The regulator’s perspective: Ben Haden

Simon Planzer: We’ve all been in Rome now for three or four days. Has the conference met your expectations?

Ben Haden: Without a doubt. We were hoping for a strong turnout, but we’ve had an amazing response with over 480 people. That is the first time I’ve seen a sellout at a conference like this. So, from that point of view, it’s been remarkable. But even more important is the diversity of people we have. You’ve got a brilliant range of jurisdictions, countries, skills, and experience. You can genuinely see people engaging with the topics on the program. People have really got into it, and that’s what we were after.

SP: The audience this time seems to be very international, with many more attendees from outside North America and Europe. Would you agree?

BH: Yes. You can see, for example, the increasing importance of regulation in Africa by the number of colleagues that have come from there. We’re lucky with IAGR that we usually draw a global crowd. But if you look at the number of continents represented, we’ve got someone from practically everywhere.

There are a couple of reasons for that: this has become an important time for regulators to meet. It’s a regular slot in the calendar where IAGR members know they come and be with their tribe, as I describe it. But this year, with the collaboration with IMGL, we’ve had a more expansive program. There is definitely something here for everyone, and I think you can see that in the number of side meetings happening in the breakout areas, the meeting rooms or just in the corridors. You see conversations happening all the time with a good range of people who are really keen to engage and talk about the challenges we’re all experiencing.

SP: That’s an excellent segue into my next question. From your conversations with regulators around the world, what are the common challenges they are facing?

BH: There are certainly similar challenges, but there’s often nuance and different perspectives, too. On our first panel on Monday, there were representatives from Canada, Denmark, Nigeria and Singapore. Very different cultures and environments, and yet you could see them coalescing around the talking points. They all need to keep their jurisdiction and regulatory regime fit for purpose. They recognize that the industry is changing, and it’s not easy sometimes to move as quickly as they would like.

There’s definitely something around the attraction and retention of talent. We, as a sector, are not alone in that. However, the range of skills needed within the regulatory space is much greater than it was even five years ago. We have to think much harder about how we attract and keep the best people when we compete with the private sector on salaries we can pay.

Then, there’s an interesting shared focus on making the most of the opportunities around data. Being efficient and effective with data is something everyone I talk to sees as a challenge. And then, finally, illegal gambling is a sectoral issue that we all have in common. Whether you’re a regulator, an operator or an advisor, people are thinking about illegal gambling, its impact and the role they should play in limiting it.

SP: Picking up the point about data, there has been a lot of talk during the conference about data driving regulatory decisions. What do you see as the possibilities and the limitations of that approach.

BH: Personally, I think the biggest limitation around data is aligning around what we mean by data and AI. AI spans everything from predictive text on your phone to the most complex, deep learning model and everything in between. It’s an easy word to throw around, but you want to be clear what you mean by being data-driven.

From my perspective, there are two things. The first one is around process. How do you make your process more efficient? How do you use data to re-engineer and improve processes? And if you look at the evolution of risk models, for example, the risk of operator non-compliance, how do you make sure you target your resource in the right place at the right time for the right reason? I think this is one of those areas where data is going to increase our potential to be more efficient and effective.

The second point is around data analysis and the ability to deliver deeper analysis than you can do with traditional techniques. By using wider data sets, we can better understand the market and what players are doing. In turn, this should enable us to see how things are changing and the impact that has so we can make decisions on whether to react with regulatory changes. Put simply, it means we can target more effectively than we have in the past.

SP: AI has been high on the agenda of the conference. Do you see an additional challenge for regulators to enlarge their employee base and bring this kind of expertise in house?

BH: There’s as interesting balance between what you can retain in-house and what you keep on retainer, as it were. From the perspective of my day job at the Gambling Commission in Great Britain, I’m keen to develop in-house capability, but I wouldn’t think for a minute that we will always have all the skills we need. We need outside experience to come in and supplement that. But it’s an ongoing challenge.

Teo Chun Ching from Singapore made the point in his panel session that they don’t need everything in-house. They can easily buy in highly specialized expert services. That’s definitely a model, isn’t it? What’s interesting is the tipping point in terms of developing something in-house versus bringing in new thinking, a fresh perspective, someone who’s done something interesting in, say, a different sector on a particular data science technique. Sometimes, you want to bring that in-house to create a team environment and give them a context within which they move forward, which can be easier within the organization. But you also need certainty. If I want an answer to a particular question, I don’t want to wait six months to recruit the skills to deliver it.

SP: IAGR is handing out its awards this evening celebrating excellence in regulation. Have you seen examples of best practice either around data or in other areas in different parts of the world?

BH: I try not to talk about best practice. When talking to our members, I’m not there to tell them how things should be done. I’m there to encourage a conversation and a dialogue and get them to share what they’re up to, how they’re doing it and why they’re doing it. That way, people can look at the various approaches and decide whether that’s something that would work for them too. To take the data example, do I want to have every single transaction with every operator in my jurisdiction? Or do I need a different level of detail to enable me to measure the outcomes that I’m interested in? It’s less about best practice and more about sharing lots of different examples of people doing things that are working.

I think there’s often a lazy narrative around regulators being slow and turgid compared to an industry which is light and agile and chasing innovation. From what I see, things are much closer than that. When you listen to the debates that regulators are having here, they clearly have an interest in responding quickly to market challenges. There is no desire to move slowly. Sometimes, that happens because of legislation. But you hear a lot of voices asking how can we create a framework for a new product and move that through quickly. How do we respond with data faster than we’ve been able to before? How do we evaluate the impact of what we’ve done faster so that we can change direction if we need to as we go forward? That’s one of the things I’ve learned, particularly over the last year, as I’ve talked to more and more people. I’ve had the chance to learn how they think and what they want to do, and you see some of it starting to come through at conferences like this and in the collaborative work we’re doing.

SP: Interesting that you mention collaboration, is it now an obligation for regulators to cooperate internationally or is it still possible for them to view their market in isolation?

BH: As we have already said, while we share many similarities, every jurisdiction is slightly different, and there could be good reasons why a jurisdiction decides to be more insular. That said, when you can share your own experience, have it questioned and debated, and then listen to the experience of others, you naturally become better informed and build the evidence base to push forward in your own market.

SP: The issue of international collaboration and cross border information sharing has been discussed here at numerous sessions particularly when it comes to enforcement. How do you see this developing with jurisdictions sharing information and acting together to drive out illegal gambling?

BH: People would probably be surprised at how much information is already shared between regulators. It’s not something that surfaces very often in public discourse, but I know, for example, that different jurisdictions have been signing MOUs with each other this week. And these MOUs are starting to look very different from those that were signed, say, five years ago. One area concerns the potential to share information where a bad actor is in one regulator’s jurisdiction. They can ask a question of another and then start collectively to bring more influence to bear on that actor. But I think regulators are far better informed now, from the point of view of enforcement than they were two years ago. It’s the kind of activity that goes unseen. There has yet to be a landmark case where this type of information sharing has materially come to light such that people would think more about it. However, considerable dialogue has been going on between regulators.

SP: MOUs are the formal and legal ways that we record ways of communicating and exchanging information, but what is realistically possible outside MOUs?

BH: You need to be careful about what information is shared, because clearly it has commercial impacts on the companies you have licensed. So there needs to be a framework in place to make that happen in the right and proper way, particularly if you’re in an investigatory process. Like any other regulatory process, it will refine and becomesmarter over time. If we were having this conversation in three or four years, maybe the sharing of data would be as significant as the verbal conversations between regulators are today.

SP: You’re about to go into your second year as IAGR president. Do you have a vision for the role IAGR can play in terms of setting the agenda for industry regulation?

BH: First and foremost, IAGR is a conduit for engagement. We’ve got over 60 different countries here this week. We provide a platform for them to engage, either to listen or to discuss and meet, and there’s clearly an appetite for that. Our role is to respond to what our members are interested in. So it’s not me or the IAGR Board saying, ‘This is what you should be interested in’. We should reflect what our members tell us in terms of putting together our programs of work. When we put a call out for papers to be presented at an event like our annual conference, we clearly see what people are interested in. That’s why there is a big focus on data and AI this year, and that’s why there is a big focus on illegal gambling. And to the extent that people are engaging as we’ve seen this week, it feels like we’re fulfilling our role.

SP: Looking forward, what opportunities do you see for IAGR to continue to evolve and become more representative of the industry worldwide?

BH: In terms of our membership, that continues to grow. Like many organizations, we had a dip during COVID, but since then, we’ve recovered and are growing again. Clearly, there are lots of opportunities, because new jurisdictions are coming online in terms of regulated gaming all the time. It’s surprising how many people contact us before or as part of their development, because they want those connections. They want to know who to talk to about a particular aspect. For me, the best thing about the new jurisdictions opening up is that they are able to borrow ideas from around the world. If you look at Ontario, for example, it’s gone out far and wide and thought really hard about what sort of framework it wants. Then, it’s taken some of those aspects and molded it to its own specific outcomes.. Every time someone new comes online, it takes that learning on a step. It’s been really interesting to watch the debate and discussion that’s been going on in Brazil and how the market is evolving there. No doubt we’ll learn a lot from that over the next 12 months.

I’m also really looking forward to some of the outcomes of our working groups, particularly around illegal gambling. We had 30 different jurisdictions sign up for that group in the space of a week so there’s clearly interest. It’s one of those areas where collectively, as a group, we must be able to make more progress than we can manage on our own. So I’m really looking forward to the outputs of that work.

SP: How do you reflect on the partnership with IMGL? What do the two organizations bring to each other?

BH: As an organization, we’ve started to engage more outside of our own conference framework, and it’s part of the reason that we’re collaborating with IMGL on this event. IMGL’s involvement brings exposure to the supply chain of the gambling industry which is shifting all the time. I think we’ve benefited from the perspective of IMGL colleagues. We’re keen to be more in that space so I’m sure we’ll continue to collaborate with different parts of the industry ecosystem. When we do we learn more and hopefully others learn more at the same time.

Every conference you do comes withrisk. You’re never quite sure how it will end up. You hope that your experience will ensure that you deliver something that’s meaningful. If we had done the program for this week on our own, it would have looked very different from the program we’ve delivered. That’s the benefit of engagement and discussion with IMGL colleagues; we have a stronger program that reflects the breadth of the ecosystem that we’re in. It’s made it much more rounded.