As the world of iGaming continues to grow with increasing popularity and with exciting new content and features being released almost daily for casino, sports betting and other product verticals, those of us in the responsible gaming space are often asked, “Well, which has more safeguards to protect consumers: Land-based casinos or iGaming platforms?” I think the answer is both. Although this may seem like an elusive answer, in truth, having seen all sides of the very scrambled Rubik’s Cube for responsible gaming, I only see a desire to bring all six sides together and find uniformity, which is the same goal of solving a Rubik’s Cube. Several critical parts make up the industry’s responsible gaming cube: 1) the consumer; 2) the consumer’s family and loved ones; 3) regulators who write the overall rules to protect consumers and their families; 4) operators who must adhere to, or exceed, the regulations set out to protect consumers and their families; 5) the vendors and content designers who make the products and provide RG tools and other services for operators to use; and 6) the problem gambling research institutions, advocacy groups, and problem gambling councils.
Both online and brick-and-mortar share many similarities in requirements and standards for responsible gaming. The following table summarizes some standard regulatory requirements for marketing and advertising, self-exclusion, cools-offs and limit-setting, and the promotion of jurisdictional helplines and local resources.
| Regulation | Casino Requirement | iGaming Requirement |
| Overall Plan | X | X |
| RG Plan with the goals of the plan, procedures, and timetables to implement the plan | X | X |
| Individual(s) who will be responsible for the implementation and maintenance of the plan | X | X |
| Employee Training | X | X |
| Commitment to train employees and annual reinforcement training | X | X |
| Certification process to verify completion of required training and annual reinforcement training by employees | X | X |
| Duties and responsibilities of employees designated to implement and participate in the plan | X | X |
| The responsibility of players, including their right to impose limits, suspension and self-exclusion | X | X |
| Procedures to identify players and employees with suspected or known compulsive and problem gambling behavior | X | X |
| Procedures for employees to report suspected or identified problem gambling behavior | X | X |
| Procedures to keep the identity of an individual suspected of problem gambling confidential | X | X |
| Procedures to monitor all game play for suspicious activity | X | X |
| Marketing and Advertising | ||
| Plan for prominently posting the Problem Gambling Statement | X | X |
| Procedures for preventing certain persons from being mailed marketing materials | X | X |
| Plan for the accessibility of the responsible gaming resources | X | X |
| Procedures for posting, reviewing and updating information on the responsible gaming webpage | X | |
| Plans for posting statements, rules, links and documents on the registered player protection page | X | |
| Procedures relating to promotions and advertising | X | |
| Informed Decision Making | ||
| Procedures for responding to registered player requests for information | X | X |
| Procedures on governing of self-imposed limits | X | |
| Details of outreach and local problem gambling programs offered | X | X |
| Provide Problem Gambling help line | X | X |
| Underage Play Prevention | ||
| Procedures to prevent underage individuals from participating in gaming and related activities | X | X |
| Self-Exclusion | ||
| Procedures to prevent excluded persons from participating in Gaming and related activities. | X | X |
| Resources available for those seeking more information | X | X |
*Not a comprehensive list
As the table demonstrates, there are more similarities than differences as it relates to complying with responsible gaming regulations regardless of being online or in a physical location. The biggest differences, however, are in two areas: the ease and accessibility of problem gambling resources for customers, and how problematic play is identified based on visual cues vs. verbal/written cues.
When it comes to visual contact with customers, the brick and mortar casinos and retail operators have the advantage. The customer is physically present and can be observed by casino employees in various roles. Behaviors such as perspiring, exhaustion, overdrinking, and other signs of increasing agitation are more evident in person, therefore giving trained employees the opportunity to intervene with an appropriate response. Brick-and-mortar and retail sportsbook employees may also have the advantage of knowing the customer’s backstory and having a more personal connection, making it easier to spot at-risk behavior based on their ordinary actions. However, not all customers’ identities are known to the employees and not all betting activity is tracked and auditable like it is for iGaming. In the terrestrial casino operation, customers can and many choose to remain anonymous with their betting activity untracked.
In the online gaming space, all customers are identified as they must go through rigorous “know your customer” (KYC) review before an account can be established for play. Once registered, every transaction initiated by the player, deposits, wagers, and withdrawals, are tracked to that player. Thus, the online operator knows every transaction for every player, but is not able to see the player or pick up on clues that require visual identification.
Recognizing that the land-based casino and the online gaming operation are armed with different means for identifying markers of problem gambling harm, they are aligned in using efforts to assure player protection. Below are high-level descriptions of some of the common tools that brick-and-motor casinos/sportsbooks and online gaming operators use.
Underage Play Prevention & Self Exclusion
Casinos can physically check ID prior to someone entering the casino floor. If the person is underage, doesn’t fit the description of the ID, or is self-excluded or banned, their entry is prohibited. For iGaming, this is achieved at initial contact with a customer seeking to establish an account through the KYC process. In this scenario, instead of a physical gatekeeper, there is technology in place to ensure identity and self-exclusion status. It should be noted that both sides also have compliance and AML teams at work who execute due diligence ensuring other safety protocols are in place.
Employee Training
Whether an employee represents an online operator or works in a physical location, employees must be trained and periodically retrained to ensure they understand and can identify the warning signs of problematic play and markers of harm. E-learning companies such as iGaming Academy have several offerings operators can choose from to support employees working in either environment.
Advertising, Helplines, Limit Setting, and Self Exclusion
All operators must adhere to advertising guidelines in every jurisdiction. Customers must generally be offered information to help them opt-out of receiving future advertisements, be better informed about options to self-regulate their play, offer a helpline number for those who need help with their play (or that of a loved one), or restrict their play for a while or indefinitely.
In the casino/retail sportsbook environment, this information is generally found within the facility in the form of brochures, posters and signage, tv monitors, and trained responsible gaming ambassadors on the floor. A good showcase of this can be found in Massachusetts through the Game Sense and Play My Way Program.
Online operators also provide these resources but they are offered digitally and through customer care teams. Online operators are required to have dedicated pages on their gaming mobile app and website, and customers must always be able to access opt-out information for marketing, a toll-free helpline number, any electronic brochures available, limit-setting options (daily, weekly, monthly), and self-exclusion with any direct links associated with accessing information in that jurisdiction.
At Rush Street Interactive, we strive to offer the best responsible gaming measures available for our online BetRivers and PlaySugarHouse brands. All RSI employees are educated on the importance of responsible gaming and our customer service team is well-equipped to provide the best possible customer service and care via live chat, email and phone communications. Like others in the industry, RSI customer service agents have great relationships with their customers. The difference is that online customer service agents do not have the aspect of visual contact. Their responsible gaming markers of harm are focused primarily on real-time verbal or written cues that demonstrate the same at-risk behaviors identified at brick-and-mortar locations. Some operators also have the benefit of machine learning to help better inform them of their players activities. Among other things, with the help of individualized data, operators can see patterns and frequency of play, and times of play, then make an assumption about the customer based on clearly outlined markers of harm.
In an effort to utilize technology to enhance the ability to better identify markers of harm, RSI has partnered with Austrian-based Neccton to deploy its mentor solution to help determine preventative strategies that can best mitigate problematic play. Using data is a great benefit to the online space. Since customer service agents do not have the benefit of having the person in front of them, they must be hyper focused on what the customer is saying, writing or doing. This in turn, should yield the same response as it would in a casino environment: immediate action. In the casino environment at-risk situations can lead to security being called and the customer being escorted off the property immediately. For online, the next actions may include everything from the customer service agent triggering additional responsible gaming information to be sent to the customer, flagging a customer’s account for review, contacting the customer directly, all the way to suspending a customer’s account access until further review.
Ultimately, whether land-based or online, gaming operators are generally engaged in best practices and following standards to ensure compliance with regulations and the protection of consumers and integrity across the industry.
Whether its online or in a casino/retail sportsbook environment, when it comes to responsible gaming safeguards, operators who believe that a happy customer is a healthy customer will always provide top-of-the-line responsible gaming solutions that meet their business objectives and company values. RSI’s commitment is evident. Our employees and leadership share the mission to prioritize the protection of those who are vulnerable to gambling problems and others who may be impacted by their behavior. We will continue to provide our players with new, user-friendly experiences, tools and resources to help them Bet Smart. Bet Fun. Bet Rivers.
