Sports betting profiles

Transcription

1 Sports betting profiles

2 Foreword Over the past few years, the global threats of match-fixing and sports betting integrity issues have been elevated in public awareness. We have seen some limited evidence of sport integrity corruption in Britain. However, it must be stressed that for every event where suspicions have been raised there are thousands more being competed fairly and honestly. Representatives of the betting industry, sport, law enforcement and the Gambling Commission are working together as the Sports Betting Integrity Forum (SBIF). We bring together a wealth of knowledge and experience, taking the lead on delivery of the national strategy to protect Britain s national and international reputation for being a safe place to enjoy sport and sports betting. Part of this strategy is to identify new and emerging risks. SBIF has assessed what we have in place to deal with the issues associated with match-fixing, to both identify what we are doing well and where we believe further work is required. We will continue to build on our understanding of the threats and updates to our strategy will be published on our website as we expand our knowledge and expertise. Darren Bailey The Football Association Mike O Kane Ladbrokes Joint Chairs, Sports Betting Integrity Forum 2

3 Introduction The integrity of sport is absolutely paramount and we have to do all that we can to protect it. Tracey Crouch - Parliamentary Under-Secretary for Culture, Media and Sport Based on our experiences to date, the threat of match-fixing in Britain is currently low. However, we cannot afford to be complacent; the threats present continual and significant challenges for which we must be prepared. SBIF is responsible for delivery of the Sports and Sports Betting Action Plan (the Plan), which outlines Britain s approach to addressing the risks associated with match-fixing and preserving sports betting integrity. As part of the Plan SBIF committed to undertake risk assessments of the threats from betting integrity on sport and sports betting. The Sports Betting Profiles delivers this undertaking, bringing together contributions from SBIF members to identify and assess the current threats and highlight good practice. The Profiles set out a series of recommendations, which will be incorporated into the work of SBIF as part of its strategy to deliver the Plan. It provides the story so far, outlining some of the very positive actions undertaken in Great Britain to address risks to the integrity of sport and sports betting and to protect our national and international reputation for being a safe place to enjoy both. It recognises that there is scope for additional measures that should be deployed if we are to sustain and maintain protection. SBIF also recognises the need to continually reassess the threats to ensure we keep abreast of new and emerging risks. SBIF will update Sports Betting Profiles to reflect new findings, incorporating any new recommendations into future versions. 3

4 Background Parry Report In summer 2009, the then Minister for Sport, Gerry Sutcliffe, put together a panel of experts, including key people from the betting industry, the police, players, fans, Sports Governing Bodies (SGB), the legal profession and the Gambling Commission. They explored a wide range of issues relating to sports betting integrity and were asked to make recommendations on how the various bodies concerned could work together more effectively. This formed the Report of the Sports Betting Integrity Panel, more commonly known as the Parry Report. A key recommendation of the report was the creation of the Sports Betting Intelligence Unit (SBIU) that could support SGBs and betting operators own prevention and deterrent efforts by the provision of relevant pooled intelligence. More information on the SBIU can be found later in the report. The formation of the Sports Betting Group (SBG) was another key recommendation of the report, calling for the sports sector to provide leadership through representation drawn from sport. The SBG is explored further in the report. The SBG took responsibility of the recommendation to develop a new Code of Conduct on integrity of sport. The report also recommended that each individual SGB have in place effective mechanisms to ensure compliance with its own rules, investigate potential breaches and impose sanctions. The report also highlighted the need for SGBs to have effective education programmes and intelligence systems in place in relation to sports betting integrity and capacity to respond appropriately to intelligence received from the Sports Betting Intelligence Unit (SBIU) and from betting operators. The report also addressed the importance of robust and clear collaboration between partners in the area of betting related corruption. This collaboration has now been formalised as part of the national platform to address betting corruption in Britain by the formation of the Sports Betting Integrity Forum (SBIF). Sports Betting Integrity Forum The Sports Betting Integrity Forum, originally called the Tripartite Forum, was established in 2012 to develop Britain s approach to protecting sport and sports betting being corrupted. It brings together representatives from sports governing bodies, betting operators, sport and betting trade associations, law enforcement and gambling regulation. SBIF is part of Britain s national platform to address the risks of match-fixing and threats to sports betting integrity. The purpose of SBIF is to support and coordinate partners individual and collective efforts in developing Britain s Action Plan for enhancing integrity in sport and sports betting. It keeps pace with the increasing complexities, such as international influences focusing on prevention, disruption and deterrents. This approach reflects the belief that match-fixing presents a major and continuing challenge for the governance, culture, reputation and operational capabilities of sports and sports betting operators. SBIF has already achieved a number of successful outcomes, which include: providing a platform for collaboration around effective early warning systems for the London 2012 Olympics Games improved communication between SBIF s partners organising practitioner events to share best practice and to promote collaboration between national and international stakeholders 4

5 supporting awareness raising of integrity matters through engagement with sports participants implementation of a case triage process to better manage incidents of sports betting corruption where criminality is suspected (see Appendix 1) development of a framework to promote consistency in the set of indicators betting operators use around reporting unusual or suspicious betting patterns identifying issues that need to be resolved to improve individual and collective performance across sport, betting operators, law enforcement and the Gambling Commission working in collaboration with the European Commission to raise awareness of sports integrity issues and contributing to EC policy studies. SBIF s future plans build on current achievements at an organisational and national level to: sustain SBIF to develop and implement the SBI Action Plan through both individual activities and coordinated responses to joint issues take action at partner levels, focusing upon developing preventative measures within sports and betting operators organisations to raise awareness of the threats, promote a culture of resistance provide facilities to enable those that wish to provide information be information led, having effective exchange arrangements that operate between public authorities and private organisations promote sports and betting operators governance arrangements and cultures that produce effective risk management strategies establish complementary and effective disciplinary frameworks within sports governing bodies (SGBs) and betting operators, that are capable of being enacted concurrently with gambling regulation and criminal justice action contribute to, and learning from, international developments and operational collaborations coordinate national policy development in international contexts. Sports Betting Integrity Action Plan The Sports Betting Integrity Action Plan (SBI Action Plan) outlines Britain s approach to address risks of corruption to the integrity of sport, and sports betting and to protect the national and international reputation for being a safe place to enjoy both. The unfair manipulation of sport events or betting markets is often referred to as match-fixing. The plan sets out the focus of agencies, SGBs, player associations, betting operators and government in delivering timely and effective actions to identify and control risks associated with match-fixing. The plan builds upon the progress made since the publication of the Report of the Sports Betting Integrity Panel and progresses Action 31 of the UK Anti- Corruption Plan, published in October The purpose of the SBI Action Plan is to put in place a framework of actions to: a. prevent sporting events and licensed sporting betting markets from being corrupted b. deter persons from organising corrupt sports events or unfairly manipulating betting markets

6 The plan recognises the need for key stakeholders to plan for and act within their areas of responsibility, support others where appropriate and work in unison as part of the broader national platform that is the basis of the strategic approach. A crucial aspect of this approach is the culture of cooperation and coordinated actions which is reflected in the approach of SBIF, which has responsibility for implementing the SBI Action Plan. It is recognised that the threat of match-fixing, whilst currently low, presents a continual challenge for the leadership and culture of sports, and sports betting to identify and implement concrete actions to prevent and deter match-fixing. This requires longer term commitment to the development of competencies and approaches. The Sports Betting Group The Sports Betting Group (SBG) was formed in 2010 following the publication of the Report of the Sports Betting Integrity Panel. One specific recommendation in the report called for the sports sector itself to provide leadership through the establishment of a Sports Betting Group made up of people drawn from sport. Purpose of the Sports Betting Group: Provide help, guidance and support to sports bodies in relation to sports betting integrity. Communicate to sports bodies the importance of protecting themselves from the threats posed to integrity by betting. Make regular assessments of the extent to which governing bodies have taken steps to effectively protect themselves from these threats. Communicate and engage with Government and the Department for Culture, Media and Sport and other relevant parties as appropriate (including the Gambling Commission and the betting industry) in order to recommend improvements to the legislative and regulatory regimes that protect sport from the impact of match-fixing and corruption and all related issues. Organisation: The SBG serves as the advisory resource for all work undertaken by the affected sports bodies on betting integrity. The SBG holds regular meetings to co-ordinate its work. Members of the SBG represent the group on other working groups related to betting integrity (eg the Sports Betting Integrity Forum). The SBG is co-ordinated by a secretariat with responsibility for arranging meetings and disseminating communications as appropriate. The current members of the Sports Betting Group include representatives from the organisations listed below and also independent consultants: British Horseracing Authority England and Wales Cricket Board Football Association Greyhound Board of Great Britain Lawn Tennis Association Premier League Professional Footballers' Association and Professional Players Federation Rugby Football League Rugby Football Union Sport and Recreation Alliance (Chair and Secretariat) World Darts 6

7 World Snooker The membership of SBG is kept under review and, through its engagement with a range of sports to raise awareness around integrity issues, the group would consider inviting additional sports to become members as appropriate. Gambling associations Association of British Bookmakers (ABB) The ABB is the trade association for high street betting shops. Their members range from public quoted companies to independent family run businesses. Between them, they represent 80% of the market, which employs over 40,000 people, serve eight million people and contribute over 3bn to the British economy. The ABB are committed to putting responsible gambling at the heart of all they do, and all members adhere to the ABB s Code for Responsible Gambling. ABB recently held Gamble Aware Week to promote responsible gambling in all members shops. The ABB promotes and represents the industry to decision makers and in the media and is responsible for making submissions to the Government or Gambling Commission on matters affecting shops. They recently signed a partnership with the Local Government Association which sets out ways the industry and local councils will work together. The ABB keep their members updated with industry developments, through regular newsletters and weekly updates. The Safe Bet Alliance, a collaborative initiative involving the ABB was introduced in 2010, has helped make betting shops as safe and secure for staff and customers as possible. The initiative has won awards and been endorsed by the National Police Chiefs Council (NPCC) as an example of an industry coming together with the police and other partners to tackle a problem. They aim to help create and sustain conditions in which socially responsible betting shop operators can compete and prosper. Remote Gambling Association (RGA) The RGA was formed in 2005 as a result of a merger between the Association of Remote Gambling Operators (ARGO) and the Interactive Gaming, Gambling and Betting Association (IGGBA). The RGA is the largest online gambling trade association in the world, representing most of the world s largest licensed and stock market-listed remote gambling operators and software providers. A full list of those members can be found at One of its membership criteria is that companies have to be licensed for gambling purposes in Europe. The RGA operates internationally and its work is overseen by its Executive Committee on which all of its members are represented. Below that it has a structure of sub-committees which specialise in particular areas. One of these is the Sports Betting Committee. A broad range of RGA members sit on the Committee and the European Gaming and Betting Association (EGBA) and European Sports Security Association (ESSA) attend as observers. This group has, for instance, been used to co-ordinate the wider industry s views and input to the development of the Council of Europe s Convention on the Manipulation of Sports Competitions. 7

8 Other examples of the RGA s involvement with sports betting integrity initiatives are: Ongoing work with the International Olympic Committee. This began in 2010 and has seen the RGA represented on various working groups and committees which have been established to address this and related issues. This will continue through its representation on the IOC s recently established International Forum for Sports Integrity. Support and funding for player training on integrity issues previously via the Professional Players Federation (PPF) and more recently at international level through the European Elite Athletes Association. ESSA ESSA was established in 2005 by regulated betting operators to meet the challenges presented by match-fixing in sport that could impact the betting industry and their customers. Originally named the European Sports Security Association, the organisation changed its name as part of its corporate identity change in June 2014 and is now simply known as ESSA. It currently represents 19 of the world s largest regulated betting operators, with an estimated 40 million customers betting with its members in the EU alone. It is a not-for-profit organisation with a central board structure (from its membership), which directs its operational policy approach and is managed by the Secretary General (and assisted by additional resources). ESSA works with other key stakeholders to address betting-related corruption in sport, which is primarily aimed at defrauding betting companies and their customers. A partnership approach is therefore at the core of its approach in achieving that objective. The association works closely with its members and other key stakeholders to exchange information related to potential match-fixing and to identify those responsible. ESSA has established information sharing agreements with over 20 sports governing bodies and a number of national regulatory platforms, including the Gambling Commission. Its core aims and objectives are to: protect the integrity of sport by preventing criminals from profiting from regulated betting provide a safe and secure betting environment for consumers work in partnership with other stakeholders at national and international levels be a leading voice in the discussion on how to combat betting-related corruption campaign for an evidence-based debate to ensure that policy decisions are effective promote the regulation of betting as a key element in defeating match-fixing call on the sports sector to ensure that robust rules and sanctions are in place support the education of players and other sporting personnel about match-fixing. A central part of ESSA s role is to protect the integrity of sport from betting-related matchfixing, notably by providing data to stakeholders regarding any suspicious betting activity taking place on its members regulated betting platforms. To achieve this, ESSA has developed and continually updated its reporting and early warning systems, and has invested in technology to provide a flexible and robust platform to deal with betting integrity issues. According to ESSA, their monitoring system has provided important data leading to sanctions against match-fixers and has been a major factor in deterring corrupters from attempting to use ESSA members regulated markets for their illicit activities. 8

9 Role of the Gambling Commission and SBIU The Gambling Commission was set up under the Gambling Act 2005 to regulate commercial gambling in Great Britain in partnership with licensing authorities. Through effective regulation and public engagement we permit gambling and ensure: it is crime free it is fair and open children and vulnerable people are protected. The Sports Betting Intelligence Unit (SBIU) is part of the Commission s intelligence capability and supports the Commission s betting integrity programme dealing with reports of bettingrelated corruption. It was set up as part of the recommendations in the 2010 Report of the Sports Betting Integrity Panel. The SBIU collects information and develops intelligence about potentially corrupt betting activity involving sport. Consumers must have confidence and belief that when they place bets with British licensed operators they are doing so on markets that are fair and free from betting related corruption. Central to this is collaborative working across the industry (including operators, sport, law enforcement and other regulators) to understand the potential threats and help protect the integrity of sport and betting. The SBIU contributes to this collaboration. How the Commission s betting integrity programme works within this collaboration is demonstrated in figure 1 below. The Commission will always remain focussed on the interests of Britain but we recognise that we must remain vigilant to international influences as these have the potential to impact British markets. To this end, where appropriate, we work with global partners and stakeholders and keep abreast of international issues to understand and mitigate the risks to British bettors and betting industry. The SBIU will share, where appropriate, specific intelligence or information with other partners (both nationally and internationally). The intention is that the SBIU will help bring together the intelligence efforts of partners and play its part in protecting sport from corruption. Figure 1: Gambling Commission Betting Integrity Programme Intent: To identify the threat and reduce the risk to sports betting and sport in Britain being corrupted by the manipulation of events or misuse of information. 9

10 National platform How SBIU works in practice: proportionality threshold regarding investigations and resources The SBIU is part of the wider Gambling Commission Intelligence capability. It is compliant with the National Intelligence Model (NIM) which is a nationally recognised intelligence led business model used by law enforcement agencies. This model enables SBIU to gather and manage information in order to make the most effective decisions. The SBIU is made up of two senior intelligence officers who have access to the wider intelligence unit resources including a financial investigator, analysts and a researcher. All staff within the unit are trained and accredited to a comparable standard with law enforcement agencies. The SBIU collate, evaluate, analyse and develop information in order to find links, associations and trends, they then produce intelligence products to inform investigative decision making on the prosecution or disruption of criminal offences (eg cheating) or regulatory action under the Gambling Act. Where relevant and appropriate, these intelligence products may be made available to third parties to assist disciplinary action. The intelligence products will also inform strategic analysis on sports betting integrity issues. The SBIU focuses upon collecting and analysing information and intelligence relating to potentially criminal activity in respect of sports betting, where that activity: relates to a sporting event that occurred in Great Britain involves parties based within Great Britain occurred with a Gambling Commission licensed operator. The Licensing Conditions and Code of Practice also outlines operator obligations under licence condition that licensees should in particular keep in mind the scope of the offence of cheating: The Commission would expect to be notified of any information a licensee has which causes them to know or suspect that there has been interference or attempted interference with: 10

11 a) an event which has taken or is taking place in Great Britain on which bets have been or are likely to be or to have been placed (whether in Great Britain or elsewhere); or b) an event which has taken or is taking place outside Great Britain on which bets have been or are likely to be or to have been placed in Great Britain. The SBIU undertakes targeted monitoring of betting on specific events and by specific individuals. It will not undertake general, pre-emptive monitoring of betting markets or sporting events. This remains the role of betting operators and sports governing bodies respectively. The SBIU acts as the Commission s gateway for sports betting intelligence matters by establishing national and international channels of communication for the receipt and dissemination of information and intelligence with relevant partners. The SBIU undertakes debriefings of sports betting integrity cases conducted by the Commission and partners to develop and share knowledge, working practices and techniques. SBIU initially assesses the intelligence gathered with the lead intelligence specialist; the intelligence will then inform the Commission decision making process. The flow chart at figure 2 gives an overview of this process. At these points amongst the following potential next steps are: No further action for example, this could be because there was an appropriate explanation for a suspicious pattern or insufficient information is available to proceed. Referral to an SGB this could be where there is potentially a breach of a sport s rule. The SGB would then decide how to proceed with it. Referral to betting operator/s this could be where there is potentially a breach of a betting operator s terms and conditions or contracts of employment. The betting operator would then decide how to proceed with it. Grounds to suspect crime is being/has been committed A smaller number of cases may be developed further this is where there is sufficient intelligence and evidence to consider that criminal offences may have occurred. The SBIU could then seek to secure additional intelligence and evidence utilising criminal investigatory powers. This will involve consideration by the Commission Issue Management Group who will decide on the proportionality of progressing the investigation and necessity to deploy additional resources. Gambling Commission investigatory powers, such as those under Regulation of Investigatory Powers Act 2000 (RIPA) and Proceeds of Crime Act 2002 (POCA) can only be utilised to investigate a criminal offence commensurate with its role in regulating gambling which in this context is usually the offence of cheating. The ability to obtain communications data, identify and seize money and conduct directed surveillance must be viewed in that context and are only used in significant criminal investigations. The Commission is subject to full external oversight and scrutiny. The Commission would not use investigatory powers once it considered an issue unsuitable for, or to continue with, a criminal investigation. The test for this is common to that of other regulatory and law enforcement agencies, one based on the sufficiency of the evidence and intelligence available at the time of the decision and the most appropriate means of disposal. 11

12 The Gambling Commission has an in-house legal team and uses expert lawyers to advise in complex matters. If the Gambling Commission identifies other criminal offences or that the investigation may require more intrusive powers it will seek to engage with appropriate law enforcement partners for their consideration of adoption of the investigation. Figure 2: High level overview of the SBIU decision making process 12

13 Analysis of betting integrity issues reported to the Commission The total number of reports has varied each year with no consistent pattern emerging. Official figures are published by the Gambling Commission in Industry statistics. Betting risks how are they managed by operators? There is still a clear distinction between retail betting (betting shops) and online betting; albeit in both mediums the landscape is dominated by a limited number of major betting sports. Retail Horserace betting is still the dominant betting medium within the retail environment with around half of all over the counter (OTC) gross win being provided by horserace betting. On average football contributes around a quarter of total OTC gross win. The main retail markets are 90 minutes and both teams to score. Both these types of market feature on multiple retail coupons every week. Greyhound racing makes a contribution of around 15% of total. These three sports, which are the mainstay of sports betting within the shop environment, together with virtual and numbers betting contribute 99% of retail OTC gross win. Whilst other markets are offered on other sports such as cricket, golf, rugby league and rugby union, all these sports make a minor contribution to retail profitability. That said the lower liquidity and lower volumes of bets in these markets makes unusual/suspicious transactions more apparent. Online sportsbooks Online markets can be divided into two areas: pre-match and in-play betting. Overall football is the biggest betting sport online (in terms of contribution to gross win), followed by horseracing and to a lesser extent tennis (match betting: head to head prices on who will win each match). These three sports account for around 95% of gross win. A much wider range of markets is offered online. These include: Golf: most significant turnover in the majors with in excess of 90% of turnover being in the win markets. Cricket: majority of turnover is on international and IPL markets and in-play. Domestic cricket is a very small part of the cricket betting landscape. Cricket is a low margin product. Snooker: match betting (head to head markets). Rugby (League and Union): handicap betting, comparatively low turnover although raised interest in high profile matches live Six Nations (union) and televised Super League matches. How markets are managed by retail/sportsbook operators Betting operators manage betting markets, from both a financial risk and regulatory compliance perspective. Bookmakers, and the sports on which markets are made, want those sports to be clean. It is the fundamental principle of the unpredictability of sports outcomes that drives interest in betting markets; so for legitimate operators the prospect of event fixing is as damaging to the operator as it is to the sport. 13

14 A principle regulatory obligation of British licensed operators is to report suspicious betting transactions. Making markets, managing the risk in those markets (altering prices etc) and detecting unusual or suspicious betting transactions is generally the function of trading specialists. Trading specialists will have general or sports specific expertise which includes knowledge of the way markets behave. Whilst it is possible to describe the general features of betting markets made on the major betting sports (see below), it is difficult to design a formal matrix which can codify the many different factors which may be taken into account by a betting operator when deciding whether or not a bet or series of bets may actually be either unusual or suspicious and whether such are reportable. This is because each set of circumstances surrounding betting activities is different and each betting company is a private operator with its own procedural and operational risk management triggers. Consequently, decisions of this type are ultimately subjective and based on experience and evidence from the market as a whole. A trader will have in mind what they consider to be a normal liability on a particular market eg Champions League final 90 minutes 500k, women s ski jumping 5k. However there will be variables due to the size of the operator and the countries they operate in. There will then be further considerations depending on how an operator has priced the market. An operator may be above market price, consistent with the market or below market price. If the operator is above market price, one would expect in excess of the defined number possibility in terms of liability. This is likely a conscious decision on part of the operator. At this point is more difficult to detect unusual activity as offering an above market price will create increased betting activity, including new customers and increased volume. If an operator is offering at market price then one would expect a steady amount of business from normal clientele. If money was seen for new customers, customers grouped in a certain area or country all back the betting option, it may be an indicator of unusual/suspicious activity. If an operator is offering under the market, one can expect less business on the market, and any unusual/suspicious transactions are easier to identify, as any large bet under the market would be an established customer with a history of betting with the operator, if not then it may warrant further investigation. There is also a significant difference between a pattern that may be unusual and a pattern which may be suspicious and it does not follow that if a bet or bets fall within the definition of unusual, it/they will turn out to be suspicious. Betting companies have reputational and financial incentives to prevent activity that indicates cheating or misuse of inside information. However, it is important to note from the outset that recognition that a bet or pattern of bets is unusual or suspicious may not always emerge at the time of acceptance; many, if not most, only become apparent after the event and are the result of retrospective suspicion or linked information. So, whilst there can be no formalised or universally applied definitions of unusual/suspicious betting patterns, there are, nevertheless, some generalised objective guidelines which 14

15 bookmakers and traders would consider in whole or in part when forming a view as to whether a particular betting pattern was unusual or suspicious or both. How integrity risks are mitigated by the operator of an exchange: A Betfair perspective Betfair operates an exchange as well as offering other sports betting products such as a sportsbook. For the purposes of this section the exchange is the focus. The same overall approach is however used across all sports products; unusual or suspicious betting activity on any product is treated in the same manner and information is shared with relevant partners. General approach The interests of betting operators and sports are aligned in that both want sporting events to be conducted in a fair and transparent manner. Customers having confidence in the markets offered is of upmost importance. Betfair has long been of the opinion that the best way to tackle betting related corruption is by sports, regulators and betting companies working cooperatively and each fulfilling their responsibilities in this area. In order to fulfil responsibilities to customers, regulators and sporting partners Betfair has a dedicated Integrity Team whose remit is to prevent, detect and investigate unusual or suspicious activity. The team has experienced analysts as well as sophisticated reporting techniques which allow anomalous betting activity to be identified, analysed and then defined as suspicious or merely unusual. Where suspicious activity is detected it is shared with relevant regulatory and SGB partners. Betfair, along with Ladbrokes, Bet365 and Betway has a funding partnership in place with the Professional Players Federation (PPF) for a betting education programme. Integrity Team - alerts and control systems Betfair has the ability to follow the money through its audit trail. All activity is recorded and the Integrity Team have access to detailed betting reports, computer forensics, payment transactions and telephone recordings, all in real time. They have access to an internal monitoring tool which allows enhanced monitoring of both market level and individual account activity on any given market. Real time alerting at both account and market level plus fast access to all relevant prior customer and market data provides the tools and information needed to quickly identify and investigate potential issues. A suite of daily/weekly/monthly exception reports are also utilised by the team. Betfair terms and conditions allow accounts to be suspended or closed and winnings from suspicious events to be frozen pending investigation by Betfair and/or external bodies (such as sports governing bodies or law enforcement). These provisions can and are utilised in the small number of occasions when suspicious activity is identified. Factors/triggers that may suggest suspicious activity would be the same as for any other sports betting product and are set out in SBIF unusual/suspicious betting framework described on page 5. When unusual betting is identified a full analysis is carried out by Betfair analysts to determine whether this activity is suspicious and to determine if it should be reported to the Gambling Commission under licence condition and/or reported to any relevant SGB either under or through the memorandum of understanding (MoU) process. Where possible these alerts are sent prior to the event in question taking place. Memoranda of understanding (MoU) information sharing agreements In 2003, along with the Jockey Club (now BHA), Betfair pioneered the concept of integrity related information sharing agreements (MoUs) between sports and gambling operators. Betfair now has over 65 such agreements with sporting and regulatory bodies worldwide, 15

16 These MoU agreements bringing partnerships across major sports at both national and international level. Once an MoU agreement is in place with a relevant body Betfair encourages the two way sharing of information; the Integrity Team often receive information from MoU partners and will provide detailed analysis of betting on specific events. When proportionate and justifiable to do so MoU partners will be provided with information relating to specific customers who have bet in a suspicious manner or have broken sport s rules. If these thresholds are not met then information identifying specific customers is not shared. The sharing of customer data with sports bodies under the MoU is possible due to the terms and conditions that Betfair customers accept upon account opening. The terms and conditions that Betfair customers accept upon account opening have specific provisions which allow, in certain circumstances, their personal details to be shared externally, for example with regulators and MoU partners. This allows for information to be shared with sports or gambling regulatory bodies within the provisions of privacy legislation. The full wording of Betfair s privacy policy can be found on the website. Betfair believes being able to provide personal details of customers placing suspicious bets is crucial to successful sports and regulator investigations. Betfair has provided data which has been used in disciplinary hearings for sports including horseracing, football, greyhound, Rugby League and snooker. Without access to personal data it can often be difficult to conduct thorough investigations into sport s rule breaches or wider threats to the integrity of sport. In addition to internal alert and control systems Betfair also offers MoU partners and regulators access to the Betmonitor. This is a web-based platform that allows enhanced real time monitoring of betting activity on the MoU partners particular sport. No personal information is displayed but users are able to view bets on their sport as they are placed. The Betmonitor is used extensively by the BHA as well as other sports governing bodies. Screenshot of the live bets page of the Betmonitor 16

17 Sports betting profiles By volume of money traded, football and horseracing are by some way the most popular sports on the Betfair exchange. Tennis followed by cricket are the next most popular sports with all other sports producing a very small percentage of the total traded on the Betfair exchange. The traded volume on any given exchange market is not the amount of potential customer winnings but the sum of all the bets matched on a market. The matched figure represents double the amount of backer's stakes that have been matched on the market, for example a customer placing a back bet of 50 at odds of 3.0 (or 2/1 in fractional prices) would increase the matched volume by 100. The traded volume figure is therefore not directly correlated with the sums won and lost by customers. If customers were continually trading a market then they could in theory trade 10m in volume with zero customer winnings. Betfair takes a small commission, typically 2-5%, of a customer s net winnings on a market. Looking at Premier League football markets in the 14/15 season from a market perspective the match odds markets offered made up around half of the total volume traded and 90% when combining this with the volume from number of goals markets. It is worth pointing out, given the recent high profile media coverage, that markets such as sending off make up a tiny percentage of the volume offered on a typical football match. Looking specifically at Premier League markets in the same period as above then total volumes traded on all bookings and sending off markets accounted for significantly less than 0.1% of all volume traded. These types of markets simply do not have the liquidity or customer interest which would support the winning of large sums. Suspicious or unusual activity such as increased interest in a market such as this would be straightforward to detect. Given this they are likely to be unattractive from a match-fixing perspective as the potential sums that could be won are small and the chance of detection is high. Similar conclusions were drawn in a recent Asser Institute study: The Odds of Match-fixing: Facts and Figures on the Integrity Risk of Certain Sports Bets. It should be noted however, whilst the limited liquidity within certain high-risk markets may reduce the risk of large-scale betting corruption, there remains a potential integrity risk from the misuse of inside information and, potentially, betting by participants associated with these markets. 17

18 Sports risks how are they managed by sports governing bodies? This section will explore a number of sports and the rules, regulations, systems and procedures in place to help mitigate the risks in betting integrity. In addition it will investigate how sports governing bodies work collaboratively with each other, law enforcement agencies, betting operators and the Gambling Commission. British Horseracing Authority (BHA) Integrity functions The BHA deals with a range of types of investigation, including cases of betting-related corruption which are amongst the most frequent and certainly the most resource-intensive. The team consists of various roles, as follows: Head of Integrity Operations Intelligence Development Principal Field Intelligence Officer Betting Analysts Intelligence Analysts Betting Investigator Investigating Officers Stable Inspecting Officers BHA s in-house experts monitor betting markets (including through Betmonitor) and racing on a daily basis, which is intelligence-led. BHA has a bespoke confidential and anonymous 24/7 reporting telephone line with Crimestoppers branded as Racestraight, along with an online form and an ability to receive information directly into the intelligence unit by telephone and dedicated address. Intelligence information sharing The BHA works to the National Intelligence Model (NIM). NIM helps to focus, prioritise and drive their business around their integrity function. The BHA has taken elements of NIM to drive its own business and integrity model. This is compatible with other enforcement agencies that use the NIM model. The system used by the BHA for the storage of intelligence and information is Memex Patriarch. This software is a widely accepted, credible and effective intelligence system and is used by the Metropolitan Police and other provincial police forces, as well as other sports regulatory bodies. Another element of NIM which the BHA uses is tactical and strategic tasking and coordination. This is an important aspect allowing them to focus and prioritise their valuable resources through tactical and strategic tasking. The BHA use i2 as analytical software. This software is used for mapping intelligence and information to produce analytical products, for example timelines of phone billings, betting data and computer sharing. The BHA also uses the software system Connexus to provide access to marketing data compiled by numerous private companies. The software searches names, addresses, telephone numbers and s, which people have shared on consumer websites. 18

19 Connexus also provides access the electoral role, directory enquiries and Companies House records. The BHA relies upon betting operators complying with licence condition 15.1 of the Gambling Commission s Licence Conditions and Code of Practice, regarding reporting any suspicion of offences. The BHA also has Memoranda of Understanding (MoU) with a number of betting operators. The BHA has an information sharing agreement with the Gambling Commission. However, the exchange of information is also facilitated by virtue of Schedule 6 of the Gambling Act 2005, within which the BHA is listed as a sport governing body. On a case-by-case basis the BHA can implement information sharing agreements with law enforcement agencies where necessary. The BHA has recently been accepted into the Government Agencies Intelligence Network (GAIN) which is a multiagency group that brings together intelligence and investigation resources to participate in enforcement action and tackle organised crime by working together in a formal relationship using an information exchange. GAIN is part of the Eastern Region Special Operations Unit (ERSOU) and the BHA is believed to be the only non-statutory body accepted into GAIN to achieve effective partnership and collaborative working. Inside information and betting by participants The BHA specifically prohibits the communication of inside information in their Rules, currently as follows: (A)36: Inside Information is information about the likely participation or likely performance of a horse in a race, which is known by an Owner, Trainer, Rider, stable employee or any of their service providers as a result of acting as such, and is not information in the public domain. A Person must not communicate Inside Information directly or indirectly to any other Person for any material reward, gift, favour or benefit in kind. The BHA provides further definition and clarification of inside information in the public domain at Schedule (A)5 of their Rules. Participants are contracted with the BHA through licensing and registration. They are bound to the below points: Trainers and owners cannot place a lay bet on a horse trained or owned by them. Professional jockeys are prohibited from any betting on horseracing in any country. Amateur jockeys are prohibited from betting in races they are riding in. Stable staff cannot place a lay bet on horses trained by their employing trainer. Service providers to owners, trainers and riders cannot place a lay bet on horses trained, owned or ridden by the person they provide the service to. Education Prior to applications being determined, and during the currency of licences, individuals are required to undertake various training on integrity, dependent on the application being made. This includes: attendance at a seminar on integrity, led by the BHA Integrity team a visit to the individual by BHA Stable Inspecting Officers to brief individuals on integrity requirements completion of a questionnaire which includes questions relating to integrity 19

20 inclusion of integrity provisions within the guidance notes of all applications to the BHA, which the individual is requested to read prior to signing a declaration to confirm their understanding and agreement. When the Rules on inside information were introduced, the BHA held mandatory seminars for all licensed persons. Further, an online module was created which individuals were required to successfully complete. For several years subsequent to the introduction of these Rules, all new applicants were required to undertake the module prior to an application being granted. Trainers in particular are required to display relevant guidance on inside information at their established premises. Within the declaration signed by applicants, the BHA reserves the right to implement further training upon a participant. Additionally, the BHA has recently published an integrity education video featuring jockey Fergal Lynch. Case studies 2013: 2014: Eddie AHERN - Failure to ride a horse on its merits - Passing of inside information - Involvement in corrupt or fraudulent practices: 10 yrs disqualification. Andrew HEFFERNAN - Preventing a horse from obtaining best possible placing - Involvement in corrupt or fraudulent practices - Communication of inside information - Offering or accepting bribes: 15 yrs disqualification. Steven GAGAN - Failure to ride a horse on its merits - Passing of inside information - Conspiracy to commit corrupt practices - Failing to supply phone records for an unregistered phone: 14 yrs disqualification. Elliot COOPER - Passing of inside information - Conspiracy to commit corrupt practices - Laying his own horse - Causing and encouraging breaches by Gagan: 14 yrs disqualification. Continual review of integrity strategy After each significant case, relevant departments of the BHA gather to discuss improvements that may be made to their systems and processes, in particular their Rules and the way they gather and utilise intelligence, evidence and manage and present cases. The Director of Integrity, Legal and Risk has announced a more general review of the BHA's integrity function to be completed by the end of

21 Other principle challenges to the integrity of horseracing: Lack of effective control over non-participants. Difficulties in obtaining evidence from individuals and other organisations data protection. Ability for individuals to communicate from wherever they are, sometimes without even leaving a trace. Economics of the sport. 21

22 England and Wales Cricket Board (ECB) Integrity functions The ECB s anti-corruption strategy is set by the ACCESS Group and delivered operationally by the ECB s Anti-Corruption Unit. The ACCESS Group is made up of a number of key individuals with a broad range of varied expertise. The Group sets the direction and delivery priorities for education, disruption, partnerships, information gathering and interventions. A confidential ACCESS Board considers the progress and impact of all investigations and will make decisions on proceedings. The ECB s Anti-Corruption Unit consists of two full time staff, one Manager and one Investigator, who are both former Metropolitan Police Service senior ranking detectives. They are currently supported by five contracted staff during the cricket season. The Anti- Corruption Unit manager reports directly to the ECB CEO and the Chair of the ACCESS Group. Intelligence and information sharing ECB uses the IBM system, i2, for the secure retention and analysis of intelligence. The i2 system is hosted on a remote server for security reasons. Access rights to i2 are restricted to the two full time Anti-Corruption Unit staff. ECB has a bespoke information sharing agreement with Betfair to share information on potential betting integrity related issues relevant to any cricket played under the jurisdiction of the ECB, including England s home international matches and all county cricket matches. The agreement acts as a safeguard against any betting integrity issue within cricket, allowing Betfair to share any relevant customer and transactional data with the ECB, where appropriate, as well as providing the ECB with access to the analysis of Betfair s integrity team. Information is also shared between the Gambling Commission and the ECB under Schedule 6, Gambling Act Additionally information is shared with other cricket jurisdictions under the authority of the ECB Anti-Corruption Code (the Code). Inside information and betting by participants Misuse of inside information for a betting purpose is included at section 2.3 of the Code. Breaches of section 2.3 attract a ban ranging from six months to five years. The ECB defines inside information as any information relating to any match or event that a player or player support personnel possesses by virtue of his/her position within the sport. Such information includes, but is not limited to, factual information regarding the competitors in the match or event, the conditions, tactical considerations or any other aspect of the match or event, but does not include such information that is already published or a matter of public record, published widely for unrestricted public consumption, or disclosed according to the rules and regulations governing the relevant match or event. 2.3 of the Code - Misuse of Inside Information: Using, for Betting purposes, any Inside Information Disclosing Inside Information to any person (with or without Reward) before or during any Match or Event where the Player or Player Support Personnel knows or might reasonably be expected to know that disclosure of such information in such circumstances could be used in relation to Betting. 22