How Playtech’s compliance department is using tech and collaboration to shape a compliance-centric business model

As one of the biggest players in the online casino space, Playtech is a name that is ubiquitous in many of the world’s biggest gambling markets. Playtech has over 30 individual licences in both B2B and B2C covering almost every regulated market, apart from the US (the company expects to close that gap in the next few months). As a B2B service provider within these jurisdictions, the company provides support to its licensee partners as they look to enter these regulated markets.

The compliance function within Playtech encompasses several departments, including regulatory affairs, compliance, anti-money laundering, bribery and corruption, GDPR and the BetBuddy compliance technology arm. This encompasses 26 staff members spread over four different offices, all reporting to Playtech’s global head of regulatory compliance, Ian Ince.

So, what does this involve on a day-to-day basis? As Ince explains, at any point in time the company is monitoring between 50 and 80 different jurisdictions. “Each of my compliance managers has a raft of jurisdictions they monitor, which is usually a mix between what I call hot and cold markets,” he said. When asked for examples of hot and cold jurisdictions, Ince highlights Denmark as a cold jurisdiction as it has endured little regulatory change and the UK as a hot jurisdiction “which is constantly evolving and changing and throwing out its own challenges and requires a huge amount of graft”.

Aside from the monitoring of jurisdictions, members of Playtech’s compliance department work extensively with operators, regulators, and governments as well as actively lobbying in jurisdictions. Staff also support licensees with compliance queries and Playtech’s own internal teams with product support, assisting in the delivery of new products to existing markets.

“Our final duties are in the areas of maintenance and our licence audits. We have ISO audits ongoing with security. We have an audit with all our regulators on a frequent basis and then maintaining the relationship with the regulators. And that was just Monday,” Ince adds.

Ian Ince, Playtech

Practising what you preach

But it’s one thing to say you are actively engaged in compliance activities and another to have a business which carries compliance as its central focus. Ince believes that any operator which doesn’t take compliance seriously is “a fool”, particularly in respect of regulated markets. Qualifying this assertion, Ince explains that as global director of regulatory compliance, he enjoys the full support and engagement of the Playtech board. “I’m a guest to the board meetings and I attend every board meeting.

“I’m lucky that the chairman sits about 30 paces away from me and I speak to him almost daily. I have regular interactions with our entire board, both at the board meetings and informally in a business environment,” Ince adds.

Indeed, Ince boldly states he can effectively operate with a blank cheque from Playtech chair Mor Weizer. “He has never said no to me on a compliance matter. If I said an Aston Martin was crucial to our compliance, he would probably get me one,” Ince jokes.

Aside from the hyperbole, Playtech is a business which is heavily exposed across several markets, each with its own regulatory standards and issues so maintaining a consistent philosophy could be difficult. Ince believes the central tenet of Playtech’s approach is doing the right thing and not making compliance a tick box exercise. “It’s about being a proactive compliance department, engaging both with our licensees and regulators on a proactive basis. But also, a huge focus on collaboration, again with regulators and all licensees and we’re in constant dialogue with all our licensees.”

Stressing the importance of collaboration, Ince says he and other members of the compliance department regularly hold meetings with their counterparts at Playtech licensees, together with the RGA and Senet Group.

Ensuring everyone sings from the same hymn sheet when it comes to compliance is an important aspect of the work Playtech does and this is a philosophy that extends into its training of staff members. However, it’s not been an overnight thing and one of the big challenges of Ince’s role over the last few years “is moving compliance to the very centre of Playtech’s offering, something which I believe I’ve achieved with the support of my team and a lot of assistance across the board”.

Sailing in the same direction

Another aspect of this, and something which is very much centred in the top down approach to management of the firm, are the information days, which provide information to staff about the business. “At the investor days, compliance is always there now. We do e-learning anyway as it’s an LCCP requirement, but we also do face-to-face training,” Ince adds.

Expanding on the process involved in face-to-face training, he reveals that representatives from Playtech’s compliance department visit 11 of the firm’s 17 offices, conducting with almost 10% of the entire company workforce (about 600 people in total).

Ince is also keen to extol the virtues of the Playtech Academy, something which the company already uses with its own employees but is planning to roll out with its licensee partners later this year, with a view to extending it to the wider industry. In addition to this, the company has taken steps to ensure that any employee who does not complete the compliance training will not receive a bonus or pay rise within the year.

But Playtech isn’t all about enforcing compliance among its employees with an iron fist, indeed a central part of this for Ince is making compliance fun. One facet is the development of a cartoon-led compliance card game that Playtech has developed with an external graphics company to explain the company’s stance on compliance. This game whittles down all the relevant policies and procedures into bite-sized forms, putting them into a cartoon format. “These cartoons and indeed the training can be individually tailored to include specific themes, character names and compliance problems endemic to a specific jurisdiction and are interchangeable.”

As a business, Playtech cites four chief values at the core of its business offering: integrity, innovation, excellence and performance. Ince believes that far from being just nice slogans, these values are at the core of the company’s ethos. “It might sound a bit cliched but integrity is a no brainer. Innovation and excellence? Yeah, damn right. I think we’re one of the leading compliance departments in the industry,” Ince adds.

Leading the charge

Having a leading compliance department for Ince comes back to one of Playtech’s core aims, that of doing the right thing regardless of the financial impact to your business. In the UK this is about going above and beyond the UKGC’s licensing codes of practice because it makes “good commercial sense” and includes things like working with charities, using its own data to bring to bear issues relating to gambling.

Expanding on this, Ince highlights several events organised and funded by Playtech where problem gamblers are brought into contact with individuals from the industry, not just from Playtech but from GVC, Hills and other firms. Feeding into the doing the right thing, regardless of the cost philosophy, the objective of these events is collaboration to ensure a more informed and stable industry. This is encapsulated in his summation that commercially “we will compete with them until the last, but in compliance we share with everyone”.

The biggest challenge for Playtech’s compliance department on a day-to-day basis is keeping on top of the regulatory changes that take place in the worldwide gambling market. Aside from the UK, there are regulatory pressures in all its main jurisdictions, where regulations change on an almost daily basis. “You can never rest. That’s the biggest challenge – the constantly moving environment, as soon as you say, ‘I’ve got this sorted’, you’re screwed,” Ince adds.

Aside from keeping up with regulations, Ince highlights the increasingly politicised nature of the debate around gambling, particularly in the UK. He believes it is no longer good enough to go above and beyond the LCCP objectives because the level of trust in the UK is such that even when an operator does the right thing, it is viewed with cynicism by the UK media. Ince believes that the entire UK gambling industry has become a highly politicised one, where statistics can be empirically twisted to suit any narrative, making the UK an extremely challenging market for operators.

“Ultimately, we’re not politicians. We’re into doing the right thing and when a regulator is forced to act purely based on political winds, it is quite scary from a regulatory perspective,” Ince adds.

One size fits all?

Managing these two dual challenges in one jurisdiction is a difficult thing, but times that by 24 and you get an understanding of the size of the task that faces the team. Every jurisdiction has wildly different concepts of compliance so the challenge becomes harmonising/standardising the business approach. However, as Ince explains, Playtech cannot harmonise its approach until technical and regulatory standards are brought into line. “There are lots of overlaps, in things like AML and RG, something that the UK is on the leading edge of and the things that we learn in the UK will be equally applicable in other jurisdictions,” Ince adds.

In the absence of regulatory harmonisation, Playtech has pursued its own technological harmonisation, encapsulated in the development of Playtech One and the acquisition of RG analytics company BetBuddy. Ince singles out Playtech One as a key driver of keeping compliant and an important USP for the business. As he explains: “Look at it from a compliance perspective, if you’ve got the ability to see in data terms, the wallet of guys and girls putting cash into a B2 slot machine and that given player spending and betting history is made available, it’s very powerful tool from a compliance perspective.”

A primary adjunct point in this is the transparent relationship that Playtech One has with its players, in that it gives Playtech a picture of the players gambling habits and lifestyle, something which can be used to ensure safer gambling, correct messaging and RG interaction where needed. Ince compares this to trying to espouse responsible gambling in the largely anonymous retail environment “Unless you’ve got a centralised database, facial recognition software across every single shop in your portfolio and indeed your competitors’ shops and you can link it to player spend then it’s pointless.”

“Whereas with Playtech, if you go into Gala Coral and put money into a B2C machine, it goes onto your account and we have a record. Likewise, when you go home and gamble on your device, your laptop, your mobile etc we have a record of that,” Ince adds.

Greater awareness of player gambling habits and spending by operators, while a good thing from a regulatory perspective, could also run the risk of creating an oversensitive RG culture, where gamblers playing regularly could be incorrectly identified as problem gamblers. The trick is to assist players without offending players. “No-one likes to be told, you are a problem gambler, you spend too much money. It’s about subtle messaging.”

One concept that Playtech is developing using its BetBuddy software is nudge messaging, which involves providing players with information on their so-called ‘markers of harm’ i.e. things such as playing late at night, late deposits and excessive time spent on one game. Another element of this is manoeuvring players onto less risky games through in-app messaging.

“We’re subconsciously managing you to be a responsible player without offending you, without upsetting your customer journey but it’s also doing the right thing in helping you,” Ince adds.

Forward march

Looking ahead, Ince highlights mental health as a key area of focus for the business in its efforts to remain consistently at the forefront of egaming industry compliance. He explains that there are several initiatives aimed at addressing the mental health issues related to gambling due to be unveiled by Playtech over the coming months.

However, as it expands into new areas, he believes one thing will remain constant at the core of the Playtech ethos: the desire to do the right thing. For Ince it’s about building on what the business has done already and answering critics of the business in the media.

“We’ve got BetBuddy, we’re constantly looking at our game design process to see how we can be more responsible, using things like the chilli rating system for game volatility and we’re constantly taking things to the next step and so on,” Ince adds.

However, Ince remains far less optimistic about the wider regulatory environment, predicting a continuance of the current increased regulation in the future. “I’d like to think it would reach a peak and fade away, but I think unless something dramatic happens it won’t. For me I hope we’ll see the industry turn a corner, what I’d like to see is trust coming back to the industry,” he adds.