This article is an opinion piece by David Lyons, Non-Executive Director at SolutionsHub and a senior gaming industry executive with experience across operations, player engagement and governance.
A number of years ago, I spent a nice evening at Shelbourne Greyhound Stadium in Dublin with my twins, watching them place bets on the tote. It was perfectly legal at the time as long as there was adult supervision. We had a great evening, but I still remember thinking that children’s presence was questionable in what was, first and foremost, a betting environment.
Can children be around adults who are betting? Yes. Should children be in a place that is primarily for betting? No.
The rules around gambling have moved on considerably since those days, and Ireland is changing them again. The Gambling Regulatory Authority of Ireland (GRAI) is putting much more weight on protecting people from gambling harm, especially children and vulnerable customers. This is no simple task, but the planned National Gambling Exclusion Register and mandatory KYC checks are a good first step.
Spotting risk is only the first step
The hard part comes when a customer’s behaviour starts to change, where they manifest a hitherto unknown impulse control problem, perhaps due to some comorbid vulnerability such as a financial issue, a mental health issue, or general stress and anxiety. This presents a challenge for gambling operators who want to identify and act on these changes proactively to protect the human being behind the account.
A change in behaviour does not automatically mean somebody needs to step in. Hair-trigger sanctioning or blocking players will have the unintended consequence of driving a player to create an account elsewhere, perhaps with a less scrupulous operator. This can protect the operator, but not the individual.
Changes in transaction patterns (whether financial or play) can be identified quickly. AI tools can help provide operators with a more sophisticated trigger that someone’s behaviour has changed and intervention may be warranted. What the system cannot tell you on its own is what that change means for the person behind the account.
The alert is only the start. With more sophisticated player management systems and alerting available today, the person reviewing the account can have enough context to see whether this is really unusual for that player. If it starts to look more serious, somebody with the authority to act needs to see it quickly.
Whatever the operator decides, write down why. Somebody coming back to the file months later should be able to follow what happened without guessing, understand the operator’s decision-making process, and assess whether the judgement was reasonable at the time, whatever the outcome.
A complaint or regulatory check can bring that decision back months later. The file then needs to show what the operator knew and why it responded as it did. That record is useful later too. It can show where staff need more guidance or where the process itself needs changing.
Why context matters in player protection
In my earliest days in online poker, I worked in payments, and it was clear that the simple act of switching to a different payment instrument was a valuable risk trigger. At the time, over 90 percent of players used a single instrument, usually a specific card. A player who typically deposited using a primary funding method like a debit card or wallet, and then switched to a credit card, or, more problematically, a business debit or credit card, gave us an easy trigger to define automatically. That alert could then be handed to a human for further review, since it could indicate a number of elevated risk scenarios, including a move towards financially irresponsible gameplay.
I remember a specific instance in 2008 of a player from Belgium spending over 70,000 Euro in a single night, significantly higher than in previous weeks. At the time, our fear was threefold: (a) had the player’s account been taken over by someone else, (b) had the player spiralled into chasing their losses, and — I’m now a little ashamed to admit — (c) we worried buyers remorse would turn these deposits into chargebacks. The solution was multilayered. Did the player’s gameplay telemetry tell us it was really him and not a fraudster? It did, thankfully. He was playing the games he normally played, just at higher stakes and across more tables at once. First fear abated. Then a simple email to the player, checking in. He replied quickly, as it turned out he had won a substantial amount of money at a live poker event, which we could verify with a quick forum search, and was taking a shot with it. To a non-poker player, perhaps a terrifying story, but to the player, and to us, a relief.
Operators rarely have a complete picture of a player. A change in behaviour may be obvious, or it may take time to understand what is really happening. That operator chose to employ only poker enthusiasts across every team, even payments, which helped staff take a holistic, human view of risks like this.
But one thing hasn’t changed: the triggers still need to happen, the escalations still need to happen, and judgement calls need to be made rapidly, based on the information available at the time. If more becomes clear later, the operator may need to act differently.
Player protection has to allow for that. You cannot write one answer for every person. The toughest calls are often deciding what to do first. Do you stop deposits straight away? Pause the account while somebody looks into it? Or leave some services open while you work out what is really going on?
Take a player who hits a jackpot and then goes on a losing streak afterwards: do you “save them from themselves” by restricting further deposits or betting while you assess whether their judgement is impaired? Gambling is often an impulsive activity, but impulse is a continuum, with entertainment and excitement at one end and compulsive behaviour at the other.
Do you sanction first and review later, or put the account on hold while the review is being made? There’s no right answer here because each option has its downsides.
The options might be written down perfectly well. You still have to decide whether this particular player, at this particular time, needs somebody to step in.
And if they do, you need to know soon enough to do something about it.
My children and I will no doubt return to the track, and learn about overrounds, handicaps, and pari-mutuel betting, and we will also have an honest conversation about the importance of protecting themselves and others in the pursuit of fun and entertainment, but not until they are of age.
The views expressed are those of the author and do not necessarily reflect the views of the SiGMA News editorial team.