Former Irish Fraud Chief Advises Against Proposed Stake and Prize Limits

A former senior police officer in Ireland has warned the inclusion of stake and prize limits into the nation’s proposed Gambling Regulation Bill which could lead to a rise in black market betting and other significant implications for online casinos.

The Gambling Regulation Bill was introduced in December of 2022 and is looking to update the antiquated statutes governing Ireland’s growing gambling market. The draft legislation was ratified by Ireland’s 160-seat lower house, the Dáil Éireann, in May and could well be passed by its 60-member Senate as soon as Wednesday. 

Anticipated Alterations 

As written, the proposed bill would revise the country’s current licensing structure, establish the Gambling Regulatory Authority of Ireland watchdog and introduce new rules on advertising. Other sections of the Gambling Regulation Bill are to result in the creation of a remote gaming and lottery licensing program alongside a national self-exclusion register and a scheme to help fund problem gambling initiatives.  

However, one of the Gambling Regulation Bill’s most controversial sections would place a €10 ($10.92) maximum stake limit on slot games, private lottery draws, and live table contests such as blackjack and roulette while simultaneously pegging top cash prizes at €3,000 ($3,270). This provision, which would not impact the Irish National Lottery or sports betting, has attracted criticism from operators worried the updated rules could hurt their businesses as punters abandon traditional venues in favor of more lucrative contests run by offshore outfits. 

Conspicuous Critic 

A past Detective Chief Superintendent in charge of the Garda National Economic Crime Bureau, Pat Lordan, has now added his voice to the club protesting against the Gambling Regulation Bill’s proposed stake and prize limits. The experienced anti-fraud supremo told the Irish Independent that enforcing such restrictions could increase the popularity of the black market and place even more strain on the resources of local law enforcement agencies. 

“If the figures as they currently are remain in place, I think we run the risk of pushing some gambling to an unregulated market where we will have no visibility,” Lordan said.​ 

Lordan served as the lead local representative during the Financial Action Task Force’s 2017 review into Ireland’s anti-money laundering and counter-terrorist financing measures. He told the newspaper that ‘overregulating’ the gambling industry could furthermore encourage criminal networks to establish sophisticated underground markets that would be difficult to police. 

“It is resource intensive if you have to go to every casino in the country that is legal and not legal because they are not going to have a sign over the door,” Lordan said. “It will fall back to Johnny the guard down in Dingle to go out on his pushbike and see if there is any gambling there in the shed of a house.”  

Critical Consequences 

Lordan went further in asserting the implementation of the Gambling Regulation Bill’s proposed stake and prize limits could additionally lead to a rise in money laundering as offshore operators are often not subject to stringent and enforceable anti-fraud regulations.  

“The Financial Action Task Force guidelines over the years said you should not overrestrict legitimate business and that there should be a proportionate approach towards managing risks,” Lordan said. “The risks here are around money laundering but is it proportionate to say the biggest bet you can have is €10? I don’t think so.” 

Adept Assessment 

In voicing his criticism, Lordan joined a group that already included Debbie Lawrence, Chief Executive Officer for local casino operator Carlton Entertainment Group. The lead figure behind Dublin’s Carlton Casino earlier told the Irish Independent that the proposed stake and prize limits contained within the Gambling Regulation Bill would render live table games such as baccarat, poker, blackjack, and roulette unviable and make it almost impossible to stage international tournaments. 

“When you are on a table, depending on the games, there will be five to eight people playing,” Lawrence said. “If you have each person playing the maximum of €10 per person, that means you have €50 to €80 placed on each hand. The hands are much slower than slots because people have to work their way through the game. It is a much slower process.” 

Lawrence advised the Irish government to give the proposed legislation more time by allowing the Gambling Regulatory Authority of Ireland to consider how different industry sectors are to be managed. Not doing so, she warned, could see her company make as many as 60 people redundant. 

“I have 60 staff I will potentially have to let go because the running costs will not cover what we are making,” Lawrence said.