European Gaming Lawyer magazine EGL_Spring2017_opt | Page 16
Skin Gambling –
A case for regulation in Malta
by Alistair Facciol
B
eing a relatively recent
development within the gaming
and gambling industry, there are
elements within the concept of
skin gambling which require the
attention of regulators, operators and consumers alike.
This article seeks to discuss the constitutive elements
of skin gambling and its prevalence amongst
consumers, its place within the definition
of gambling according to Maltese law and following
this analysis, recomendations to the Malta Gaming
Authority (MGA).
What are skins?
In order to achieve a better understanding of skin
gambling, it is pertinent to begin with the origin
of the term within the gaming industry. It can be
argued that the term ‘skin gambling’ traces its origins
to Counter Strike: Global Offensive (CS:GO), an
electronic game developed by Valve Corporation
which sees two teams of players earning points by
virtually killing players from the opposing team. In
order for one team to beat its opponents, players make
use of virtual weapons such as AK47s and knives.
In order to give the game a personal aspect, players
may personalise the weapons used – for instance an
AK47 is available in customary black, but players
may also spice up their AK47s by making use of a
‘skin’ to have a camouflaged weapon available for use
during the game. Skins are cosmetic items that can
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| European Gaming Lawyer | Spring Issue | 2017
be used in electronic games such as CS:GO, having
the sole aim of altering the aesthetic appearance of a
player’s in-game weapon, gear or avatar. It is worth
mentioning that a skin does not improve the power
or functionality of an in-game weapon but merely
changes its aesthetic appearance.
There are various ways for players to acquire
these skins. In CS:GO, players are awarded skins
in-game whilst playing or through promotional
events. They can also trade skins with other players
through ‘Steam’, an online platform operated by Valve
Corporation, third party platforms or purchase skins
through available online marketplaces. The rarer a
particular skin is, the more valuable it is.
Another way in which players may acquire these
skins is by purchasing keys to unlock cases which
contain a quantity of various skins as a prize. This
model could be compared to casino slot machines
since the game involves the purchasing of a key for
the opportunity to win a number of skins as a prize.
Acquired CS:GO skins are added to the player’s
inventory on the Steam account.
Skin Gambling
Like a casino chip, a skin can serve as a de-facto
virtual currency which can be used for gambling
purposes. Players may make use of skins acquired in
one of the above mentioned methods to bet and place
wagers and gamble. Several products allowing skin
gambling are available, including roulette, sportsbook