would look at Netherlands, Czech Republic, Portugal, and the evolving of the Romanian market.
Netherlands being a market proven in the .com market with high PV.
Czech Republic which is the Eastern European diamond, which is now dominated by TipSport, iFortuna, Sazka, Synot and StarTyp will open up Jan 2017 for additional licenses by international companies.
Portugal, with mass-market attraction for sportsbetting, various .com case studies such as BWIN and Betsson(Dhoze).
And of course the Romanian market which is proving to be very fruitful by the day.
Tom John Light Biography – (EEGReport – Magazine – Issue2 – February – May 2016)
Tom John Light was born and presently resides in Tel Aviv, Israel. Tom has lived and traveled worldwide and is highly knowledgeable and experienced working in various global regions.
Tom has been working in the gaming industry for many years with a focus on casino operations and sports betting. Currently Tom acts as Vice President of Business Development at SBTech. He is renowned for his role as Vice President of Business Development at FashionTV. Additionally Tom has successfully served as CEO for several online gaming companies such as 7Red Casino and 1King Casino.
Tom is recognized for his high involvement with the creation of the Online How-To Guide ‘eHow’ and has been featured/published in various interviews and articles.
Gal Ackerman Crowdtrading – (EEGReport – Magazine – Issue2 – February – May 2016)
EEGReport Magazine: In the last couple of years we have seen a growth in the launch of financial programs, but none of them seems to attract so many new traders as Trade360. The innovation which came with CrowdTrading seems to have swept the enthusiastic traders off their feet and they now choose your platform for their trading activities. What is the real innovation behind this phenomenon?
Gal Ackerman: In a nutshell, CrowdTrading is about taking the big data that banks and brokers rely on and putting it in the hands of the people. Revealing how new market trends develop in real-time is really the perfect way for new Traders to get a feel for the rhythm of the markets, and as their knowledge grows, their profits should too!
EEGReport Magazine: When it comes to financial trading programs and platform, a huge concern always is raised and it’s a concern the EU is trying to battle daily. It is concerns regarding Money Laundering. How is Trade360 with such problems, has there been any incident, is it tracked and reported?
Gal Ackerman: We have a talented and experienced team dedicated to AML. So far, we’ve managed to identify and prevent the handful of attempts that have been made to cheat the system. We’ve reported each incident to the appropriate authorities and we’re confident that we’ll continue to stay well ahead of the curve and maintain our all-important integrity.
EEGReport Magazine: Since Trade360 is a rather new financial service form, it falls within the newer and stricter operating guidelines issued by CySEC. How are client deposits protected and standards executed in this enhanced regulation?
Gal Ackerman: Our legal team in Cyprus is in constant contact with CySEc to ensure full regulatory compliance. Our clients’ funds are held securely in segregated accounts at top-tier EU banks and our customer support team is always working to ensure the highest standards of service across the board.
EEGReport Magazine: How are the affiliates taking advantage in promoting this innovative way of trading? There certainly has to be a high demand for marketing materials and payouts. We’ve seen that there is a top $650 CPA for affiliates.
Gal Ackerman: The growth in our Affiliates Programme has been exponential, and we’re all very proud to be part of it. We know that to attract the finest Affiliate talent, we need to pay the best CPA, and I’m so pleased that there have been so many substantial payouts in such a short time. Our USPs are proving to be super-appealing to clients, feedback from Affiliates is universally positive, and it’s very gratifying that collateral take-up is so high.
EEGReport Magazine: As we know, you have always been in the Financial industry. In your expert opinion, can there still be room for innovation in these trading platforms? We have witnessed so many these couple of years, that gave access for individuals that did not know anything about trading to start and venture into this great niche.
Gal Ackerman: I think there will be major convergence between people’s social, leisure and economic networks over the next few years, with advances in augmented reality enabling us to multi-task far more effectively. And with the growth of decentralized, crowd-based and peer-to-peer financial services, I think we’re going to see some very interesting developments in terms of synergy, gamification and crowd investing. Watch this space!
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