eLBA was co-founded by five leading lotto betting operators, namely Legacy 8, Lottogo, Lottoland, Multilotto and myLotto24.
Why did you set up eLBA?
eLBA has been set up to offer the industry a collective voice. Our main aim is to create more regulated opportunities for lotto betting, which takes account of customer protection and social responsibility. We want to dispel the misunderstanding surrounding the industry and foster closer working relationships with European regulators
What values do you aspire to?
eLBA encourages ethical business practices, social responsibility and initiatives to combat problem gambling. eLBA will especially look to engage and combat minors gambling.
What are the myths and untruths?
The sector is often described as unregulated and often accused of not having the right customer protection measures in place or undermining national lotteries. That’s not true. We’re not “parasites” nor are we to be considered “black”/”secondary” lotteries, we’re a legitimate betting product that offers betting on the outcome of live events; our live event is international lotteries. Additionally, we are regulated, licensed and have thorough consumer protection and fraud prevention programs in place. Furthermore, there is no evidence to support the claim that we are having a significant impact on sales in Europe or returns to “Good Causes”. Finally, there is no truth in the claim that we have failed to pay out a genuine winner – we all have robust insurance models that have been tried and tested.
Are you doing this because countries like Australia are cracking down and changing legislation to stop you operating?
No, eLBA was not set-up as a reaction to what has happened in Australia. Australia’s had an impact on the sector, of course, and the general tone and language coming out about lotto betting in the media is misperceived. But it is not the reason why eLBA was set up. eLBA’s role is more comprehensive. We want to dispel myths about lotto betting and create better relationships with regulators to show this is a mainstream betting product which requires proper regulation, not prohibition which simply drives customer interest to unregulated offerings.
Where will your focus be?
eLBA’s has identified certain jurisdictions as of priority status but we will focus on all of Europe as a general rule. However, the main objective is not geographic, but to ensure the availability of licensing for betting on lotto as a gambling product.
Are you going to set targets?
eLBA’s founding members are currently working towards a common programme of activity aimed at establishing betting on lotto products in unregulated jurisdictions.
Do you give to good causes?
There have been misleading comments about lotto betting operators impact on lottery giving. Taking the UK as an example, according to a National Audit Office report earlier in 2018, there is no evidence to show that lotto betting takes money away from the National Lottery. Lotto betting operators (much like other betting operators) voluntarily engage in CSR projects, not because they are compelled to by law. The betting on lotto industry actively participates and has a strong corporate responsibility footprint.A few examples illustrate well the engagement of eLBA members: 1) the Irish Red Cross and Lottoland recently sealed a partnership deal to raise money to ensure the digitalization of all reporting and traditional paper-trail administration for the Irish Red Cross’ entire fleet of 130 emergency ambulances and 2) Mylotto24 has been supporting the London Community Foundation and through them set up the Good Neighborhood Fund. Mylotto24 has supported 13 small projects and charities in London who are tackling projects such as retraining women, food banks and projects encouraging social cohesion. Resulting in the provision of support for nearly 2000 Londoners to date. The above examples (non-exhaustive) clearly show eLBA members give back and contribute significantly to society by creating jobs and further investing in advertisements example.
Will eLBA help you in situations similar to the recent ASA incident?
The industry has been hit from a number of angles we want to learn from. That’s something we’re working on, we’re trying to make our messages more prominent and clear when communicating to customers. Operators take these responsibilities seriously as part of their licensing requirements. eLBA will also look to engage more thoroughly with relevant government bodies in order to assess if operators could go beyond the requirements of their licensing agreements. Finally, members of eLBA will focus on fostering inter-sectoral exchanges in order to facilitate the improvement of the industry as a whole.
Will other companies join the eLBA?
We hope so!
How big is the betting on Lottery market?
There is no readily available aggregate data on the actual size of the betting on lotto market. In In the long term eLBA will attempt to bring more clarity to the numbers.
How will the group ensure pay-outs?
The insurance-backed betting model is a sophisticated, robust and proven model. Each individual operator relies on a proprietary insurance model. Pay-outs are not an issue for the industry. As a matter of fact, two of eLBA’s members (Mylotto24 and Lottoland) have been responsible for two of the biggest pay-outs. €48 million in May 2015, in Germany and €90 million in Germany in June 2018 respectively. There has never been a case of non-pay-out where the winner was verified.
What is the code of conduct and when can we see it?
The code of conduct is meant to provide high standards of integrity and probity for eLBA members. The Code will further encourage social responsibility initiatives including support for charities and initiatives to combat problem gambling. By joining eLBA each member agrees to commit to and enforce these standards across their respective businesses. The Code of Conduct will be published in the upcoming weeks.
Don’t you just piggyback on lotteries?
Not at all. We offer a betting product on the outcome of a public event – a lotto draw. The product offered is simply different. It includes ad-ons, special jackpots, bonuses etc. All of which are inherently unique to betting on lotto operators. Just like a sporting event, an election and any other noteworthy public event, we simply offer an innovative and customer friendly way to bet on this outcome.
Aren’t your products confusing for customers to differentiate from lottery purchases?
Not at all. eLBA members’ website content and marketing are accompanied by sufficient, clearly available information that allows the customer to determine that he or she is placing a bet on the outcome of the lottery and not entering the primary lottery itself. eLBA members have and will continue to work towards tackling any issue that could lead to customer confusion. eLBA itself is entrusted by its members to continue raising awareness as to how the lotto betting industry operates and further promote a deeper understanding of the types of products its members offer. See our statement of values to view our commitment.
There have been several judgements by the UK regulator against lotto betting operators. Can you comment on that?
The judgements revolve around marketing lotto betting and are based on the regulator taking a new view on enforcement. As an industry we take note of these judgements and are complying with the new precedents.
Meet the officers
Elisa Field (myLotto24)
Chair of eLBA
Elisa Field (myLotto24)
Elisa Field is Senior Legal Counsel at myLotto24, an innovative bookmaker offering bets on the outcome of international lotteries. She provides legal and regulatory advice for the UK, Irish and German markets as well as supporting international expansion and strategic projects. Elisa holds an LLM in International Contract and Commercial law and has more than 9 years of experience working in legal roles providing cross-jurisdictional advice, both in the gambling sector and other technologies.
Elicia Bravo (Lottoland)
Vice-Chair of eLBA
Elicia Bravo (Lottoland)
Elicia Bravo is Chief Strategy Officer at Lottoland, the world’s leading online lotto operator. She focuses on addressing compliance and regulatory matters as well as other strategic projects including M&A and insurance. Elicia joined Lottoland in 2016 post MBA at INSEAD and has over 7 years of international finance legal experience liaising with regulators and representing corporates, sovereigns and top-tier investment banks in a variety of multijurisdictional transactions.