Internet Gambling Self-Exclusion in the EU...and Australia?

Last week the European Parliament passed a resolution concerning the regulation of online gambling. According to this article at TimesofMalta.com, the Parliament recommends that the EU adopt an internet gambling self-exclusion system through which a gambler could exclude from all EU-state-licensed sites with one application. Further, each gambler could establish system-wide money and time limits, so that reaching the self-imposed money limit on one site could not be avoided just by going to a competing EU internet gambling provider.

Incidentally, Australia is contemplating legalizing internet gambling, and in establishing a national web gambling self-exclusion system. A second proposal is to require internet gambling sites to notify gamblers when their betting behavior is suggestive of problem gambling. Australia's new prime minister, Tony Abbott, has indicated that he does not support the previous government's efforts to make self-limitation mandatory for Electronic Gaming Machine play.

Australia, Singapore, Britain Self-Exclusion Updates

(1) Australia continues to develop its program to allow gamblers to self-exclude from many venues simultaneously. They can choose whether to ban themselves from the entire club premises, or those parts of clubs where any gambling takes place, or only the rooms where pokie machines operate. (Self-Exclusion first noted this ongoing process some months ago.) The program was trialled in March, and expanded in New South Wales a couple months later. Australia is not immune from the common problem that the enforcement of self-exclusion agreements is spotty: some excluded patrons manage to gamble in violation of their agreements.

(2) Singapore is thinking of enhancing its problem gambling protections for citizens and permanent residents. "Under the proposed new regulation, any Singaporean (and [permanent resident]) who visits the casino more than five times in a given a month is considered a “high frequency” gambler. It may compel him to show that he is not in financial distress before being allowed to visit it the sixth time." (Casino visits are tracked in the Netherlands, too, and frequent gamblers are approached by staff to help assess the possibility of self-control issues and impose visit limits (see 35-page pdf here).) The linked article also notes that despite hosting only two casinos ("Integrated Resorts"), Singapore gambling revenues exceed those of Las Vegas, trailing only Macau on that metric. Singaporean locals have to pay a per-visit casino entrance fee of about $80, or purchase an annual casino pass for approximately $1600.

(3) The manifold shortcomings of the enforcement of self-exclusion in Britain are noted in this article. A bounty system for staff who identify a self-excluded gambler might be one element of improved enforcement.

Ohio Casino Self-Exclusion Kicks Off...

...and it has its first client: "He has proudly framed his letter from the commission notifying him that he’s barred from the casinos. He keeps it next to a photo of his deceased father, who had urged him to stop gambling." He has remained bet-free for more than 500 days.

The Ohio program allows gamblers to exclude for one year, five years, or for life. People who violate their exclusion order are subject to arrest and the loss of any winnings. When an exclusion order serves its time and expires, the reinstatement of gambling privileges requires that the gambler take the positive step of filling out a form to request reinstatement -- the default is continued exclusion. Sounds to me like Ohio has a good set of self-exclusion regulations.

The linked article indicates that Caesars Entertainment, which is operating the just-opened Cleveland casino, offers its own self-restriction program, along with self-exclusion. Self-restriction prevents the gambler from receiving marketing materials, and enjoins the casino from offering services such as credit or cashing checks to restricted customers. It appears that restrictees can choose more constraining rules, too.

Aussie Pokies Controversy Boosts Self-Limitation and Self-Exclusion

We noted last month how the push for mandatory betting limits in Australia was, perhaps inadvertently, promoting enhanced self-exclusion as a sort of compromise from opponents of the mandatory limits. Voluntary self-limitation is another policy that is garnering support:

Australia's biggest pokies operator Woolworths has lobbied the federal opposition to tackle problem gambling with voluntary pre-commitment measures, despite the limited success of its own trial of optional bet limit cards....At last year's Woolworths annual general meeting, it was revealed only 11 per cent of registered players had taken up an offer of voluntary cards under the ALH trial, which started in 2009.

Eleven percent seems fairly significant to me. Meanwhile, in New South Wales, the potential to self-exclude from multiple venues, and to do so over the internet, also is being introduced:

WITH just the click of a button, problem gamblers living anywhere in NSW will be able to use a secure website to ban themselves from their local clubs....The technology allows problem gamblers to complete a legally binding self exclusion document in the presence of a gambling counsellor or a trained facilitator at their local club. Previously the individual had to visit each club individually.

Additionally, the problem gambler can now choose to ban themselves from multiple clubs rather than the time consuming process of visiting each venue and repeating the process time and again. Problem gamblers are provided with the following self-exclusion options: banning from the club, banning from any area of the club with poker machines and banning from any area of the club where gambling takes place such as poker machines, Keno and ClubTAB.

The internet sign-up is probably an upgrade over an earlier, unfortunate suggestion from Victoria, Australia, that those seeking to self-exclude call a hotline that, uh, promotes betting.

Self-Exclusion as a Substitute for Mandatory Limits?

The Australian government is attempting to require that all players of "pokies" (electronic gaming machines) at clubs and pubs choose an expenditure limit. When they hit that limit, the players would have to wait (24 hours?) before they could resume gambling. The Australian loyal opposition is looking into alternative measures, including a national self-exclusion system. Perhaps more controversial is the possibility of third-party or family exclusions, where someone can be barred from gambling following an application not from the gambler him or herself, but from a close family member. Of course, family exclusions already exist in Singapore -- and in Australia! Another measure that the opposition is considering is to remove ATM access at gambling locales for would-be punters on the exclusion list. The inquiry by the Australian opposition is slated to be completed by the end of the month.

Mandatory Gambling Limits in Australia?

Electronic gaming machines in Australia are slated to be retrofitted with card readers or other devices that will be able to keep track of a player's wagers. The idea is to enforce limits to gambling -- and it will be mandatory for gamblers to pre-specify those limits, at least if the central government gets its way. The proposal is meeting significant opposition, with pubs, clubs, and hotels that host gaming machines involved in the backlash. One of the animating developments behind the "mandatory pre-commitment" movement is the 2010 Productivity Commission report on gambling that (once again) showed the extent to which profits drawn from electronic gaming machines come from problem gamblers. From Chapter 5 (pdf here) of the report:

"Based on available survey data, there are between 80 000 and 160 000 Australian adults suffering significant problems from their gambling (0.5 to 1.0 per cent of adults), with a further 230 000 to 350 000 experiencing moderate risks that may make them vulnerable to problem gambling (1.4 to 2.1 per cent of adults).

Although there are substantial difficulties in calculating gambling expenditure, it is estimated that problem gamblers account for 22 to 60 per cent of total gaming machine spending (average of 41). The likely range for moderate risk and problem gamblers together is 42 to 75 per cent."

eCOGRA's Safe and Fair Seal Requires Exclusion Options

Internet gambling seems to combine two area of human activity that display more than their share of less-than-trustworthy behavior. Someone interested in placing a bet online could be scared off over the uncertainty surrounding the integrity of the transaction offered by an internet betting shop or casino.

The internet gambling industry recognized their credibility problem at an early stage. One response that they adopted is a form of self-regulation. This response involves a sort of Good Housekeeping seal of approval, and one non-profit, independent (of the online betting shops) organization that awards the e-gambling seals is eCOGRA. To qualify for the right to display a "Safe and Fair" seal, internet gambling providers must meet a host of requirements concerning player protection, fair gaming, and responsible conduct. The detailed guidelines can be found here (49-page pdf). More than 100 e-casinos, internet poker rooms, and e-betting shops, including many of the best-known ones, currently are authorized to display the Safe and Fair seal.

Among the requirements for a Safe and Fair seal is the provision and effective communication of self-exclusion measures. A 24-hour cooling-off option must be available to players, and a six-month or longer exclusion also must be on offer. Third parties can request that a gambler be excluded -- as in Singapore's land-based casinos -- but those requests need not be honored. The guidelines also require, if I understand things correctly, that the gambling sites allow players to establish deposit limits, and to decrease those limits. Requests to increase a deposit limit that previously had been decreased cannot be honored for at least 24 hours. So both self-exclusion and self-limiting features are built into Safe and Fair e-gambling sites. Nevertheless, it does not appear to be the case that a single exclusion request will apply to multiple websites. (A system mentioned earlier had the feature of allowing a single exclusion to be implemented at multiple sites.) An e-gambler hoping to cut off access to his or her vice of choice might have a hard time maintaining enough stamina to self-exclude from dozens of e-casinos, of course.

Will Problem Gamblers Self-Limit?

Self-exclusion and self-limit programs are aimed at people who have, or fear they might have, self-control problems with wagering. Most of the people who choose to self-exclude do seem to be problem or pathological gamblers. But if you offer a voluntary self-limiting program -- say, the option of making a commitment prior to entering a casino to spend no more than $x there (where the gambler can choose x) -- will people who have gambling problems choose to participate? A recent study by Lia Nower and Alex Blaszczynski suggests that problem gamblers might not be all that eager to take part.

The study looks at 127 adults who, on their way into an Australian casino, agreed to fill out questionnaires. Based on the ensuing self-reports, 20 of these people were categorized as problem gamblers. When asked about whether they would take advantage of "smart card" technology that would allow them to limit their monetary exposure once inside the casino, the problem gamblers were less likely than everyone else to endorse the use of such cards. Further, the problem gamblers who were willing to use the cards were more likely to want the cards to be flexible, so that additional funds could be accessed during a single session or additional cards purchased. This relative reluctance to limit gambling losses is indicated despite the fact that problem gamblers also were the most likely to lose track of their monetary situation (money won or lost) during a gambling session.

Many gamblers who self-exclude do so only after wagering has wreaked havoc upon their lives. Does a lack of sophistication by problem gamblers about their own future self-control issues suggest the desirability of a mandatory regime of limit setting, such as that maintained at Svenska Spel's internet poker facility?

Self-Limits in Internet Gambling

Responsible internet casinos follow the lead of their terrestrial counterparts by offering a self-exclusion option -- and many of the programs are tied together, so that one application results in exclusion from myriad gambling sites. Furthermore, options for partial exclusions also can be made available -- as with Sweden's Svenska Spel.

In 2008, addiction researchers published an article that looked at the behavior of internet gamblers who took advantage of a self-limiting option. (The article grew out of an ongoing research collaboration between web gaming company bwin and the Division on Addictions associated with Harvard Medical School.) Daily (1000 euros) and monthly (5000 euros) deposit limits are imposed by bwin, but internet gamblers are allowed to choose lower limits. (The 1000 and 5000 euro limits were those in place at the time of the study.) At least for the sample used in the article, the vast majority of gamblers on bwin chose not to establish their own limits. Those who did self-limit, however, tended to decrease the frequency of their betting and the amount wagered. More than 10 percent of self-limiters abstained completely (from gambling with bwin) after imposing the limits; more than 7 percent imposed limits before they placed their first bet.

The authors point out that the time devoted to gambling can be as big a problem for some people as monetary losses. Self-limiting programs could invoke time constraints, on a per session, per-day, per-month (and so on) basis. (Come to think of it, something that limited my time on the internet to two hours per day might make my life better...)

Non-Zero-Tolerance

Self-exclusion orders often are limited in duration and in geographic scope, but they are otherwise categorical: an excluded person cannot gamble at all at a place from which he or she has chosen to exclude. In that sense, self-exclusion is an all-or-nothing proposition: either you can gamble under the same regime that governs everyone, or you cannot engage in gambling.

Lots of folks who fear their loss of self-control, however, might not want to renounce their vice of choice entirely. For these people, rules that allow limited indulgence, as opposed to enforcing abstinence, might be preferable to self-exclusion. Many people try to adopt and enforce such rules on their own, through two-drink limits or by only carrying a small amount of cash into a casino. But in the case of gambling, casinos can help, and sometimes they do, by offering special rules, such as voluntary credit limits or opt-outs from gambling on credit altogether. Further, the regulatory structure surrounding gambling can provide some limits, of the not-so-voluntary variety. Until recently, Missouri casinos had a loss limit of $500 per two hours, and $6000 per day (that would be a sufficiently bad day for me). To enforce the limit, every casino-goer needed to present an ID, and would be issued a boarding card. The boarding card would have to be swiped at buy-ins for table games and inserted in a reader during play at electronic games, so that the limit could be enforced. One side effect of operating with mandatory loss limits was that self-exclusion orders could be policed more easily, thanks to the ID requirement. It might be the case that the Missouri self-exclusion program is being undermined by the repeal of the loss-limit regulation.

More on self-limiting behavior in future posts, I hope.

Self-Excluded Gamblers Mistakenly Sent Promotional Material

The Missouri Gaming Commission has fined Harrah's North Kansas City $25,000 for mistakenly sending marketing materials to hundreds of people who had voluntarily signed up on Missouri's list of excluded gamblers. People on the list are denied entrance to Missouri casinos, and could even face arrest for trespassing if they do visit a casino. They are also supposed to be excluded from receiving gambling promotions in the mail, but, well, mistakes were made. The Motley Fool has the story.

From the Motley Fool article I followed the link to Harrah's webpage on responsible gaming. I learned that Harrah's itself has two categories of voluntary exclusion. The self-exclusion option keeps you out of all Harrah's casinos. But there is also a self-restriction option that precludes you from receiving promotional material, or from employing credit or check cashing privileges at any Harrah's casino. The two levels sound like a great idea to me. I wonder if someday they will allow gamblers to voluntarily set loss limits at the time that they enter a casino? (Given the card tracking of betting that is now widespread, it is technically feasible to calculate losses.) I also think that slot machines should be programmed to detect potential problem gambling, and make occasional suggestions to bettors to slow down or even to implement a slowdown through technical means.

Incidentally, the president of Harrah's is a former professor at the Harvard Business School. He co-authored a fine book on, of all things, the Polish post-socialist transition.