Effective communication as the key factor to success

Trevor De Giorgio, on Malta’s transformation into an international iGaming Hub

This interview was published in the Autumn edition 2019 of SiGMA magazine, Issue 9. Read similar articles in the digital edition?here.

Greentube Malta has an anniversary to celebrate. First licensed by the MGA in 2006, the company began to employ staff on the island in 2009 and now has a plethora of well-deserved milestones to toast. After starting out with a team of just six employees there, it is now almost 50 strong. At its headquarters in Vienna, there are more? than 400 employees working for the company. SiGMA magazine meets with Trevor De Giorgio, a man who has borne witness to Malta’s transformation into an international iGaming Hub.

Trevor made his first foray in the industry when he took on a work placement with the then MEP Simon Busuttil. It was a case of being in the right place at the right time. A threemonth posting turned into a year and he found himself at the heart of a controversial debate, as the IMCO debated whether online gaming should be included in the services directive. It proved to be a definitive moment for both the industry and his career – and certainly one that piqued his interest.

He followed this up during a spell with the MGA, helping them set up an EU affairs office. Eventually, in January 2010, Greentube came knocking. He joined as a lawyer for the company’s in-house counsel that June. It was a formative decision and, as he says, one that he had to mull over. He had enjoyed his work at the MGA and had thrived under its mentors, then CEO Reuben Portanier and Head of Legal and Chief of Legal and Regulatory Affairs, Joe Borg.

In the intervening period, Greentube had seen a gradual shift from the dot com approach to a dot country one. When Trevor first joined the company, it was only licensed in Malta. Now, it holds licences in eight other jurisdictions: the UK, Alderney, Gibraltar, Spain, Italy, Romania, Belgium, and Germany’s Schleswig Holstein. As with everything else, Greentube takes compliance seriously, offering the industry a forward-thinking approach to tackling tricky and often restrictive regulatory demands.

“The UK regulator has set the trend. Initially I believe quite a few operators took it with a pinch of salt, and you can’t do that. The reality nowadays, and I think the UK has shown this, is that compliance is key,” says Trevor de Giorgio. “There are a number of different facets which everyone attributes to compliance but they should be handled individually because they’re all equally important.”

Trevor De Giorgio – Chief Legal Officer at Greentube.

Trevor goes on to explain that if you look at the UK, there are multiple challenges to deal with, including compliance, money laundering, and responsible gaming. “The problem”, he says, “is that we try to package them all in a neat little compliance box, but they are separate issues. They’re linked but have their own individual peculiarities. You need to be prepared for every single one.

“How you do that depends on the compliance attitude of the board and its appetite for risk. I have to say that here at Greentube, because of our link with the NOVOMATIC Group, we take compliance very seriously. We have a board position where we try to ensure we are as compliant as possible and I think the results show. We have seen challenges in a number of different jurisdictions, and we have adapted and moved forward. I’ve seen a positive change of attitude here in Malta. I’ve seen a regulator that is looking at not only ensuring the market is regulated but also communicating with other regulators. If we want to move forward, regulators need to speak to each other. If we remain isolated in our castles then the situation is not going to improve.”

“I like what I’ve seen from the new administrator at the MGA, I like it a lot. They’re not just open to speaking to regulators – this has been common throughout – but they speak a lot to operators, they ask them about the trends. They want to listen as well, and I appreciate that.”

“The Key Individual scheme introduced by the MGA, whereby senior company executives undergo a due diligence process, is a strong step in the right direction. I think it maintains individual responsibility for the sector. People know now that you are answerable for what’s going on. I don’t believe in the situation where you have one person who is covering 20 to 30 companies as a key official. I don’t think that is sustainable and if I was to read between the lines, I think it shows that the MGA doesn’t think it is sustainable either. We need to have much more visibility on what is going on and I feel that ensures responsibility.”

It is refreshing to see such a proactive attitude. Even when the UK Gambling Commission started issuing its first fines, many operators took a rather lackadaisical ‘wait and see’ approach. In contrast, Trevor tells me Greentube took the issues affecting the industry to heart, hoping their approach would be prevention rather than cure. Whilst it’s not a panacea to all regulatory ills, it has certainly prepared them to meet challenges head on.

“You need to stay ahead of the game – and we have done this. We believe we have taken a proactive approach that is required to counter any difficulties. Training is essential. We need to be prepared and the only way to do that is to listen to similar experiences.”

One thing Trevor believes is currently lacking, that would help make life simpler for operators and suppliers alike, is if regulators came together more frequently to discuss their experiences and work out best practice that might help standardise compliance regulation. “We sometimes have a tendency to close ourselves off and not communicate with each other. I believe if we started doing that more, sharing these similar experiences, we’d learn much more.”

Of course, there are also issues that stem from the regulatory side. One of the biggest challenges according to Trevor is the perceived conflict between compliance and brand. “On the one hand, the brand wants to make the site a strong revenue stream, whilst compliance is seen as trying to limit that revenue stream. The biggest bumps in the road happen when there isn’t proper communication. If you communicate with each other, you will eliminate that point of conflict.”

There are also difficulties when regulators ask for change without allowing for enough time for the company to solve the issue. “We like to call it the butterfly effect, where if we touch one part of our platform, there will be a ripple effect. Sometimes the period of time given to us to fix it is not enough, and we need to explain this to regulators. We aren’t delaying because we want to make as much money as possible; we simply need to make sure the platform performs properly after we carry out the changes. It’s not just clicking a switch, it’s much, much more complicated.”

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