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

23 Education The ECB works closely with and supports the Professional Cricketers Association (PCA) which leads on the education of cricketers about sports betting integrity. All professional players are required to undertake and complete an online educational tutorial as a part of the registration process. Compliance and completion with this requirement are monitored remotely. A registered player cannot play for his club until this tutorial is completed. Compliance with the Code is a condition of each players ECB registration and annual undertaking. All playing squads are briefed each year by the PCA and the ECB s Anti-Corruption Unit on emerging issues, one of those issues being the threat of corruption to cricket. Annual presentations are delivered to many stakeholder groups about the threat of corruption and reporting mechanisms. Case study One of the most notable recent cases studies in cricket involves former New Zealand international and Sussex batsman Lou Vincent and his team mate and Pakistani bowler Naved Arif. In 2014, Vincent was charged with 14 offences relating to two matches: a Twenty20 match between Sussex and Lancashire and a 40-over game between Sussex and Kent at Hove. Arif was charged with six offences in relation to the 40-over game between Sussex and Kent in August The ban prevents them both from playing, coaching or participating in any form of cricket which is recognised or sanctioned by the ECB, the International Cricket Council or any other national cricket federation. Continual review of integrity strategy An operational review is conducted at least annually by the ACCESS Group where the Anti- Corruption Unit is held to account for performance delivery. Their systems and processes are consistent with and based upon the Code of Conduct. Other principle challenges to the integrity of cricket The ECB consider that the biggest and most difficult challenge to domestic cricket is the threat posed by the illegal and unregulated bookmakers from the sub-continent at one day broadcast cricket matches. Agents of the bookmakers are present at these one day matches and broadcast live commentary to the bookmakers in order that they can set odds and markets based on information communicated to them quicker than the broadcast play. The clubs have introduced a ground regulation to prevent the unauthorised broadcast of data and this is enforced by ECB staff through interventions at matches. 23

24 Rugby Football League (RFL) Integrity functions Education processes and strategy for betting integrity are developed by the RFL Operations Department with assistance from the Legal and Compliance Department. Any betting integrity matters that arise will be referred to the RFL s Legal and Compliance Department which consist of qualified legal professionals. These may be referred via the Gambling Commission or by alerts from the RFL s own intelligence sources. The RFL has wide investigatory powers included within their Operational Rules. Any investigation would be handled by one or more of a number of independent compliance investigators. These individuals have varied expertise gained predominately either through police, forensic accounting or private investigatory work. The RFL Legal and Compliance Department will assist and liaise with the Gambling Commission, individual bookmakers etc where appropriate to do so. Any case referred for adjudication will heard by an independent panel chaired by an acting or retired High Court or Circuit Judge. Intelligence and information sharing All compliance investigations are carried out using established systems and procedures developed by the RFL Legal and Compliance Unit. Files are only accessible by a limited number of authorised personnel. The RFL has an information sharing MoU with Betfair as well as links to other major bookmakers. Information is shared between the Gambling Commission and the RFL under Schedule 6, Gambling Act Social media channels are actively monitored for evidence of betting activity, and all RFL Match Commissioners consider potential betting integrity issues when attending games on behalf of the RFL. Inside information and betting by participants Misuse of inside information for a betting purpose is included in the RFL s Betting Code of Conduct (Code). The following offences identified in the Code are some which are relevant: E Using in relation to Betting, or providing to any other person for use in relation to Betting, any information relating to any Match, Competition or Event(s) that the Person has in his possession by virtue of his position within the sport and that is not in the public domain or readily accessible by the public E Providing information to any person for reward, before or during any Match, Competition or Event, regarding the competitors in the event, the conditions, tactical considerations or any other aspect of the event, unless such information is already in or will come into the public domain. Players and player support personnel as defined are not permitted to bet on any Rugby League activity under the jurisdiction of the RFL. This includes games and other markets in all professional competitions, not just the division or competition in which they are participating. Further to the rules already considered the Code also covers encouraging others to enter into a bet for the person s direct or indirect benefit and to ensuring the occurrence of a 24

25 particular incident in a match, competition or event, which occurrence is to the person s knowledge the subject of a bet. Recommended sanctions for breaches of the Code are set out in the RFL s Off Field Sentencing Guidelines however are unlimited. Participants are also not permitted to have any commercial arrangement with any company or other undertaking that promotes, brokers, arranges or conducts any form of betting activity in relation to Rugby League matches as defined. Education The RFL delivers player training itself rather than it being delivered by a Players Association. All Super League, Championship and League 1 clubs have received workshop based training either in 2014 or 2015 and this will be repeated in This education is delivered by recently retired former full time professional players. In each year the workshop is also delivered to all new professional players at their RFL Central Day. All match officials and match commissioners have also attended educational workshops. The RFL are also looking to develop on online tool to support this education. Case study 2014: Sean Long and Martin Gleeson. Great Britain internationals were banned for 3 and 4 months respectively and fined This related to betting against their team in a game in which Long didn t play but Gleeson did. 2010: Mark Cass. Assistant coach of a Championship team banned in 2010 for 12 months for betting against his own team. 2011: Sean Leaf. Championship player was stung in a national newspaper story and bet unsuccessfully against his own team. This led to an 18 month suspension. 2013: Ayden Faal and Johnny Campbell. Suspended for 9 months and 4 months respectively for betting on the outcome of the first scoring play in the 2013 Championship final. Campbell played in the game Faal did not. 2014: Andy Thornley and Rob Worrincy. Championship players were banned for 10 months and 9 months respectively in 2014 for multiple breaches of the Code. 2015: Former England International Richard Mathers was banned for 6 months for breaches of the Code relating to passing on inside information and encouraging persons to bet against his team in a game in which he did not play. League 1 player Jy-Mel Coleman banned for 6 months for multiple breaches of the Code. Continual review of integrity strategy An operational review is conducted annually by the Operations and Legal and Compliance Departments. Any necessary amends to the relevant regulations will be made after this review. The RFL also had their betting integrity regulations including the Code reviewed by an external consultant in 2013 to confirm their relevance and fitness for purpose. 25

26 Other principle challenges to the integrity of Rugby League Rugby League has not been identified as a particularly high profile betting sport but it is acknowledged that a betting culture in general has existed amongst some participants in the sport. The primary betting market in Rugby League is handicap betting which creates obvious risks. Also the increase in markets available on matches brings with it additional risks of corruption. For example, markets such as first scoring play and anytime try scorer are potentially particularly subject to corruption and an instance of this has been seen in Australian Rugby League. It is recognised that the potential for this type of corruption is restricted by lack of liquidity in these markets however. The relatively tight geographical spread of the sport may carry with it increased risks that inside information is passed between participants 26

27 Football Association (FA) Integrity functions The FA s Integrity Unit comprises a Head of Football Integrity, with the support of an Investigations and Intelligence Manager and Officers. The Unit is also supported by a regulatory legal advice team, comprising a number of barristers with specific sports regulatory experience. The FA uses a specialist bet monitoring company to provide comprehensive details of any matches their systems may have identified as suspicious. Under its Rules, The FA has the power to require participants to attend for interview and to provide (or procure provision of) all documentation, records etc as is required by The FA in the course of its inquiries. Intelligence and information sharing The FA is now utilising a bespoke sports integrity intelligence management system. This system, currently used in Major League Baseball and Australian Rules Football, enables detailed grading (in accordance with the National Intelligence Model) and analysis to be carried out of intelligence and for it to be developed to assist investigations. The FA s intelligence comes from a wide variety of sources, including its own reporting line and account, its customer service line, UEFA/FIFA, operators and experts within the betting industry itself, the Gambling Commission and state agencies. An Investigations Officer has responsibility for maintaining this information and there are strict access protocols in place. The FA has an MoU with Betfair and has direct links with a number of on and off shore betting operators which can assist in the conducting of an investigation. Information is regularly shared between the Gambling Commission and the FA under Schedule 6, Gambling Act Additionally, information is also shared with law enforcement authorities, in particular the National Crime Agency, either directly or through the Gambling Commission. The Head of Football Integrity also represents the FA on a European basis as a UEFA appointed Integrity Officer, and will share information with his counterparts across the continent as appropriate. Inside information and betting by participants The FA has a specific rule governing the definition and use of inside information: Rule 8 (2) (d) Where a Participant provides to any other person any information relating to football which the Participant has obtained by virtue of his or her position within the game and which is not publicly available at that time, the Participant shall be in breach of this Rule where any of that information is used by that other person for or in relation to betting. (2) (e) It shall be a defence to a charge brought pursuant to sub-paragraph E8(2)(d) if a Participant can establish, on the balance of probability, that the Participant provided any such information in circumstances where he did not know, and could not reasonably have known, that the information provided would be used by the other person for or in relation to betting. 27

28 Participants are prohibited from betting (either directly or indirectly) on any football match, competition or event anywhere in the world. Betting on any under-18 match is also prohibited at whatever level the participant is operating. A participant also refers to any match official, referee coach or referee assessor. Education All professional clubs are visited at the start of the season, either by the FA, PFA or a combination thereof. Written material, including a guide to the rules for players is also issued annually. Both the PFA and the FA websites provides a number of resources on integrity matters for Participants, including a number of educational films released to coincide with the complete prohibition on betting on football. Case studies There have been a number of high profile cases relating to betting integrity in recent years. These include Newcastle midfielder Dan Gosling who was fined 30,000 for breaching multiple betting rules. Tottenham midfielder Andros Townsend was fined 18,000 in June 2013 and banned for four months, with three of those months suspended, for breaching betting regulations. Cameron Jerome, then at Stoke, received a 50,000 fine in August 2013 for the same offence. More recently, the FA imposed a lifetime ban against Michael Boateng in relation to match manipulation. Boateng admitted to charges laid against him by the FA for several breaches of the FA Rules, including accepting a bribe, gift, reward or other consideration which was, or appeared to be, related to seeking to influence the outcome or conduct of a match or competition. The player also admitted to the charge of failing to report the offer made to him. The charges relate to matches in the Conference South in the sixth tier of the English football league system in Continual review of integrity strategy The FA s Director of Governance and Regulation sits on SBIF and SBG and accordingly ensures that specific changes of the nature identified above are fed back into the operations of the Integrity Unit. A regular rules review process is also undertaken to ensure that operational practice and learnings are reflected in the approach to integrity matters. Other principle challenges to the integrity of English football A major challenge for the sport in recent years has been working (in conjunction with the Gambling Commission) in seeking to engage law enforcement authorities to use each body s complementary powers to take on cases of betting corruption. The FA is optimistic that recent National Crime Agency activity indicates a willingness to do this. A further issue is the largely unregulated Asian betting operators, and the limited lines of communication between them and either the governing body, Gambling Commission or law enforcement agencies. These impact on the ability to obtain information in relation to possible betting corruption cases. 28

29 Rugby Football Union (RFU) Integrity functions The RFU has an integrity function and this falls under the remit of the legal and governance department. The RFU has a nominated anti-corruption officer who is responsible for anticorruption matters, the establishment of an internal cross-departmental rugby integrity group some years ago to put together a specific strategy for anti-corruption and has put in place a Professional Rugby Integrity Group to oversee and manage the implementation of the agreed strategy. The Professional Rugby Integrity Group compromises of representatives from RFU, Premiership Rugby, the Championship clubs and the Rugby Players Association and has been functioning for a number of years. In terms of investigative capability, such capabilities are already in place in relation to regulatory breaches, although not bespoke to corruption breaches. Intelligence and information sharing The RFU has a system in place to log any reported intelligence. The single point of contact for logging such intelligence is the nominated anti-corruption officer and education is being carried out to raise awareness of this. The RFU also has a dedicated anti-corruption hotline number and address. The RFU has a number of MoUs in place with betting operators and also engages a third party monitoring company to monitor betting patterns of all matches under the jurisdiction of the RFU. World Rugby and Six Nations also have similar arrangements in place. There are also information sharing provisions in the RFU regulations and World Rugby regulations to enable the RFU to share information with other unions, tournament organisers and regulatory bodies. Inside information and betting by participants The RFU s rules on inside information, betting and match-fixing are set out in RFU Regulation 17. These provisions mirror and reinforce the provision of World Rugby Regulation 6. Rugby Union imposes a blanket ban on all players, player support personnel and other connected people from betting directly or indirectly on any rugby anywhere in the world. The restrictions and obligations are set out in Regulations as well as in staff policies, player and match official codes of conduct and third party contracts. Education Premiership players and the England squads have been educated on anti-corruption for the last few years, which includes face to face education as well as completion of an online module. The RFU, Premiership, Championship and RPA also communicate regularly with its clubs, players, staff and officials on this area by circulating digital communications to all individuals who are captured by the regulations to remind them of the restrictions and obligations. Communications on the anti-corruption regulations have been circulated to players, clubs, rugby stakeholders, match officials, disciplinary personnel, staff, board and council members. There is a plan to put in place a bespoke education programme in this area so that education is extended to the championship clubs and the semi-professional clubs, as well as improving existing education programmes. 29

30 Currently, the RFU does not impose any specific sanctions for non-completion of such training/education programmes although this is being looked at in advance of next season. World Rugby provides education to players and team management in advance of the World Sevens competitions and the World Cups. Presentations have been made to RFU staff, England Rugby 2015 staff and the professional referees on anti-corruption regulations, monitoring and reporting. Case studies In 2015, Leicester Tigers coach Phil Blake, was banned for six months for placing bets on his own team. He was additionally fined 669, the amount he won on his bets. Continual review of integrity strategy The RFU has a detailed rugby integrity strategy in place underpinned by the key focus areas identified by the Parry report. The strategy contains a series of recommendations/action points, some of which have been actioned already and others that will be implemented over the coming seasons. This strategy, together with the regulations and procedures, is reviewed on an ongoing basis and work is continuously being carried out in this area. The RFU continues to liaise with other sports and specialists in this area and is constantly adding to the recommendations in its strategy. Other principle challenges to the integrity of Rugby Union Although the RFU has not had considerable direct experience of anti-corruption issues, one of their main concerns is whether they would have the necessary investigative powers and the necessary data protection consents in place to permit them to successfully conduct an investigation. 30

31 World Professional Billiards and Snooker Association (WPBSA) Integrity functions The Head of Integrity is the Vice Chairman of the WPBSA and has full autonomy from the WPBSA Board and commercial arm to deal with integrity issues. The WPBSA works in partnership with Monitor Quest who provide an Integrity Unit and confidential contact lines. Investigations are conducted by the Head of Integrity using partners such as Quest and the International Centre for Sports Security (ICSS) dependant on the case. Intelligence and information sharing Worldwide betting monitoring is conducted through Sport Radar. All intelligence is kept within the Integrity Unit. There is no dedicated intelligence software used. WPBSA has just entered into an agreement to use RAID software to monitor social networking and forums. WPBSA has MoUs to share information in place and work closely with BetFair, ESSA, ABB, BHA, ECB and other SGBs. Information is also shared between the Gambling Commission and the WPBSA under Schedule 6, Gambling Act Inside information and betting by participants WPBSA has in place clear rules prohibiting the use of inside information. It has defined inside information as:...to use for betting purposes, or to provide to any other person for such purposes, any information relating to the tour and/or any tournament or match that the member possesses by virtue of his position within the sport and that is not in the public domain or readily accessible by the public. Additionally, to provide information to any person for reward, before or during the tour and/or any tournament, regarding the competitors in a tournament or match, the conditions, tactical considerations or any other aspect of the tournament or match, unless such information is already in or will come into the public domain without delay or is readily accessible by the public. WPBSA members and players are prohibited from betting (either directly or indirectly) on any snooker or billiards event anywhere in the world. Education Induction days are held annually for new entrants to the professional tour. This includes a presentation on corruption issues and snooker case studies. This is a condition of playing on the professional tour. One to one meetings are held between the head of integrity and players at tournaments. Presentations are also conducted in Chinese to the Chinese professional and amateur players, referees and coaches in Beijing and Zhangjiagang 31

32 Work is being conducted with the Thai snooker federation to provide support re anticorruption through rules and disciplinary support in country. A new e-learning package is being developed with Sport Radar that will start in the New Year. This will be a condition of competing on the professional tour. Case studies Joe Jogia WPBSA contacted by betting operator re suspicious betting. Investigation with the Gambling Commission led to disciplinary finding for breach of the betting rules. Jogia was banned for two years and ordered to pay 2,000 costs. Stephen Lee following a police investigation, Lee was referred back to WPBSA when CPS took the decision not to prosecute. Lee was investigated by WPBSA was convicted at an independent disciplinary hearing of seven counts of match-fixing. He was banned for 12 years and ordered to pay 125,000 in costs. John Sutton more recently, following suspicious betting patterns that were reported after a 6-0 loss in 2014, Sutton was found guilty of match-fixing and passing on inside information. Sutton was banned for six years in 2015 and ordered to pay 5,000 costs. Continual review of integrity strategy According to the WPBSA, integrity systems are under constant review. The Members and Disciplinary Rules were last reviewed in Other principle challenges to the integrity of snooker and billiards WPBSA s main challenge is obtaining betting data from gambling operators in Asia. Without this data, investigations are obstructed as it is difficult to make links to the players. WPBSA has also stated that another challenge is data sharing agreements with public sector bodies. 32

33 Professional tennis governed by: Association of Tennis Professionals (ATP) Women s Tennis Association (WTA) International Tennis Federation (ITF) Grand Slam Board Integrity functions The Tennis Anti-Corruption Program (TACP) was introduced on 1 January The TACP provides a robust set of rules and powers to allow proper investigations to be carried out by the Tennis Integrity Unit (TIU). The TIU consists of a Director, three Investigators, one Information Manager and one Admin Support Staff. Under the TACP each governing body appoints a Professional Tennis Integrity Officer (PTIO) and above them sits the Tennis Integrity Board (TIB) which is made up of the four Presidents of each of the governing bodies. The Director of the TIU is responsible for setting the direction and delivery priorities for education; prevention and investigation. At the conclusion of an investigation the Director of the TIU submits a report to the four PTIOs who consider the evidence and decide upon a majority verdict whether or not a Corruption Offence may have been committed. If they conclude that a Corruption Offence may have been committed the PTIOs refer the matter to an Independent Anti-Corruption Hearing Officer (AHO) and a Notice is served upon the accused. AHOs are appointed by the TIB. Intelligence and information sharing The TIU uses CLUE which is an integrated intelligence and investigation management system. The global remit of the TIU has necessitated use of secure virtual private networks (VPN) to enable 24 hour access to all ITF and intelligence systems. The TIU has a number of MoUs with various betting regulators and operators worldwide. It also has several with different law enforcements worldwide including Interpol and Europol and is able to share information with the UK Gambling Commission by being the recognised entity under Schedule 6 of the Gambling Act The TIU is data compliant and registered with the Information Commissioners Office. It operates to the standard of the Attorney General Guidelines. Inside information and betting by participants The TIU defines inside information as information about the likely participation or likely performance of a player in an event or concerning the weather, court conditions, status, outcome or any other aspect of an event which is known by a covered person and is not information in the public domain. Section D1h: No Covered Person shall, directly or indirectly, solicit or accept any money, benefit or Consideration, for the provision of any Inside Information. Section D1i: No Covered Person shall, directly or indirectly, offer or provide any money, benefit or Consideration to any other Covered Person for the provision of any Inside Information. No Tennis Player, Related Person or Tournament Support Personnel are allowed to bet on any Tennis match and the following offences are created under the TACP. 33

34 Section D1a: No Covered Person shall, directly or indirectly, wager or attempt to wager on the outcome or any other aspect of any Event or any other tennis competition. Section D1b: No Covered Person shall, directly or indirectly, solicit or facilitate any other person to wager on the outcome or any other aspect of any Event or any other tennis competition. For the avoidance of doubt, to solicit or facilitate to wager shall include, but not be limited to: display of live tennis betting odds on a Covered Person website; writing articles for a tennis betting publication or website; conducting personal appearances for a tennis betting company; and appearing in commercials encouraging others to bet on tennis. Education All players are required to undertake and complete the online Tennis Integrity Protection Program (TIPP). This is an educational tutorial in six different languages. This is monitored by a media business company. It is compulsory to complete the program before being able to enter any tournament. The TIU also produces an Information Wallet which as well as listing the TACP has topical questions and answers in a quiz format. These are distributed to players and officials through the governing bodies and national federations. They are currently printed in English but from 2016 will be available in different languages. The wallet contains a QR code which gives access to an online app containing 12 further questions and answers. The TIU presents to groups of tournament officials, tournament directors, players at the ATP University and One to Ones with WTA players. Presentations are also given to Junior Forums twice a year although they are not covered by the TACP before they enter a professional tournament. A new video featuring a convicted player and endorsements from leading players is currently being finalised and will be used for educational purposes. Case studies To date the TIU has had a total of five Covered Persons banned for life and several others receiving shorter suspensions and fines for corruption offences. The TIU operates a strict confidentiality policy and will only comment when an individual has been sanctioned. All results are published on the TIU website. Continual review of integrity strategy Through regular meetings with the PTIOs and the TIB, the Director of the TIU reports on trends and cases of interest and any areas of concern. This in itself generates discussion on current practices and the need for any rule changes. The TIU has also undertaken a self-assessment using outside facilitators to ensure the correct strategies and policies are being used. Other principle challenges to the integrity of tennis Courtsiders responsible for transmitting live data from tournaments have been problematic worldwide. The ATP and WTA employ staff to actually travel to many tournaments and identify such individuals. Each tournament has the responsibility to prevent the continued operation of electronic devices courtside. All courtsiders are placed on a No Credentials List 34

35 and if seen are generally removed by the tournament security. They are served with a Data Protection Notice and details of the TIU privacy policy. The notice also informs them not to attend any tennis tournament and the fact they will be ejected if identified. The TIU liaises with many different law enforcement agencies worldwide and receives a varying response of co-operation. Experience has shown that law enforcement investigations generally prolong the investigations of the SGB. However the standard of proof for the TACP is much lower (Balance of Probabilities) and therefore should the criminal threshold not be met good evidence can be provided to the SGB. 35

36 Greyhound Board of Great Britain (GBGB) Integrity functions To ensure independence of the regulatory function from any commercial influence, incorporated within GBGB but with independent status, is the Greyhound Regulatory Board (GRB) whose key function is to uphold the integrity of licensed greyhound racing. The integrity function of the GRB is undertaken by Integrity and Welfare Services which deal with a variety of investigations into breaches of Rules of Racing, including any betting related corruption. Welfare and Integrity Services is headed by the Director of Regulation and overseen by the Manager of Welfare & Integrity Services. The integrity unit includes: Intelligence Officer Race and Betting Analyst Senior Stipendiary Steward Stipendiary Stewards Sampling Officers Welfare & Integrity Co-ordinators. Live race feed is available via streaming from Satellite Information Services Ltd (SiS) and this is linked to live betting monitoring using both Betfair s Betmon monitoring tool and live betting feeds. Race and betting analysis is both intelligence led and random, and is linked with the drug testing strategy in force at that time. GBGB operates a reporting line and online reporting facility for users to provide the integrity unit with confidential information relating to alleged breaches of its rules. Intelligence and information sharing Intelligence is graded using a 5x5x5 method based on the National Intelligence Model (NIM). Data is stored electronically within a bespoke intelligence module developed by Nintex which includes the necessary functions of a search function, intelligent scanning, workflow process and case file management. Access to documentation is graded in terms of staff seniority and case involvement. GBGB works closely with the Gambling Commission s Sports Betting Intelligence Unit and is confident that that the terms of Licence Condition 15.1 is adhered to by betting operators. The exchange of information between regulatory body and the Gambling Commission is facilitated by Schedule 6 of the Gambling Act. GBGB has in place a Memorandum of Understanding with Betfair and monitors greyhound markets via the use of Betmon. Under the terms and conditions of its privacy policy, and pursuant to the relevant sections of the Data Protection Act 2003, GBGB will share information with other third parties such as law enforcement agencies and other regulatory bodies in the course of discharging its regulatory duties. Inside information and betting by participants GBGB does not have a specific rule relating to the use of inside information, however, any misuse of such information will be deemed a breach of rule 152 (acting in a manner prejudicial to the integrity, proper conduct or good reputation of greyhound racing as regulated by GBGB). It is incumbent upon any licence holder, owner and certain licensed officials to adhere to rules B (betting) which covers the following situations: no betting to take place on any trial 36

37 no licensed official shall make any bets on any race at any racecourse to which he/ she is licensed a trainer to lay any greyhound under his/her care or control a person licensed by the GBGB to lay any greyhound, under the care or control of the trainer for whom he/she is licensed, whilst so licensed and for a period of 21 days after ceasing to be an owner to lay any greyhound he/she owns any other person, who has provided a service or services connected with a trainer s business of training greyhounds and within 21 days of his/her having done so, to lay any greyhound under the care or control of the trainer in question to lose a race with a betting organisation or to instruct any person on his/her behalf to do so or to receive the whole or any part of the proceeds of such an act. Education Licences are issued on condition that each applicant has read and agrees to abide by the GBGB Rules of Racing, and any conditions of licence that may apply. Applicants for training licences are interviewed by a GBGB official as part of the initial inspection process and are examined on their knowledge of the Rules of Racing, including integrity issues. All trainers are regularly inspected by GBGB for compliance with its Rules of Racing and accompanying regulations in force at that time. Trainers will be briefed on relevant rule changes or on trainer notices relating to welfare and the integrity of greyhound racing. GBGB publishes a fortnightly calendar, which is sent to all trainers, licensed veterinarians and officials, which includes industry and regulatory updates and advice to trainers and licence holders. The calendar is also available on the GBGB website. The registered owner of a greyhound must also consent to be bound by the GBGB Rules of Racing when registering a greyhound to race. Additionally, GBGB also issues notices to be displayed in the paddock area at each racecourse. Case studies In 2015, greyhound trainer Christopher Mosdall was imprisoned for four-and-a-half months after being found guilty of cheating, in a case that was prosecuted by the Gambling Commission. Mosdall admitted administering the drug Cyclizine to two dogs between 1 April and 16 April Continual review of integrity strategy An operational review is undertaken quarterly through various committees to ensure certain integrity processes are being followed and are fit for current operational requirements. A review of procedures by the GRB will follow any significant disciplinary case. An annual review of the systems and processes will be undertaken by the disciplinary authority of the GRB. Other principle challenges to the integrity of greyhound racing Greyhound racing is a sport purposely designed for betting and as a result there will always be persons that try to manipulate the integrity of the product for personal gain. With that in mind the main principle challenges to the integrity of greyhound racing are seen as: economics of the sport no control over persons that fall outside GBGB regulations obtaining evidence and linking evidence to licence holders and registered persons developments in doping techniques (globally) and a filtering of substances and techniques from human sport into greyhound racing. 37

38 Professional Players Federation (PPF) education projects As the collective body for the Player Associations in the United Kingdom, the PPF has played a leading role in promoting education for athletes on sports betting integrity issues delivered by the Player Associations. By bringing the Player Association together to share knowledge and expertise, the PPF has been able to help drive the initiation and implementation of sports betting integrity education in a range of sports. In 2010, the PPF started a long running partnership with some of the leading sports betting operators, including Betfair, Bet365, Ladbrokes, the RGA and Betway. This has provided both funding and specialist betting industry expertise for athletes education programmes. Thanks to the support of the betting industry, the PPF has been able to provide funding to the Professional Footballers Association, Professional Footballers Association (Scotland), Rugby Players Association, Professional Cricketers Association, World Professional Billiards and Snooker Association and the European Tour, to support the development of e-learning modules, face-to-face player meetings and educational videos in football, cricket, rugby union, snooker and golf. The PPF has delivered regular tutor training events for Player Association staff with a range of different partners including the betting operators, the Gambling Commission and Interpol. These train the trainer sessions have assisted in the experience and the knowledge of the people who have been educating the players. The Player Association s experience is that players listen to players and where the message is explained in a way they understand and where they are given clear and practical examples. The PPF promotes a strong partnership approach between the Player Associations and their sports governing bodies and professional leagues, as it is believed that this is the best way of ensuring effective education for players. This is reflected in the good working relationships that exist in many sports including cricket, rugby union and English football. The PPF was a member of the original Sports Betting Integrity Panel which produced the Parry Report in 2010 and is now an active member of the SBG and SBIF ensuring that the views of athletes are included within this important policy area. 38

39 Analysis and assessment So far, this report has identified the governance in place within operators plus each SGB and the measures they take to help mitigate the risks in terms of betting integrity. Drawing on this information, it is important to identify the good practice and improvements needed to uphold betting integrity that have been put in place since the publication of the Parry Report and identify areas that require further investment. It should be noted that not all recommendations are appropriate for all sports and that a differentiated approach may be required depending on the nature of the sport in question. Integrity functions A recommendation of the Parry Report was that each SGB should have effective mechanisms in place to ensure compliance with its own rules and have the capacity to investigate potential breaches and impose sanctions. Good practice Many SGBs have demonstrated their compliance with this recommendation and have in place nominated personnel who have responsibility for dealing with betting integrity issues. The various models for handling this are wide ranging. For example some sports have in place a dedicated Integrity Unit, supported by a legal team. Others have a single point of contact for whom responsibility for integrity issues is only part of their role. Some sports have a dedicated Anti-corruption Officer or a cross-departmental integrity group. SGBs have shown further commitment to having the infrastructure in place to deal with betting integrity issues by putting in place dedicated reporting lines and contacts. Operators have evidenced they have objective guidelines in place which they would consider in whole or in part when forming a view as to whether a particular betting pattern was unusual or suspicious. Although many SGBs now have in place dedicated teams or contacts to deal with betting integrity issues, there are still some sports, for a variety of reasons, which do not. This could be due to a lack of resource or being unaware of both the vulnerabilities of their sport to the risks of betting integrity or the support that is available to them. Recommendation: As a minimum, all sports should have in place a single point of contact for betting integrity issues. Details for this contact should be made available to other stakeholders. This would mean that should an incident occur, other stakeholders, such as the SBIU, can alert the sport to the issue and agree an effective and appropriate course of action. Additionally, as well as having robust processes or guidelines in place to recognise unusual or suspicious betting, operators should review these on a regular basis to ensure they reflect the vast sportsbooks that are constantly changing and being provided. 39

40 Intelligence and information sharing Good practice Many SGBs have MoUs in place with other sports, operators and law enforcement agencies (LEAs) enabling the flow of information to be shared. This exchange of information is also facilitated by the virtue of Schedule 6 of the Gambling Act 2005, in which all SBIF members are named. In addition to MoUs, a number of SGBs have dedicated systems in place for the secure storage and analysis of information and intelligence. Some of this software is also used for mapping intelligence and information to produce analytical products, for example timelines of phone billings and betting data. Only a limited number of SGBs have these resources available to them potentially highlighting a gap or area of concern in relation to collecting and analysing information and intelligence. Another example of good practice demonstrated by some operators, is having rules in place in their terms and conditions meaning operators are permitted to share customers data with LEAs and the Commission where they deem it appropriate. Recommendation: That where possible, to maximise experiences and knowledge; SGBs pool their resources and work in partnership to develop and enhance integrity strategies the larger SGBs with the resources available to offer support and share good practice through partnership working (with the acknowledgment that this does happen is some areas) As identified, Schedule 6 does not include all sports and bodies. Schedule 6 lists persons and bodies for the purpose of exchanging information with the Gambling Commission. Although, it may not be not be feasible to include all sports and bodies, a recommendation would be to review the appropriateness and relevance of all current members and potential members to be added to the list. For sports and bodies not currently included on the list, it would be beneficial to consider having terms and conditions in place, similar to that of the operators, allowing bodies to share customers and participants data with LEAs and the Commission. 40

41 Inside information and betting by participants As the previous chapter shows, some SGBs have imposed clear codes of conduct on integrity in sports in relation to sports betting, that includes minimum standards which all sports are to observe and cover in their rules on betting. Good practice Most SGBs have clear rules and definitions in place to deter from use of inside information. Many follow a similar explanation of inside information as information about the likely participation or likely performance of a player in an event or concerning the weather, court, pitch or course, its conditions, status, outcome or any other aspect of an event which is known by a participant and is not information in the public domain. Additionally, a number of SGBs further outline that no person involved in their sport; from players to coaches to officials can directly or indirectly solicit or accept money for the provision of any inside information. Having in place this clear definition which covers all participants in the sport helps deter them from violating any of the codes of conduct in relation to betting through lack of clarity. A number of the SGBs have taken a similar approach in terms of betting on a participant s own sport. As explained in the previous chapter, players and player support personnel are not permitted to bet on any matches or competitions under the jurisdiction of their own governing body. This refers to both directly or indirectly, by encouraging others to place a bet for them. A potential gap in this is that players and player support are only restricted to betting on sports controlled by their own governing body. Recommendations: All sports to implement clear and unambiguous definitions of participants to avoid any confusion as to whether or not they are permitted to bet. Furthermore, SGBs should consider introducing rules that forbid their members to betting on any match, competition or event anywhere in the world extending to the under-18 level, including events outside of the SGBs jurisdiction. The introduction of stringent rules regarding the use of mobile devices in stadiums and player areas is another area of best practice that could be adopted by SGBs. This could potentially alleviate the issue of betting by participants and the use of inside information. 41

42 Education Good practice Those SGBs that are members of SBIF now include betting integrity in players education, either delivered directly or through the relevant Player Association. Examples of this include SGBs requiring their potential members or licence holders undertaking various training on integrity before determining their licences or membership. This often includes attending a seminar on integrity or completing a questionnaire which includes questions relating to integrity. A potential gap that appears in some SBGs approach is that participants are only required to attend a seminar/workshop at the start of the season and regular sessions are not conducted. In addition, some SGBs and Player Associations provide betting integrity education where it is not a mandatory requirement for members to attend. Operators have evidenced good practice in terms of education through identifying key indicators that their integrity teams use as guidance when analysing a market and determining the difference between suspicious and unusual bets. This is further supported by specific drawn up scenarios that can assist the decision making process. Recommendations: SGBs could ensure regular betting integrity sessions are conducted as part of the continual education programme. This could include SGBs or the relevant Player Association providing education sessions which are then continually refreshed and reinforced via targeted messaging at matches and tournaments. Mandatory tests could be included as part of this which would help to demonstrate a player s understanding. This continual education programme should also be a compulsory part of a participants contract or membership. A further recommendation for SGBs is to vary the type of education being delivered and share good practice with other SGBs and Player Associations. One such example is the Mervin Westfield video released by cricket. This video features Westfield who was banned for spot-fixing and warns other players not to follow the same path he chose. This delivery of education is felt to be more effective when delivered by ex-players, as players may be able to relate better. Operators should also provide all employees education regarding LCCP condition and that requires licence holders to supply any information that they know or suspect may relate to an offence under the Gambling Act. This education should not only test if staff have knowledge of what or not to report but also the process of escalation once a suspicious transaction /customer is identified. 42

43 Continual review of integrity strategy There are a number of different approaches SGBs and operators have shown how their sports betting integrity systems and functions are reviewed. The most common theme appears to be holding review meetings on an annual basis. Good practice An approach adopted by some SGBs is that after each significant case, relevant departments 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. Recommendations: For those SGBs that do not encounter any significant cases throughout the year/season a recommendation would be to carry out regular stress tests to determine the robustness of their systems in place, essentially a continual assessment rather than an annual. Additionally, when reviewing integrity strategies, a further recommendation for SGBs and operators would be to liaise with other sports and operators and share best practices between them consequently building their own strategies resilience. This is something that SBIF has already begun to facilitate and must continue to do so through group cooperation. Sharing best practice and using external advice or opinions, could benefit both SGBs and operators as coming from an outside perspective allows more of an objective, bird s eye view of the organisation and the industry as a whole. An external partner may also have faced similar challenges working within their organisation. 43

44 Other principle challenges A number of themes have been highlighted amongst the SGBs and operators in terms of the principle challenges to the integrity of their sports and industry. A significant threat is around organised match-fixing activity involving criminals based in Europe but the activity is coordinated from Asia with money being made in the illegal and unregulated Asian betting markets. Due to the nature of sporting events, markets outside of the SBIU s jurisdiction cause restrictions on how far investigations can progress. This is as a result of implications upon the gathering of key evidence and betting data from the unregulated betting operators - making it difficult to obtain successful prosecutions. Recommendation: SBIU continue to build and maintain working relationships with overseas organisations, such as Interpol and Europol, to enable them to pass on information that may be useful for intelligence gathering by other jurisdictions. Recommendation: SBIF initiate a research study on Asian markets to understand the impacts they pose which could help lead to some possible solutions or further recommendations. An additional principle challenge shared by a number of the SGBs and operators involves difficulties in obtaining data from partner organisations due to Data Protection restrictions. This was mainly due to a lack of clarity in what information could be requested or shared with partners. Recommendation: Organisations to establish an agreed information sharing framework. Having this in place would essentially act as a form of checklist to ensure all aspects of DPA are covered when requesting or sharing information. 44

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