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Cryptocurrencies & Gambling

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Cryptocurrencies & Gambling


Allowing players to wager with cryptocurrencies

has proved to be an alluring idea for gambling

companies in all corners of the world, but

regulators have, for the most part, been

predictably cautious to wholeheartedly embrace

a form of payment which promises freedom from

government control.

With many cryptos also beset by massive

fluctuations in value and an association with illicit

dark web activities, the future of cryptocurrencies

in gambling is as complex as the technology that

underpins them.

What are cryptocurrencies?

Cryptocurrencies are digital or virtual assets. They

can be used on platforms that rely on advanced

cryptography to ensure secure transactions by

preventing counterfeiting and double-spend.

Why are operators considering using them?

Using cryptocurrencies to gamble offers operators

numerous opportunities, and new gambling

products and regulations have been established as

a result of the underlying technology.

Already, offbeat unregulated casinos that exist on

the blockchain are processing millions of dollars per

day in crypto-based transactions.

Freedom from any central bank means fewer fees

to pay and should, in theory, make the process of

deposits and withdrawals lightning fast.

Off the chain … and on the chain

Off-chain cryptocurrency gambling refers to

online as well as land-based casinos accepting

cryptocurrencies into a virtual casino account. The

cryptocurrencies can then be exchanged via a third

party into a local national currency, often referred to

as “fiat currency”.

In contrast, on-chain transactions rely on blockchain

technology to facilitate a gambling transaction using

smart contracts, where “a program enforces the

contract built into the code”, according to a 2018

U.S. Senate report.

Decentralised and centralised

On-chain transactions take place on a blockchain

using numerous smart contracts, which rely on

decentralised networks. These are known as

decentralised applications or DApps.

As decentralised networks do not rely on a single

server, the risk of being overwhelmed by internet

traffic is removed, ensuring high-speed internet

connections. However, running a decentralised

network can be costly due to the large amounts of

computer processing they require to operate.

This disseminated system is also designed to be

safer than a traditional network; however, in theory,

if one group gains more than 50 percent of control

over the decentralised servers then it can gain

complete control over its functions. Cryptocurrency

exchange Binance confirmed in May 2019 that

leading cryptocurrency identities considered

orchestrating a wholesale “rollback” of the Bitcoin

blockchain in a move that would have erased days

of spending and allowed crypto-gamblers to reclaim

lost wagers.

Existing and upcoming regulation

The gambling industry appears to be at the forefront

of cryptocurrency regulations, due in part to its

popularity with tech-savvy gamblers. Despite

this, the regulation of cryptocurrencies is still very

much in its infancy compared to other areas of the

gambling industry.

In 2017, the Isle of Man began to offer licences

to crypto-betting operators and skins betting

operators. Crypto-betting operators Unikrn and

Luckbox received their licences in 2018 and 2019,

respectively.

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The Malta Gaming Authority (MGA) has also made

inroads into regulating the use of cryptocurrencies

in gambling. Its regulation is now in its second

“sandbox” phase.

The Gambling Commission in the UK advises

consumers to be cautious when using digital

currencies to gamble due to what it sees as

associated risks:

» There is no central authority that supports the

value of digital currency (Bitcoin, for example, has

a history of large price fluctuations).

» There is a history of hacking, theft and other

criminal activity associated with digital currencies.

Other international regulators, such as in South

Africa, have also expressed a desire for future

regulation on the use of cryptocurrencies in the

gambling industry to ensure its proper supervision.

Cryptocurrency regulatory risks

Some regulators see the security and decentralised

appeal of cryptocurrencies as a risk to money

laundering, terrorist financing and know your

customer (KYC) checks and the verification

procedures they already have in place.

“The issue with cryptocurrency is people want

to have anonymity talking about payments and

payment sources,” said Louis Rogacki, deputy

director with the New Jersey Division of Gaming

Enforcement (DGE).

“It’s the anonymity that right now is causing a

problem and anything we do concerning payments

from a regulatory standpoint, we are going to be

guided” by the U.S. Department of the Treasury’s

Financial Crimes Enforcement Network (FinCEN),

anti-money laundering regulations and our

department of banking, he added.

Since at least 2017 there have been numerous

gambling products running on a blockchain,

and although some have made inroads in to the

traditional online gambling market, many exist a

world away from the regulated sphere.

These bootstrap outfits are not built by online

gambling incumbents, but crypto specialists with

little regard for regulation.

Many financial institutions also remain highly

cautious about the use of cryptos for payments of

any kind and for the most part do not consider them

to be of equal practical use to fiat currencies.

Sweden’s central bank in March 2018 said “cryptoassets

or cryptocurrencies are not the same thing as

money. This is because these assets lack an official

issuer and because at present, they do not meet

the conditions required of an efficient means of

payment.”

In 2019, a research report from blockchain

analytics firm Elliptic found close ties between

cryptocurrencies traded on the dark web and money

laundered through online gambling sites.

U.S. Treasury’s FinCEN director Kenneth Blanco

said U.S. casinos facilitating cryptocurrency

transactions fall under the authority’s remit, urging

them to enforce the same controls applicable to

money services businesses.

Where are they banned?

According to the Library of Congress, trading or

using cryptocurrencies has already been banned

in eight countries: Algeria; Bolivia; Egypt; Iraq;

Morocco; Nepal; Pakistan; and the United Arab

Emirates. An “implicit ban” applies in Bahrain,

Bangladesh, China, Colombia, the Dominican

Republic, Indonesia, Iran, Kuwait, Lesotho, Lithuania,

Macau, Oman, Qatar, Saudi Arabia and Taiwan.

3


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Authors: Harrison Sayers, Douglas Clarke-Williams

Editors: Joe Ewens, Louise Coleman, Hannah Frost

Disclaimer

This report has been created by VIXIO GamblingCompliance,

a product of VIXIO Regulatory Intelligence. Information

contained within this report cannot be republished without

the express consent of VIXIO GamblingCompliance.

VIXIO GamblingCompliance does not intend this report

to be interpreted, and thus it should not be interpreted,

by any reader as constituting legal advice. Prior to relying

on any information contained in this article it is strongly

recommended that you obtain independent legal advice. Any

reader, or their associated corporate entity, who relies on any

information contained in this article does so entirely at their

own risk. Any use of this report is restricted by reference to

VIXIO GamblingCompliance’s terms and conditions.

© Compliance Online Limited (trading as VIXIO)

Image: © Liu Zishan/Shutterstock

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