LUN 10 DE AGOSTO DE 2020 - 18:01hs.
Ludovico Calvi, President, Global Lottery Monitoring System

“GLMS’ Code of Conduct could be a reference to regulate the betting sector in Brazil”

Ludovico Calvi is a sports betting expert and chairs GLMS monitoring system to prevent, detect and analyze irregular betting and suspicion activities that may question the integrity of a sports competition. He is in Brazil to address a lecture during the Brasil Futebol Expo - CBF (September 4 to 8 in São Paulo). Before the event, Calvi gave an exclusive interview to Games Magazine Brasil to anticipate some of his concepts.

The congress, which is organized by the Brazilian Football Confederation (CBF), will be attended by key football stakeholders, including managers of Series A and B clubs, national federations, students and experts on the matter, aiming to continue the development of Brazilian football.

The lecture on “Betting Site” will be held on September 6, from 1:00 p.m. to 5:00 p.m. with the participation of the Secretary of Evaluation, Planning, Energy and Lottery of the Ministry of Economy - SECAP / ME, Alexandre Manoel Angelo da Silva; president of the Global Lottery Monitoring System (GLMS) and sports betting consultant for the Oregon State Lottery, Ludovico Calvi; and the president of the Brazilian Institute of Legal Gambling - IJL, Magnho José.

Calvi worked on the implementation of this modality in Italy, managing the largest betting network in the country through Lottomatica. GLMS, the state lottery sports betting monitoring system, went global in 2015, building its reputation on the experience of the European Lottery Monitoring System (ELMS) established by the European Lotteries.


GMB – Which do you consider are the best options to fight results manipulation in different sports?
Ludovico Calvi -
In order to fight sport competition manipulations, one should create and implement a combination of measures/actions, including:

  • A comprehensive sports betting regulatory framework with solid provisions on Sports Integrity, which includes prevention of conflicts of interest
  • The creation of a National Platform to safeguard Sports Integrity - a national structure with the participation of all key stakeholders with the objective of coordinating and centralizing national actions against all types of manipulations of sports competitions. The key stakeholders which should be involved are: regulatory authorities, all relevant ministries including finance, sport, interior, justice, customs, etc, relevant key national sport federations and organisations, legal and licensed betting operators, law enforcement authorities, prosecutors and the judiciary.
  • The creation of criminal provisions, sport and administrative sanctions for athletes (accompanied with protection for whistle-blowers)
  • The creation for a comprehensive set of programs on Education & Prevention initiatives targeting athletes across all sport segments, including school-age and college students  
  • The engagement in solid cooperation and coordination at a national and international level with global integrity bodies such as GLMS (Global Lottery Monitoring System)
  • Concrete provisions against illegal sports betting

In general, the most effective way for a Government to be efficient in this fight, would be – as mentioned above -  to ratify and implement the Council of Europe Convention on the manipulation of Sport Competitions. Therefore, I would urge the Brazilian authorities to proceed to the ratification of the Convention as soon as possible.

How often do you discover manipulated results in the international scenario? In which countries or leagues do these practices tend to be most detected?
In terms of sports, in our intelligence activities, football is consistently the sport that generates the vast majority of alerts. This is because football is typically the most popular sports for betting. Therefore, odds fluctuations are very high and alerts are easily triggered. However, our monitoring platform does not only monitor football, but also a number of other major sports like Basketball, Tennis, Ice Hockey, American Football and Baseball.  Tennis alerts have been increasing in recent years and we are watching closely this emerging phenomenon.

In terms of geographical areas, there is no predictive pattern: each time there is a different number of alerts generated in different regions. Same is true for the leagues and sport competitions. This is partially because crime syndicates shift their work across various geographies to distribute risk and avoid detection. Several years ago, these organisations may have targeted Italy/Serbia; and in 1990s, the target shifted to Korea/Singapore. More recently, the focus moved to countries in Southeast Asian such as Laos, Cambodia. And finally, of late, Eastern European countries seem to be more involved.

What is also important to note is that some sport competitions have become easy targets for integrity breaches:  for example, competition with a weak fan base  (e.g. friendlies, lower leagues competitions, matches at the end of the season); or competitions in which players are not well or reliably compensated.

Do you consider that operators can be, in some ways, part of the problem? Have you discovered cases where they participate in results manipulation?
Betting operators a priori are not part of the problem, but should be part of the solution. Sports betting is not a problem per se, as long as it is offered legally and is well regulated. However, from the one side, the presence of illegal sports betting operators in certain jurisdictions does not facilitate the solution. At the same time, as mentioned above, conflict of interests need to be prevented.

For instance, sports betting operators should ensure that the ownership of betting operators and sport clubs should not be the same. At the same time, betting operators should not influence any sporting decisions, when they are sponsors of a team. Finally, employees of betting operators, involved in the odds compiling should not be allowed to place bets with their employer. All these matters are sufficiently addressed by the GLMS Code of Conduct on Sports Betting.

Brazil began the process to regulate its sports betting market. Considering other international experiences, what kind of mistakes should Brazil prevent?
The legalization of sports betting in Brazil is a very positive development which will yield a number of benefits for Brazil as a nation, its economy, its social fabric, public safety, and local communities from coast to coast throughout Brazil.

There are also, however, some risks that need to be taken into account and proactively addressed. For this reason, pending legislation needs to be comprehensive and strategic in addressing key regulatory and legal issues:

  • The creation of a competent and centralized Federal Regulatory Betting Authority responsible for defining the sports betting regulatory framework and overseeing its implementation in the market.
  • The definition of sustainable legal, fiscal, commercial and operational market conditions are paramount. The regulatory framework needs to safeguard the entire value chain which would allow operators to develop a competitive and innovative sports betting offer and effectively combat illegal market operators. If the conditions are sub-optimal, it will be difficult for public and private stakeholders (Betting Regulators, Betting Operators, Technology Suppliers, Sports Organisations, Data Feed suppliers and so on) to realize the full value potential for the entire country.  
  • Clear directions and measures against illegal sports betting. The absence of tangible enforcement measures against illegal sports betting will undermine the value of any regulatory betting provisions.
  • Consumer protection is a must when it comes to the management of incidents of fraud, responsible betting, underage betting and sport integrity. Clear provisions on Responsible Gaming and Player identifications are relevant and often serve as deterrents for bad actors.  

At the same time, the GLMS Code of Conduct on Sports Betting – which is aligned with the Macolin Convention - provides a concrete set of guidelines on transparent sport betting operations and has informed the work of several Gaming regulatory bodies in other jurisdictions. We hope, therefore, that it could also become a reference for the Brazilian Betting Regulatory Authority in this transformative phase of sport betting legalisation in Brazil.

One of the problems in the international market are the illegal betting sites. How do you manage to monitor results in that scenario?
Illegal sports betting (e.g. an operator being active in a certain country – without a license/authorisation issued by that country) adds to the problem, as these operators are subject to little or no controls whatsoever. At the same time, they are not compliant with any regulatory provisions defined by the competent local regulatory authority.

The first step would be to ensure that there are – as much as possible – no illegal sports betting operators targeting local consumers. The measures you can take would include IP blocking, ban on advertising and a payments blocking (through your National Central Bank).

This is also a measure required by article 11 of the Macolin Convention. As for the suspicious betting pattern monitoring activities, specifically, GLMS platform monitors more than 1 mln odds every 5 seconds on 1600+ leagues / competitions a week on all major sports worldwide. GLMS operation team of analysts based in Hong Kong and Copenhagen would monitor all suspicious betting patterns all over the world.

The monitoring activities is split in 4 phases :

  • Alerting Services – warning system informing members of possible suspicious betting patterns
  • Betting Intelligence and Reporting – Post Mortem and Betting Event Analysis with proof points supporting suspicious betting patterns
  • Real time messaging services among members – Strategic real time interaction between GLMS members through a very effective messaging platform
  • Pre Match, In-play and Post-play analysis

Whenever irregular trading patterns are detected, the match would be further investigated.

GLMS sends out 3 types of alerts:

  • GREEN: Notification to members highlighting the key information found
  • YELLOW: Alert to members highlighting the risk that is of concern
  • RED: Alert to members the risk that is of concern with clear evidence

How does GMLS work to detect suspicious trends? What tools does the company have?
GLMS operation team monitors pre-match and in-play odds movements through a real time market monitoring platform. We have our own threshold settings on different sports and competitions which categorizes the risk of different odds fluctuations.

However, the majority of the suspicious betting patterns are nowadays detected while the game is being played. GLMS Integrity Hubs in Hong Kong and Copenhagen are in real time contact with 32 GLMS members trading operation rooms worldwide monitoring different major Asian, European, North and South American betting markets with operators accepting large staking customers. Whenever match-fixers are trying to manipulate a game for betting purpose, they would inevitably affect the normal odds fluctuation during live-betting. Suspicious betting trends could therefore be detected.

In the process of monitoring suspicious betting patterns, the contribution and effective support of the GLMS global Integrity network (32 members in 4 continents) to the success of the activities of GLMS 2 hubs is crucial. Every member contributes with the monitoring of their local betting offer and patterns on sports, leagues and matches with specialized local knowledge and intelligence reporting any irregularities to the 2 GLMS operation Integrity hubs. 

In order to produce a report on a suspicious game, GLMS operational teams trigger an alert, every time an anomaly in terms of betting patterns has been detected. An alert generated leads to thorough consultation with the GLMS Members, as well as a deep local investigation on potential grounds that could justify the irregularity detected in the odds changes. When the irregularity cannot be justified on objective grounds and also the information received from GLMS Members (also regarding the money flows) further indicate an irregularity, then GLMS operational team issues a report.

More and more markets regulate sports betting generating a huge number of games to monitor. How to achieve a global reach to control as many as possible?
The monitoring of numerous games all over the world is of course not an easy task. The right methodology with the right technological and mathematical approach (predictive models, artificial Intelligence and algorithms) are indispensable to ensure real time pre-match and in-play monitoring of competitions all over the globe.

GLMS is very well equipped with a far-reaching intelligence platform that our full-time analysts are using in order to detect irregularities. Of course, the automatic tools are not enough. The personal judgement, local intelligence by GLMS members worldwide, market data points, the sourcing of relevant sporting info and updates are also necessary for the overall evaluation of each individual case.

Can you tell us about a recognized case of results manipulation in which GLMS has worked?
On January 15, FIFA released a public statement, on the CAS (Court of Arbitration of Sport) decision relating to match official Joseph Odartei Lamptey. The award of the Court of Arbitration for Sport (CAS) confirmed the lifetime ban imposed by FIFA’s Disciplinary and Appeal Committees on Ghanaian match official Mr. Lamptey. The CAS concluded that there was a link between the intentionally wrong decisions of the match official and a deviation from an expected betting pattern, as reported by 5 different monitoring systems, including the GLMS (which was the first monitoring system to report this). The CAS has found Mr Lamptey guilty of having unlawfully influenced the result of the match. GLMS Executive Committee Member, Rupert Bolingbroke (Head of the Trading of the Hong Kong Jockey Club), has also contributed to the case with his expert knowledge on this case.

This is the sequence of the case:

  • 12 November 2016 : Soccer World Cup 2018 Qualification Match, South Africa v Senegal – Referee under investigation for allegedly manipulating match result
  • 12 November 2016: GLMS is the first monitoring system that sends an alert to FIFA – other monitoring systems followed up in the next days
  • FIFA’s Disciplinary and Appeal Committees lifetime ban on Ghanaian match official Joseph Odartei Lamptey for manipulating a sport competition
  • CAS validates decision
  • January 2018: CAS publishes decision: GLMS is mentioned as the monitoring systems that detected abnormalities – evidence used by the Court.

Source: Exclusive Games Magazine Brasil