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“We feel that people are always interested in gambling and that we are the party who should offer that in a safe way. [Holland Casino] has been careful to maintain that, but of course our costs rose very quickly, so we restructured at our head office. We have also been looking at innovations in offerings, which we are currently also testing, including a further development of the Next Zone. We’ve also introduced the double zero in roulette, which we didn’t have previously in the Netherlands,” the CEO says.

“Obviously, in the gaming industry we don’t have a price tag on our product where you can just change the RTP (return-to-player) and your problem is solved, it doesn’t work like that. Especially not if you take responsible gaming seriously.”

Speaking of which, in Holland the casinos must have two databases, one for online players, one for land-based, and keep them very separate – except for when it comes to responsible gambling (RG). A casino can’t use its online offering to promote the land-based side to players, and vice-versa – but the data can all be used together to make sure customers are safe from harm whenever they play with the same operator, online or otherwise.

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The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.

“We had various iterations of the drafts internally probably going back at least a decade, and just never made it to the finish line for various reasons,” he explained.

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One such rule was for licensees that had faced compliance enforcement during the five years operating in the Netherlands.

At the time KSA announced: “Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.” 

This requirement raised concerns among operators worried that the barriers to entry could have become more restrictive, But at a meeting on the policies last year the regulator assured licensees it was not enforcing a specific strict rule on this.