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Establishing the optimum sports betting

regulatory system to protect the integrity
of Indian sports

(/topics/articles/item/establishing-the-optimum-sports-betting-regulatory-system-to-protect-the-integrity-of-indian-sports)
Published 21 November 2018 | Authored by: Kevin Carpenter (/item/kevin-carpenter)
Sports betting is a global phenomenon. Thanks to advances in mobile technology, principally mobile phones, and the
pervasiveness of the internet, online sports betting is one of the world’s fastest growing and most dynamic industries. This
brings with it incredible opportunities economically including vast employment and income to the state from taxation.
However, at the heart of any regulatory system that is adopted has to be the protection of the integrity of sport. Only then will
betting operators, sports and other stakeholders, have faith in a crime-free system which benefits all stakeholders.

India remains one of the largest unregulated sports betting markets. This lack of transparency has partially contributed to a
number of match-fixing and betting integrity issues arising in Indian sport, ranging from cricket and the IPL
(https://www.espncricinfo.com/indian-premier-league-2013/content/story/636375.html)1 (leading to the high profile ‘Lodha
Committee report (https://www.gujaratcricketassociation.com/file-manager/lodha/Lodha_Committee_Report.pdf)’2) and Indian
football (https://www.espn.in/football/minerva-punjab/story/3352401/minerva-punjab-report-match-fixing-approach-made-to-
their-players)3.

However, globally there is a movement by large currently unregulated markets to embrace the inevitable creep of sports
betting, meaning the appropriate regulatory approach (e.g. the United States of America (https://www.legalsportsreport.com
/sportsbetting-bill-tracker/)4), and integrity frameworks, are now at the top of both the political and sporting agendas. These
progressive jurisdictions are in the fortunate position of being able to learn from other countries around the world who have
already put in place effective regulatory and integrity frameworks. Leading countries are objectively viewed to be Great Britain
(England, Scotland and Wales), France and Australia.

This article will set the background by taking a look at the history of sports betting in India, and where we are today, before
briefly set out the approaches taken in Great Britain, France and Australia, the recent Law Commission of India report, and
ending by setting out what the author believes to be the key integrity elements for a successful regulated Indian sports betting
market. Specifically, it looks at:

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History of sports betting in India and shortcomings of the current system of prohibition

Overview of the current law

IPL Probe Committee Report

Supreme Court Committee on Reforms in Cricket

Systems of sports betting regulation around the world

Great Britain

France

Australia

Law Commission of India report

Key elements to a regulated Indian sports betting market

National and state betting regulators

Open licensing system

Licensing condition to report suspicious activity

Establish a specialist sports betting integrity unit

Robust money laundering regulations

The blocking of unlicensed operators

Specific legislation to support the new regulatory system

Final remarks

History of sports betting in India and shortcomings

of the current system of prohibition
Overview of the current law
The federal law in India regarding sports betting is the 150-year old Public Gambling Act 1867, which prohibits public
gambling. Section 12 of this Act provides that the prohibition only applies (https://www.asser.nl/SportsLaw/Blog/post/towards-
a-suitable-policy-framework-for-cricket-betting-in-india-by-deeksha-malik) to a “game of chance” rather than a “game of
skill.”5 This distinction has been tested in the Indian courts, particularly in two Supreme Court of India judgments: State of
Bombay v. RMD Chamarbaugwala [A.I.R., 1957 S.C. 699] and Dr. K.R. Lakshmanan vs State Of Tamil Nadu & Anr [1996 AIR
1153]. In in interpreting the 1867 Act, the Court has decided (https://www.lexology.com/library/detail.aspx?g=6315b42a-
661b-40b7-816c-8c4146dba9e8) that games with the following elements are not “gambling”:

where success depends on substantial degree of skill; and

despite there being an element of chance, there is requirement of application of skill.6

The elements which may mean there is sufficient “skill” involved in a particular game include:

Superior knowledge;

Training;

Attention;

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Experience;

Adroitness of the Player.

Overall, the element of skill must predominate over the element of chance. As a consequence, the test in this regard is called
the “predominance test” or “dominant factor test”.

Despite the federal 1867 Act still being constitutionally valid, since gaining independence in August 1947 (just after the
Second World War), individual states in India have the power to legislate on betting and gambling. However, the regulation of
any kind of sports betting has only happened in one state (Sikkim), and so it is still treated as being illegal throughout the rest
of the country (https://novojuris.com/2017/04/12/development-of-law-related-to-games-of-skill-in-india-focus-on-the-nagaland-
prohibition-of-gaming-and-promotion-and-regulation-of-online-games-of-skill-act-2017/).7

The only exception to the current country-wide prohibition is horse racing, betting on which was made permissible following
the ruling of the Indian Supreme Court in 1996 in the aforementioned Lakshmanan case, where it was said that betting on a
horse race entails evaluating and balancing a number of factors such as the speed of the horse, past performances of the
jockey, etc.

IPL Probe Committee Report

During the sixth edition of the IPL in 2013 ("IPL 6"), Delhi Police arrested three players from the Rajasthan Royals franchise
soon after their match in Mumbai for spot-fixing. Eleven bookmakers were also arrested at that time, including one who was a
former Royals player. The arrests kicked off a nationwide search and arrest of bookmakers. One of those picked up in
Mumbai was a small-time actor, Virender "Vindoo" Dara Singh, arrested on charges of links with bookmakers. However, his
testimony led the police to arrest, Mr. Gurunath Meiyappan, a top official of Chennai Super Kings and son-in-law of then BCCI
president Mr. N. Srinivasan.8

A three-member Committee were entrusted with examining the allegations. As part of the Committee’s Recommendations
(https://www.thehindu.com/migration_catalog/article11476957.ece/BINARY
/JUSTICE%20MUDGAL%20IPL%20PROBE%20COMMITTEE%20REPORT%20%20tilll%20Feb%208)9 they said the
following, “It is most imperative to enact a substantive law making all forms of manipulation of sports, corruption and
malpractices a criminal offence. The law so enacted must be applicable uniformly in the country and should stipulate the
creation of an independent investigating agency, a dedicated prosecuting directorate and a separate judicial forum for
expeditious trials.”

Supreme Court Committee on Reforms in Cricket

Following on from the IPL 6 scandal, various governance scandals arose surrounding the Board of Cricket Control for India
("BCCI"). This led to another Committee being established by the Supreme Court to, “recommend those changes in the Rules
and Regulations of BCCI that will further the interest of the public at large in the sport of cricket, improve the ethical standards
and discipline in the game, streamline and create efficiency in the management of the BCCI, provide accessibility and
transparency, prevent conflicts of interest situations and eradicate political and commercial interference and abuse and create
mechanisms for resolution of disputes and grievances.”10

Chapter 9 of the Lodha Committee’s Report focussed on "Match-Fixing and Betting". The Committee stated that the Indian
legislature ought to legalize betting on cricket, whilst at the same time putting these safeguards in place:

Regulatory watchdogs would be necessary to ensure that the betting houses as well as those transacting there are strictly
monitored, failing which their registrations would be susceptible to cancellation.

The Players, Administrators and others closely associated with the sport would be required to furnish the details of their
incomes and assets for the sake of transparency.

Licenses would have to be issued to those placing the bets as well, with age and identification details recorded.

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Strict penal sanctions would have to be imposed on those transgressing the license and other requirements.

In the final proposals of the Lodha Committee Report, Recommendation 14 addressed sports betting in India and stated, “A
recommendation is made to legalize betting (with strong safeguards)…also a recommendation for match/spot-fixing to be
made a criminal offence.”

Systems of sports betting regulation around the

world
Great Britain
Great Britain is one of the most liberal, and yet highly regulated, gambling markets in the world. Anyone who wishes to offer
consumers in Great Britain the opportunity to bet on sports, regardless of where they are based (i.e. even outside of the UK),
must apply for a licence to do so from the regulator, the Gambling Commission (GC). The areas covered by the licence
application process, in a pure regulatory sense, include:

Having written policies and procedures that explain how the business will meet the following licensing objectives: (i)
keeping crime and disorder out of gambling (e.g. money laundering, match-fixing); (ii) ensuring that gambling is fair and
open; (iii) ensuring that children and vulnerable people are protected from being harmed by gambling; (iv) promoting
social responsibility in gambling.

Demonstrating with the relevant gambling and software technical standards.

An application fee is payable when submitting your application, then subsequent annual fees are due to the GC every year.

All gambling businesses which are successful in applying for a licence from the GC, then have a continuing obligation to
comply with the Gambling Act 2005 (https://www.legislation.gov.uk/ukpga/2005/19/contents) and the GC’s Licence Conditions
and Codes of Practice (https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/LCCP/Licence-
conditions-and-codes-of-practice.aspx) (LCCP).11 There are various parts of the LCCP’s that can be seen to apply squarely
to combating illegal gambling activities and betting-related corruption in sports (https://www.gamblingcommission.gov.uk
/about/who-we-are-and-what-we-do/how-we-regulate-the-gambling-industry.aspx)12, including Conditions as to accepting
"Payments" and "Anti-money laundering". However, the key Condition in this regard is 15.1 on "Reporting suspicion of
offences etc.", in particular:

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When such information is reported by a licensed sports betting operator, it will be fed to the GC’s Sports Betting Intelligence
Unit (https://www.gamblingcommission.gov.uk/news-action-and-statistics/Match-fixing-and-sports-integrity/Sports-Betting-
Intelligence-Unit.aspx) (SBIU), who collect information and develop intelligence about potentially corrupt betting activity
(https://www.gamblingcommission.gov.uk/news-action-and-statistics/Match-fixing-and-sports-integrity/Match-fixing-and-
sports-integrity.aspx) involving sport.13 14

France
Gambling has long been totally prohibited in France, but over the years, several exemptions have been granted, gradually
authorising certain gambling activities. These must be either offered in specific venues or provided by authorised operators
(https://uk.practicallaw.thomsonreuters.com/9-634-4247?transitionType=Default&contextData=(sc.Default)&firstPage=true).15
The online gambling authority, the Autorité de Régulation des Jeux en Ligne (ARJEL) can license operators authorising the
offer of sports betting. ARJEL has full competence to issue licences, enforce online gambling regulations and fight against
illegal gambling websites.

Bets can only be made on certain sports, competitions and types of results, determined by ARJEL following consultation with
the sport federations. The official list is available on ARJEL's website and ARJEL can decide from time to time to add new
competitions or new types of results. Under French law, organisers of sports competitions have rights over the competitions
they organise. Consequently, sports betting operators can only offer bets on the competitions for which they have entered into
an agreement with the organiser of each competition. Any licensed operator requesting one must be offered the possibility to
sign a contract if the operator meets the general conditions set by the organiser. These contracts are reviewed by ARJEL and
the French Competition Authority (Autorité de la concurrence) and must offer similar terms to all operators.

One of ARJEL’s missions is to ensure the integrity of online sports betting operations which can be altered by manipulations
of sports competitions. ARJEL works closely with the French Ministry for sports and the French sports movement
(federations, competitions organizers). Specifically, regarding the prevention, detection and sanctioning manipulations of
sports competitions (https://rm.coe.int/final-report-kcoos-first-study-visit-17-18-january-2017-arjel-docx/168073ed01):

ARJEL implements prevention measures relating to prevention of conflicts of interest, risk

analysis and the betting right;

ARJEL ensures the detection of online betting related manipulation of sports competitions online; and

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ARJEL supports the disciplinary actions of sports.16

Australia
Australia has not embraced online sports betting to same extent as the other two counties already mentioned. The main form
of legislation that covers online gambling in Australia is the Interactive Gambling Act 2001. Sports betting is one form of online
gambling that is legal under the Act (https://www.legalsportsreport.com/australia/).17 Recent amendments
(https://www.communications.gov.au/file/25201/download?token=HfZSMwrL) to the Act now prohibit an organisation providing
regulated online sports betting services to Australian consumers unless the person holds a licence under the law of an
Australian state or territory.18

One important caveat that only services that are licensed by an Australian state or territory are allowed to provide such online
wagering services to Australian customers, is that the provision of online "in-play" betting on sporting events to Australian
customers is prohibited under the 2001 Act. The Australian Minister for Communications has clarified the application of the
"in-play" betting rules to cricket matches, golf tournaments and cycling events that take place over multiple days. The effect of
this determination is that online betting on these events is permitted from the end of play or racing on one day to the start of
play or racing the next day (https://www.acma.gov.au/Industry/Internet/Internet-content/Interactive-gambling/in-play-
betting).19

Regardless of the state in which an online sports betting operator is regulated, they will be required to comply with numerous
obligations relating to integrity. For example, they must report suspicious transactions (https://www.addisonslawyers.com.au
/knowledge/So_you_want_an_Australian_Online_Wagering_Licence__This_is_what_you_need_to_know711.aspx) to the
relevant sports governing body and provide that body with information relating to customers and transactions upon request.20

Law Commission of India report

In July 2016, the Supreme Court asked the Law Commission of India (LCI) to examine whether betting on cricket should be
legalised, and, if so, to frame a law be framed to enable it. The LCI published its report "Legal Framework: Gambling and
Sports Betting including in Cricket in India (https://lawcommissionofindia.nic.in/reports/Report276.pdf)" in July of this year21,
and addressed topics ranging from the history of betting and gambling in India and the constitution of India and betting,
through to the need for regulation.

The starting point for the LCI is to consider the reasons why sports betting is currently prohibited in the country, and balance
this against the arguments in favour of legalising sports betting. Like most democratic governments around the world, the
Indian Government principally prohibits activities such as betting to prevent societal harm (e.g. problem gambling). However,
governmental policy may in the present day not be in tune with existing social values, despite morality and religion having a
significant influence over gambling policy historically.

The LCI recognised the illegal and unregulated betting industry in India, which is extremely difficult to curb/control, is
“rampant”. The consequences that ensue as a result include: match-fixing, “black-money” generation and circulation, and
associated crimes, and overall the reduction of national revenue/funds which the LCI say could be used for public welfare.

Legalisation and regulation would importantly create transparency and ensure the detection of fraud and money laundering.
Opining further on spot-fixing and match-fixing, particularly in India’s most popular sport cricket, the LCI believe that if sports
betting is left unregulated, this corruption in sport could further manifest and grow uncontrollably.

The final part of the LCI’s report are their recommendations. In the context of this article, it is worth quoting paragraphs 9.7
and 9.8 of the LCI’s report in their entirety:

“9.7 The existing policy of the Government (National Sports Development Code of India, 2011, etc.), the current socio-
economic atmosphere in the country and the prevalent social and moral values do not encourage betting and gambling.
Accordingly, the Commission reaches the inescapable conclusion that legalising betting and gambling is not desirable in
India in the present scenario. Therefore, the State authorities must ensure enforcement of a complete ban on unlawful
betting and gambling.

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9.8 An incapability to enforce a complete ban has resulted in rampant increase in illegal gambling, resulting in a boom in
black-money generation and circulation. Since it is not possible to prevent these activities completely, effectively
regulating them remains the only viable option. Thus, if Parliament or the State Legislatures wish to proceed in this
direction, the Commission feels that regulated gambling would ensure detection of fraud and money laundering, etc.
Such regulation of gambling would require a three-pronged strategy, reforming the existing gambling (lottery, horse
racing) market, regulating illegal gambling and introducing stringent and overarching regulations.”

Upon publication, the media focussed on paragraph 9.8, rather than reporting it in the context of 9.7, and the LCI felt it
necessary to publish a clarifying Press Note (https://lawcommissionofindia.nic.in/reports/press-note-6.7.18.pdf) that stated in
clear terms the LCI consider, first that legalising betting and gambling in India is currently not desirable and a complete ban
must be maintained, only then, if that is not found to be possible, should effective regulation be introduced.22

The other recommendation from the LCI which is key to the future protection of the integrity of Indian sports was that match-
fixing and sports fraud should be specifically made criminal offences, with severe punishments.

Key elements to a regulated Indian sports betting

market
By learning from the chequered history of betting and Indian sport, and the well-functioning sports betting regulatory systems
in other countries (as were also considered by the LCI in their report), these are the elements the author believes India should
adopt to maintain the integrity of sports betting, whilst secondary but at the same time, reaping its benefits.

National and state betting regulators

Preferably, subject to the constitutional legislative competence as between the Indian federal government and the states,
there should be an overarching national (federal) sports betting regulator whose duties must include
(https://www.gamblingcommission.gov.uk/pdf/licensing-compliance-and-enforcement-policy-statement.pdf):

licensing operators and key personnel;

setting appropriate licence conditions and codes of practice;

carrying out compliance activities;

enforcement and prosecution work; and

providing advice.23

Due to the size of the country, and nature of how it is run and gambling regulation is currently devolved, it may be preferable
to delegate some of these functions to newly established state regulators.

Open licensing system

Although there should be stringent licence conditions, both upon application and ongoing, there should no restrictions on the
number of sports betting operators that are able to obtain a licence to offer regulated sports betting to Indian consumers.

Equally, there should be no restrictions on the betting types which such licensed operators are allowed to offer. This is
because India is part of what is now a global online sports betting market. Therefore, if India were to adopt the same
approach as Australia (i.e. prohibiting in-play betting), this would simply mean Indian consumers would look to offshore
unlicensed bookmakers and the same spot-fixing risks would remain as have arisen previously.

Licensing condition to report suspicious activity

The effective, efficient and yet secure exchange of information is paramount to ensure the integrity of any regulated sports

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betting market. Therefore, it must be a condition of having and maintain a license that all operators promptly inform the
national regulator when they become aware of any suspicious activity in the betting markets. Equally, licensed operators must
be compelled to operate with the regulator when they request information as part of an investigation.

Establish a specialist sports betting integrity unit

Following on from the obligation to report suspicious information, and the need to exchange information, the national regulator
should play a central role in establishing a national sports betting integrity unit. As a minimum, this should be staffed with
experts from sport, betting and law enforcement.

This would echo closely what the only international convention on match-fixing (https://rm.coe.int/16801cdd7e)24 envisages
as “national platforms”. The National Platform should (in accordance with Indian law):

serve as an information hub, collecting and disseminating information that is relevant to the fight against match-fixing to
the relevant organisations and authorities;

co-ordinate the fight against match-fixing;

receive, centralise and analyse information on irregular and suspicious bets placed on sports competitions taking place in
India, and, where appropriate, issue alerts;

transmit information on possible infringements of laws or sports regulations to public authorities or to sports organisations
and/or sports betting operators; and

co-operate with all organisations and relevant authorities at national and international levels, including national platforms
of other countries.

Currently in India, there is a Sports Integrity Unit (SIU), that was set-up in April 2014 under the Special Crime Branch in India,
but its powers are currently limited (/blog/indian-sports-law/item/how-effectively-is-india-s-new-sports-integrity-unit-helping-to-
tackle-corruption) to conducting investigations and then providing a recommendation to the relevant state.25 However, by
widening it’s remit and capabilities in line with the requirements above, the SIU could become India’s “national platform”.

Robust money laundering regulations

Both the IPL Probe Committee Report and the Lodha Committee Report state that money laundering has been an inevitable
outcome of illegal sports betting in India. In fact, the IPL Probe Committee Report put it strongly as this, “The law must
provide for stringent deterrent punishments, similar provisions as in Section 18 of the MCOCA (Maharashtra Control of
Organised Crime Act 1999) and restrictive bail provisions as in [the] NDPS (Narcotic Drugs and Psychotropic Substances Act
1985) and other similar enactments. This is necessary because influx of hawala money and involvement of terrorist elements
in matter of betting and fixing of sports is causing serious threat to national security.”

Money is the oxygen of match-fixing, and so regulations must be in place to track the money flows from corrupt betting and
ultimately recover the criminal assets, to ensure the long-term integrity India sports and the sports betting market.

The blocking of unlicensed operators

A key factor in ensuring regulation is successful is that the licensed market is protected by preventing unlicensed operators
from gaining access. This will require a variety of tactics to be used (e.g. IP blocking), most of which will be driven by
technology.

Specific legislation to support the new regulatory system

All of the preceding building blocks will require new legislation to be passed. However, with protecting the integrity of Indian
sport being paramount to any future regulatory approach to sports betting in the jurisdiction, other specific provisions must be

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included / laws must be passed to create the most robust and comprehensive legislative framework possible.

Even before the LCI’s specific recommendation, India has initiated the adoption of specific (https://www.prsindia.org/uploads
/media/draft/Draft%20Prevention%20of%20Sporting%20Fraud%20Bill%202013.pdf) provisions (https://164.100.47.4/billstexts
/lsbilltexts/AsIntroduced/4408LS.pdf) related to match-fixing26 27, with best practice being for such law(s) to include:

both the active and passive manipulation of a sport event as the objective elements;

the concept of any undue advantage resulting from the match-fixing offence, be it material (“gift”, “present”,
“consideration”, “allotment”, “material/pecuniary/financial advantage”) or non-material;

the criminalization of both the manipulation of an entire match/event (i.e. match-fixing) and the manipulation of the course
of a match/event (i.e. spot-fixing);

the introduction of civil asset recovery, whereby even if a criminal conviction fails, the proceeds of the corrupt activity can
still be recovered on a the balance of probabilities;

the protection of witnesses and of reporting persons (in accordance with the legal principles of the jurisdiction).

Final remarks
The LCI concluded their recent report by quoting Justice D.P. Madon that “as the society changes, the law cannot remain
immutable” and that “the law exists to serve the needs of the society which is governed by it.” In the author’s opinion, of all the
needs of society, keeping it corruption free is of paramount importance, and therefore the Indian government must change the
law to adopt the measures set out in this article at the earliest opportunity to protect the integrity of Indian sports to the fullest
extent.

References
1 ‘Full coverage of the IPL spot-fixing allegations’, ESPNcricinfo, 2013 https://www.espncricinfo.com/indian-premier-league-
2013/content/story/636375.html (https://www.espncricinfo.com/indian-premier-league-2013/content/story/636375.html)

2 Lodha, R.M., Bhan, A. and Raveendran, R.V. ‘Report of the Supreme Court Committee on Reforms in Cricket [Volume One
– Report & Annexures]’, 18 December 2015 https://www.gujaratcricketassociation.com/file-manager/lodha
/Lodha_Committee_Report.pdf (https://www.gujaratcricketassociation.com/file-manager/lodha/Lodha_Committee_Report.pdf)

3 Selvaraj, J., ‘Minerva Punjab report match-fixing approach made to their players’, Sony ESPN India, 18 January 2018
https://www.espn.in/football/minerva-punjab/story/3352401/minerva-punjab-report-match-fixing-approach-made-to-their-
players (https://www.espn.in/football/minerva-punjab/story/3352401/minerva-punjab-report-match-fixing-approach-made-to-
their-players)

4 ‘Legislative Tracker: Sports Betting’, Legal Sports Report https://www.legalsportsreport.com/sportsbetting-bill-tracker/

(https://www.legalsportsreport.com/sportsbetting-bill-tracker/) [Last accessed 18 November 2018]

5 Malik, D. ‘Towards a Suitable Policy Framework for Cricket Betting in India’, 09 February 2018 https://www.asser.nl
/SportsLaw/Blog/post/towards-a-suitable-policy-framework-for-cricket-betting-in-india-by-deeksha-malik (https://www.asser.nl
/SportsLaw/Blog/post/towards-a-suitable-policy-framework-for-cricket-betting-in-india-by-deeksha-malik)

6 SS Rana & Co, ‘India: It’s not an easy game to play under the Gaming laws’, Lexology, 18 December 2017
https://www.lexology.com/library/detail.aspx?g=6315b42a-661b-40b7-816c-8c4146dba9e8 (https://www.lexology.com/library
/detail.aspx?g=6315b42a-661b-40b7-816c-8c4146dba9e8)

7 Kundu, A. ‘Development of Law Related to Games of Skill in India – Focus on The Nagaland Prohibition of Gaming, and
Promotion and Regulation of Online Games of Skill Act, 2017’, NovoJuris, 04 December 2017 https://novojuris.com/2017/04
/12/development-of-law-related-to-games-of-skill-in-india-focus-on-the-nagaland-prohibition-of-gaming-and-promotion-and-
regulation-of-online-games-of-skill-act-2017/ (https://novojuris.com/2017/04/12/development-of-law-related-to-games-of-skill-

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in-india-focus-on-the-nagaland-prohibition-of-gaming-and-promotion-and-regulation-of-online-games-of-skill-act-2017/)

8 See Footnote 1

9 Mudgal, M., Rao, L.N. and Dutta, N. ‘A Report on the Allegations of Betting and Spot/Match Fixing in the Indian Premier
League – Season 6’, Justice Mudgal IPL Probe Committee, February 2014 https://www.thehindu.com/migration_catalog
/article11476957.ece/BINARY/JUSTICE%20MUDGAL%20IPL%20PROBE%20COMMITTEE%20REPORT
%20%20tilll%20Feb%208 (https://www.thehindu.com/migration_catalog/article11476957.ece/BINARY
/JUSTICE%20MUDGAL%20IPL%20PROBE%20COMMITTEE%20REPORT%20%20tilll%20Feb%208)

10 See Footnote 2

11 ‘Licence conditions and codes of practice (LCCP)’, Great Britain Gambling Commission, 31 October 2018
https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/LCCP/Licence-conditions-and-codes-of-
practice.aspx (https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/LCCP/Licence-conditions-and-
codes-of-practice.aspx)

12 ‘How we regulate the gambling industry’, Great Britain Gambling Commission https://www.gamblingcommission.gov.uk
/about/who-we-are-and-what-we-do/how-we-regulate-the-gambling-industry.aspx (https://www.gamblingcommission.gov.uk
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20 Nettleton, J. and Azzi, J. ‘So you want an Australian Online Wagering Licence? This is what you need to know’, Addisons,
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