DIGITAL PAYMENT SYSTEMS WITHIN GAMBLING VENUES OFFER IMPORTANT HARM-MINIMISATION OPPORTUNITIES - SALLY GAINSBURY AND ALEX BLASZCYNSKI

DIGITAL PAYMENT SYSTEMS WITHIN GAMBLING VENUES OFFER IMPORTANT HARM-MINIMISATION OPPORTUNITIES - SALLY GAINSBURY AND ALEX BLASZCYNSKI

By IAGR Media

For years gambling venues have predominately been cash-based; however, COVID-19 has accelerated the move away from bank notes and placed demand on the industry to expedite the creation and implementation of digital payment systems. Due to their virtual and intangible nature, digital payments may reduce the perceived importance of money spent on gambling and online bank transfers offer little to no friction or delays which may increase spend beyond intended and affordable levels by some gamblers. Nonetheless, digital payment technologies offer important harm-minimisation opportunities, which if harnessed and regulated, may enhance consumer protection capabilities.  

Cash has been king of the gambling venue for decades, but the dark undercurrent of criminal activities such as money laundering as well as consumer preferences for digital payments has meant that cashless options will be required within the coming years. Internationally, by 2023 digital wallets on mobile devices are expected to be the dominate point-of-sale payment method. Digital payments and services such as ATM machines allow for instantaneous funds transfers without consideration or delay and there is also research available indicating that electronic payments contribute to excessive online gambling problems due to ease of funds access. It is known that digital payments are prohibited for some land-based gambling venues by regulators in many international jurisdictions, however, with an increasing proportion of consumers simply no longer using cash, regulators are now facing the challenge of how to enable digital payment systems in a way which will uphold harm-minimisation standards. 

The ‘pain of payment’ is an important factor to harness when trying to curb excessive gambling expenditure. Handing over ‘cold, hard cash’ after withdrawing from the bank or ATM machine and then viewing a bank balance can have a salient impact on gamblers. By limiting what gamblers physically carry with them serves a physical reminder when their funds are gone. Obtaining additional cash requires taking a break from gambling, interacting with venue employees, usually walking some distance perhaps off the gaming floor, and engaging with a banking interface – all opportunities to reflect on the decision to obtain further funds to gamble. However, cash is problematic from a regulatory perspective as it does not allow expenditure to be tracked to any specific individual and efforts to limit funds such as ATM withdrawals are easily circumvented.  

Digital payments can be tracked and traced, which makes them incredibly important for identifying risky gambling and providing personalized interventions. There are many different systems and processes which could be implemented including establishment of an e-wallet for gambling or direct transfers from accounts to gambling activities. An e-wallet system has several advantages; it requires customer identification verification, thus prohibiting play by minors and self-excluded customers, and tracks all gambling expenditure, which can be shown to customers using a clear activity statements with summaries of wins and losses over time and notifications to indicate risky behaviours with suggested actions. E-wallets can have limits on spend, enforce a delay between deposits and spend, and make automatic withdrawals of large wins to avoid re-gambling. Aggregated data from e-wallets would allow identification of risk indicators, allowing personalized notifications and interventions and regulators can use the aggregated data to see real-time gambling behaviours, thus enabling much more effective evaluation of policies and practices.  

Several operators are developing digital payment systems and trials are underway in multiple jurisdictions across the world. However, there is a low evidence-base to inform policy direction, particularly regarding how to implement a harm-minimisation framework that offsets the additional risks introduced. There is little understanding of how digital payments impact gambling behaviour, the extent to which consumers use digital payments compared to cash to track and manage their gambling spend, and whether specific consumer cohorts are at greater risk of gambling excessively with digital payments. Further research is needed to inform optimal harm-minimisation policies such as the extent of delay between deposits and spend to offset impulsive gambling or loss chasing, how to provide customers with feedback on their gambling to promote sustainable play, and encourage customers to set appropriate limits based on their own discretionary budget.  

Collaboration between industry including gambling, technology, and payment providers, government, and researchers is important to develop an evidence base to inform policy which should aim to minimisegambling harms and take advantage of the opportunities digital payments bring. Applying the principles outlined will address the risk that digital payments will lead to impulsive access to additional funds and problematic gambling. 

This article is based on a peer-reviewed publication: Gainsbury, S. M., & Blaszczynski, A. (2020). Digital gambling payment methods: Harm minimisation policy considerations. Gaming Law Review. https://doi.org/10.1089/glr2.2020.0015 

Please contact sally.gainsbury@sydney.edu.au for a copy and more information about ongoing research on this topic

Harm-minimisation principles to guide regulation of digital payments within gambling venues

  • The use of digital transactions should incorporate mandatory age verification requirements. Digital payment facilities must be restricted to adults aged 18 (19 or 21 years subject to its jurisdiction), and account holders must be verified using accepted identification documents. 
  • All deposits to an account should require a set waiting delay period before they can be used for gambling. This is essential to avoid immediate access to funds to continue to gamble when in an emotionally volatile state. 
  • There should be default limits on the maximum that can be transferred to an account at any time. There should be no limits on the amount which can be withdrawn from an account or delays in withdrawals being processed. 
  • It must not be possible to access cash from accounts within venues, which may be used as a way to overcome limits on ATM and cash-withdrawal facilities.  
  • Accounts must be linked to a central self-exclusion registry which apply across venues. The use of digital payments should allow for easier real time identification/detection and suspension of individuals breaching self-exclusion agreements.
  • Customers must be able to set customisable limits on time and money spent over a week/month in real time and should be encouraged and ideally incentivised to use these. Applications to increase limits should be subject to appropriate delays per time period while reductions of limits should be implemented immediately. Individuals should be able to set temporary time-outs, implemented immediately.
  • There should be made available through financial institutional facilities the capacity for individuals to set money limits. To minimise impulsive gambling, digital facilities can be set at default maximum limits in gambling venues as is currently the case for in-venue ATM and cash withdrawals. Increases in limits should be approved by financial institutions as is currently the case for credit and debit card withdrawals.
  • All digital transactions should be recorded and summarised in player activity statements that are provided in real-time including clear graphic displays of net wins and losses. If external accounts are used, the merchant code category should be linked to expenditure and financial institutions should be encouraged to provide clear summaries of all funds spent on gambling.
  • Digital payments linked to an account allows for real time tracking for risk indicators and systems have the capacity to send personalised messages via SMS to mobile devices, directly to electronic gaming machine screens, to venue staff notified to initiate interactions with players, or to an individual nominated by the customer. 

Gainsbury, S. M., & Blaszczynski, A. (2020). Digital gambling payment methods: Harm minimisation policy considerations. Gaming Law Review. https://doi.org/10.1089/glr2.2020.0015


Associate Professor Sally Gainsbury is Director of the University of Sydney Gambling Treatment and Research Clinic and Alex Blaszczynski is Emeritus Professor in the University of Sydney School of Psychology

The Gambling Treatment and Research Clinic is Australia’s only university-affiliated gambling treatment clinic and has been operating for over 20 years. Our aim is to use knowledge gained from the nexus of conducting world leading research and treatment to shape policies and practices to minimize gambling-related harms. Our research focuses on understanding gambling behaviours, products, and environments to determine how problems develop to inform the development of interventions to prevent harms and provide clinical interventions. Our research focuses on optimizing emerging technologies to prevent harms while identifying and minimizing unique risks.

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