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