European Gaming Lawyer magazine Spring 2014 | Page 24
International Pooling Networks:
What are the regulatory issues?
By André Wilsenach, Executive Director, Alderney Gambling Control Commission
André Wilsenach
Background
Network or business-to-business (“B2B”) gaming is
an established form of remote gambling that pools
the customers from different business-to-customer
(“B2C”) operators to play against each other on one
B2B network. It is generally used in peer-to-peer or
community gambling such as poker or bingo, but can
also be used to pool rake from player bets against the
house in order to build progressive jackpots, in effect,
a significantly greater jackpot than any one operator
can offer alone.
Peer-to-peer gambling requires high volume
player participation and financial liquidity in order
to operate successfully and many B2C operators will
therefore rely on arrangements with a B2B network as
they have insufficient liquidity as stand-alone entities.
The recent concept of international pooling operates
along the same lines as existing network gaming,
but with the added distinction of pooling players
from different jurisdictions onto a single gaming
platform. Currently there is a presumption against this
happening and although some national regulations
may allow cross-jurisdictional pooling in theory, there
is a lack of international standards and regulatory co-
24 | European Gaming Lawyer | Spring Issue | 2014
operation to provide operators with the certainty they
need to invest in international pooling networks to tap
into this prospective international market.
Operators are increasingly looking to
regulators to come up with a solution that will
provide a secure framework to enable investment
in international pooling.
This paper proposes a solution to remove the
regulatory uncertainty for those operators who wish
to participate in international pooling networks
and who are keen to adhere to the very highest
international standards set by those regulators who
are interested in regulating this business.
Why is there a need for international pooling?
Operators have long recognised that the key to
growing the overall size of the market in relatively
mature regulated gambling environments is the ability
to introduce high levels of liquidity into the market,
which creates a network effect that is greater than
the sum of the parts. There is also player demand to
increase the breadth of skill of players in peer-to-peer
or community forms of gambling such as poker by
allowing players from different jurisdictions to play