Understanding LOTBA's Role: An interview with Ezequiel Domínguez on Gambling Talk

In recent times, the growth of illegal online gambling has grown exponentially at a global level due to massive access to the Internet and mobile devices. Argentina was no exception, despite the fact that in our country Article 301 bis of the Penal Code provides for sentences of up to 6 years in prison.

This year, at the express request of the Head of Government of the City of Buenos Aires, Jorge Macri, the President of the Board of Directors of the Lottery of the City of Buenos Aires, Jesús Acevedo, made the firm decision to move forward and confront the black market of gambling and, in particular, to work on raising awareness and preventing childhood gambling addiction, a problem that affects young people and adolescents.

The message we received from the Head of Government was forceful: NO BETTING AND CHILDREN!

From the City, collaborative work was initiated between the Executive, Legislative and Judicial powers, starting an unprecedented precedent in our country.

Through an agreement between the City Government and the Public Prosecutor's Office, the first Specialized Prosecutor's Office was created to investigate cases related to illegal gambling, headed by Dr. Juan Rozas. This was possible thanks to the work of the Ministry of Justice, headed by Dr. Gabino Tapia, and the Attorney General of the City, Dr. Juan Mahiques.

The results were not long in coming. Less than two months after its creation, investigations related to clandestine gambling were significantly accelerated. More than 30 raids were carried out in coordination with Prosecutor Alejandro Musso, in charge of the Specialized Prosecutor's Office for Cybercrime in San Isidro, where large amounts of money were seized and several people who promoted betting on social networks from the City of Buenos Aires and the Province of Buenos Aires were arrested.

Likewise, we made progress in the signing of a cooperation agreement with the Council of the Magistracy of the City of Buenos Aires, promoted by Councilor Manuel Izura, which includes technical assistance tasks on crimes associated with this activity.

On the other hand, we are working together with the City Legislature to reach a consensus on a bill that meets the current challenges of the gaming industry and, at the same time, we are developing joint actions with various City ministries, such as the Ministry of Education, Justice and Human Development, the Ministry of Sports and the Ministry of Integral Welfare, to carry out courses and workshops that help raise awareness and prevent the various actors in society about the risks associated with illegal online gambling.

Finally, we continue to work jointly with other jurisdictions in the country through the Association of State Lotteries of Argentina (ALEA) chaired by Dr. Ida Lopez, being able to sign important public and private agreements in order to mitigate illegal gambling.

As a result, between January and September 2024, the following were achieved:

• Blocking of access to illegal online gambling sites in schools/BA WIFI network: 1,291
• Blocking of websites (ALEA / NIC Argentina): 18
• Blocking of websites by ENACOM TOTAL: 465
• Blocking of websites by court order to ENACOM: 371
• Blocking of websites by court order of complaints made by LOTBA: 2
• “.com.ar” websites reported to ENACOM for blocking: 92

Blocking social media profiles and advertisements (Instagram and Facebook – ALEA/META Agreement): 1,124

• Removing posts from Mercado Libre (ALEA/Mercado Libre): 14
• Sending Document Letters to influencers + cases reported to the courts: 18
• Firm AJL sanctions: 6
• Complaints filed for illegal Physical Gambling: 13

1. Can you tell us about your journey and how you became involved with LOTBA?
   
   

One of the functions I perform as a full member of the LOTBA Board of Directors is to actively contribute to the development and implementation of strategies aimed at combating illegal gambling and protecting the integrity of regulated recreational activities, promoting a safe and transparent gambling environment.

Illegal gambling has mutated strongly in recent times and the way of attacking it, as was done a few years ago, is long gone. Today we need the commitment of all the actors that make up the gambling industry to be able to confront it.

As a member of the Board of Directors, I have the honor of representing LOTBA at the SBC Summit Latin America 2024 and speaking on topics that go in this direction: “Restricted access: strengthening regulation against illegal online betting sites” and “Addressing the black market in recently regulated jurisdictions” proposed by IMGL. It will be a pleasure to share with my fellow panelists and conference attendees the actions that we are carrying out from Lotería de la Ciudad, as a regulatory body, regarding this problem.

2. How does LOTBA ensure the integrity and transparency of its operations?
   
   

LOTBA implements a supervision and control program to ensure that online gaming agencies operate in accordance with established regulations. This supervision process is carried out through several integrated strategies to ensure transparency, security and responsibility in the online gaming sector.

• Periodic Inspections of online gaming agencies: designed to verify compliance with current rules, standards and regulations. During these inspections, inspectors examine various operational, functional and management areas of the platforms to ensure that gaming activities are carried out fairly and in accordance with the law.
• Certification of Conformity by International Laboratories: we require online gaming agencies to obtain and present certifications of conformity issued by recognized international laboratories. These certifications must demonstrate that the gaming platforms comply with the specific technical standards of the City of Buenos Aires.
• Certification ensures that gaming software, security systems and other technological components comply with international quality and security criteria.
• Compliance Audits: In addition to inspections and certification, LOTBA may also require compliance audits conducted by independent third parties. These audits are aimed at thoroughly reviewing the agencies' operating systems, internal controls and financial records to detect any possible deviation from applicable regulations.
• Periodic Reports and Continuous Communication: Agencies are required to send periodic reports to LOTBA S.E., detailing their operations, incidents and any other relevant aspect that may affect their compliance with the law.

Through these measures, LOTBA ensures that the online gaming environment in Buenos Aires is safe, fair and in compliance with established standards, thus protecting the interests of players and maintaining the integrity of the sector.

3. What measures are in place to prevent money laundering and other illegal activities in the lottery sector?

First of all, it must be said that Argentina has been a full member of the Financial Action Task Force since 2000. The country has committed itself almost 25 years ago, with the international community, to apply the FATF standards.

Within this framework, the Buenos Aires City Lottery is Obligated to collaborate with the Financial Information Unit, the national governing body in this area.

In this regard, LOTBA has established a policy for the Prevention of Money Laundering and Financing of Terrorism, which has a Compliance Officer. I had the honor of being appointed to this position in May, as a member of the Board chaired by Jesus Acevedo, responsible for this policy. In addition, there is a permanent area dedicated to its application and development.

Among the most important aspects of this policy, a periodic evaluation of the risks inherent to our commercial activity is carried out, applying the concept of the “Risk-Based Approach” (RBA) recommended by the FATF, in order to ensure the most efficient application of resources.

Specific typologies related to our products have been identified, and mitigation actions have been developed for the risks detected.

Likewise, significant resources are invested in developing technological tools that accompany control tasks, such as automated alert systems, market behavior analysis, detection of unusual operations that deviate from the uses and customs of the activity.

Furthermore, important tasks of training, dissemination and training of staff and the sales network are carried out, in the understanding that this topic must be integrated in a transversal way to all the activity developed by the institution.

In turn, the entire AML/FT policy is subject to internal and external audits, in order to make the corresponding observations and corrections.

And finally, it is worth noting that, as a national reference body, we maintain permanent contact with the Financial Information Unit and carry out important institutional activity in the sector, coordinating and collaborating with the different lotteries in the country through the Argentine State Lottery Association (ALEA) and, also, at an international level with the Ibero-American lotteries within the framework of the Ibero-American State Lottery and Betting Corporation (CIBELAE).

4. Can you share some insights into the recent initiatives or campaigns LOTBA has launched?

LOTBA is a State Company whose function is to administer, regulate and control gambling in the City of Buenos Aires.

That is to say, on the one hand, we authorise and monitor legal gaming operators, requiring them to comply with the most demanding regulations and quality standards at a regional level, to ensure that they promote gaming in a safe, healthy and transparent manner. And, on the other hand, we combat illegal gaming, which, precisely because it does not comply with any type of requirement, is what encourages the growth of the black market, clandestine betting and prohibited practices such as access to gambling by minors.

Considering that today the growth of child gambling addiction is an alarm that has been raised globally, we developed the communication campaign Hablar es Ganar, which was launched massively this year with the aim of making this problem visible, putting it on society's agenda and preventing it by raising awareness among young people and adults.

“Talking is winning” promotes dialogue and awareness to work on prevention from a comprehensive and interdisciplinary approach. The campaign targets parents, educators, tutors, families and the community in general with messages such as: “If you think your child is gambling, bet on dialogue”, “If you bet illegally, you always lose” and “Don’t take the risk”.

In this framework, we do strong training work thanks to the quality of human resources that are part of our organization, with strategic partners such as the Ministry of Education, Health, Sports, Human Development and Habitat, Justice, among other areas of the City Government, so that the results are effective and involving all the actors that are part of this campaign (families, teachers, sports clubs, etc.):

This action includes awareness and prevention workshops for students in schools and families, as well as in summer camps. We also participate in initiatives such as the Dialogando Buenos Aires program through the Secretariat of Government and Citizen Relations headed by César Torres.

Between January and September of this year:

• 55 workshops were held
• 370 families were reached
• 6159 students/adolescents were reached
• Access to online gambling sites was blocked in 1770 schools

5. What initiatives has LOTBA implemented to promote responsible gambling among players?

First of all, I would like to mention that this year, LOTBA certified the WLA Responsible Gambling Level IV; an achievement that ratifies the commitment assumed with the Principles of Responsible Gambling and demonstrates the continuous effort in the promotion and implementation of initiatives aimed at promoting the values ​​of responsible, safe, legal and healthy gambling throughout its community.

At LOTBA we promote responsible and healthy gambling through the development of various actions, among which the following stand out: awareness campaigns and workshops aimed at different audiences; the execution of research studies; the development of guides for teenagers, families and educators; and general recommendations on the use of technology.

Regarding online gambling, LOTBA developed a responsible gambling standard that ensures that authorized platforms respect the principles of responsible gambling. These principles include a registration process that verifies the age of bettors and prevents the entry of minors; the possibility of performing an online self-exclusion; the establishment of time limits, deposits and/or losses; the implementation of a time-out button; the receipt of alerts about the passage of time; as well as limitations on economic transactions and advertising.

This year, and in light of the reality that young people are going through, LOTBA launched its program 'What's at stake', aimed at addressing the use of technology and gambling in adolescents. Through its campaign 'Talking is winning', this program seeks to raise awareness about the responsible use of technology in order to prevent problematic behavior related to online gaming and gambling. In addition, it focuses on educating about safe and legal gambling, including preventing minors from accessing gambling, promoting responsible gambling, identifying problematic behavior and collaborating with the community to promote a safe internet environment for young people, as well as applying effective prevention measures.

Finally, I would like to highlight that LOTBA conducts a monthly survey and sends lists of URLs to allow the blocking of gaming sites in public and private schools, as well as in concession areas, with the aim of minimising access to such content in these areas.