16
Examination of witnesses
John Pierce, Nigel Mawer and Karen Moorhouse.
Q10 The Chair: Good afternoon, everyone, and thank you for coming back again to discuss the Macolin convention. I am pleased to be to be able to welcome three important contributors to our evidence: John Pierce, the director of enforcement and intelligence at the Gambling Commission and Karen Moorhouse, CEO of the International Tennis Integrity Agency—thank you very much for being with us in the Room—while joining online is Nigel Mawer, co-chair of the Sports Betting Integrity Forum. Thank you very much for joining us today. We have had some interesting evidence sessions, including a particularly interesting one last week from Moses Swaibu, who gave us a moving account of his own life. You could see how easy it is for people to be corrupted in that way, and you might want to comment on some of the evidence we have heard.
With so much sport going on at the moment—we have just finished Wimbledon and we have the World Cup tomorrow, so you have probably been pretty busy—we are keen to hear from you, specifically relating to the treaty. Our job is to scrutinise treaties and agreements and to comment on the detail within recommendations to Parliament. In light of that, I ask you to frame your answers relating to that specifically rather than simply the issue of match fixing, which clearly we are very keen to control.
Lord McDonald of Salford: My question is to all three witnesses. From your professional experiences, do you think the problem of manipulating UK sports competitions is getting worse or perhaps is changing in nature? Are there any particular sporting actors, betting services or contacts that are more at risk?
Nigel Mawer: It is hard to judge if the problem is getting worse. As we get more regulated jurisdictions, reporting is increasing, so, while there is an increase in cases and alerts, I am not convinced that that is necessarily an overall increase in the problem.
In terms of its nature changing, I have seen an increase in match fixing at lower levels of sport. I believe that actually originates from Covid. During Covid time, betting operators were looking for markets to offer and they offered markets on lower-level events. That included the full markets, including handicap markets, and that has continued to the present day. It is an attraction to low-income players to fix aspects of matches that they are playing in because, if they fix certain aspects, they can still win the match, so they can get money from betting and also win prize money. That often involves friends and family or business associates of the player doing the betting. For me, that is an interesting aspect or an interesting development. It is not transnational or organised crime as such; it is at a much lower level, but it is still quite impactive.
When handicap markets are offered on a sport, that makes the sport more vulnerable to fixing. There is a possibility of making more money, especially in single-player sports. Where you have two players, the betting operators are very good at setting the odds, so if you then change certain aspects of that match—who is going to win the next part of the match, who is going to win the next service game, things like that—then those are things you can bet on, and you can get increased odds.
Interestingly, they are illiquid markets, which means there is not a tremendous amount of money in those markets, so if you have a fix then what tends to happen is that a lot of money goes in and that creates an alert, which then leads to investigation and the full process coming in.
Football and tennis remain the top sports that are having problems. I think that is simply because there are so many events being offered, as opposed to it being that there is any particular problem with those sports.
A wider number of sports are having betting products offered on their events. A big problem is that we are heavily reliant on sports governing bodies to deliver investigations and processes to manage this particular problem, because it is generally accepted that criminal prosecutions in this area are very rare in the UK, and that is something that we need to look at going forward. A lot of small sports will not have the resources to deal with these types of issues if they strike. The Sports Betting Integrity Forum and the Sports Betting Intelligence Unit provide advice and guidance to smaller sports, and we try to help them to frame their rules and processes, but it is a fact of life that, when you are in a civil process or an arbitration process, it is expensive to run. So that is a key area for these sports.
Lord Anderson of Swansea: What has been the betting industry’s response to the convention? Has it been wholly supportive or are there some reservations?
John Pierce: In relation to the response from operators, it is within the terms of reference for operators that they have to comply with our requirements. The response that we get from industry is inevitably positive. We get reports coming through where there are potential concerns around specific events or potential match fixing, any sorts of concerns of that nature. We get those reports through from industry and, from my experience over the last few years at the Gambling Commission, that is working well in terms of the transfer of information from industry to the Gambling Commission sports betting intelligence team.
The Chair: Karen, do you have a comment on that regarding how the industry has welcomed the convention?
Karen Moorhouse: Ultimately, our interests are aligned with the betting industry. They also lose when there is corruption, so we they have a joint interest in ensuring that we have the systems in place to find it and take action.
The Chair: Thank you. To go back to Lord McDonald’s question, we heard last week that match fixing is on the up and increasing substantially—although I do not know how you measure that. Would that be your view as well?
Karen Moorhouse: I shall give you some reflections from a tennis perspective. The International Tennis Integrity Agency is responsible for running the anti-corruption and anti-doping programmes for professional tennis worldwide, funded by the four Grand Slams, the two tours—ATP and WTA—and World Tennis, formerly the ITF. Our scope is quite vast. We cover 15,000 players and over 100,000 matches every year.
Match fixing is difficult to measure. Corruption is by definition something that happens in secret. That is why this is so important in terms of us having the resources to find out what is happening. The risk is definitely evolving and the environment is changing. We are seeing across the world the growth in betting, both in the revenue—the amount that people are betting—and, to Nigel’s point, a growth in the different types of market that people can bet on, and that inevitably increases risk.
From a tennis perspective, we are certainly seeing the increasing involvement of organised crime, even if that is behind the scenes so the players who are doing the corrupting may not even realise they are part of it. There is also increasing sophistication. Corruptors are good at what they do and go to great lengths to avoid detection, not only in where they are putting the money on but also in how they recruit and train players to avoid detection. So it is a complex area and certainly requires resources across everyone who has an interest.
John Pierce: I completely agree with what Karen has said. In the reports coming through to the Sports Betting Intelligence Unit, we have seen an increase. The data shows that there has been a 28% increase in the period from 2024 to 2025. We are seeing just under 600 reports annually coming into the Gambling Commission where there are concerns about match fixing or potential corruption associated with sport. As Nigel said, the main reports are typically about football and tennis, but we are starting to see issues in some other sports as well, including table tennis and darts, as well as in the emergence of esports. They are all emerging threats that we are aware of at the Gambling Commission.
Also, the markets have started to extend internationally. There is growth in the north and south American markets, and we have seen some increases there in relation to events that are taking place in those countries and the potential to bet there. About one-third of that activity relates to match fixing taking place in this country, which again points to what Karen and Nigel have said: there is an international issue where markets could be attacked in our country in relation to events taking place overseas, and we need to be mindful of that.
The Chair: That leads on an excellent question from Lord Hannay.
Q11 Lord Hannay of Chiswick: You have moved on to the area that my question relates to, which is basically to replicate the questions that Lord McDonald asked you with regard to the international scene. To what extent is the international dimension of these criminal activities increasing? To what extent is it changing in nature or context? Separately, perhaps you could add this on: to what extent is our ability ourselves in the UK to deal with this inhibited by the changes that took place here after we left the EU, when quite a few of the activities of law enforcement co-operation ceased to be so effective? On those two general questions, and then the specific one, it would be very helpful to hear the views of all three of you.
John Pierce: This is absolutely an international issue, and the data supports that. We get lots of examples of cases where issues take place overseas and they will attack the GB market. We have a really important role to play within our sports betting intelligence function to make sure that we are not only getting the intelligence across the international community and using the networks that are available for that, but trying to leverage that cross-collaboration and cross-support with other law enforcement teams or even through industry and the sports bodies. We cannot underestimate the value of sports bodies in providing the evidence and the information to help tackle this issue as well.
In relation to the changes with leaving the European Union, the frameworks in place to pass intelligence through those networks still exists for us. We are still able to do referrals through Europol and Interpol. We have had visits to our office from overseas enforcement teams involved in match-fixing cases. That network is strong, but it is very much reliant on the proposals in the convention to take that work forward. We are very much of the view that ratification will really strengthen what already is a solid framework to try to tackle this on an international level.
Lord Hannay of Chiswick: Are you getting what you recognise as full co-operation from both the other European countries involved and Latin America, as you mentioned, in some contexts?
John Pierce: Absolutely. The model that has been set up within GB has been replicated in other countries, so we have a really strong network among co-regulators to share information, pushing forward the intelligence opportunities to share not only potential examples of match-fixing but how we operationalise that function in GB. That has been adopted by other countries. A key part of the work that the team do on an annual basis is to really drive forward the approach that we have taken in GB, because a lot of that is built within the convention itself. If you look at the platform that has been created in GB, for example, that part of the convention is something that they are looking to take forward internationally. We have made a great start. Ratification is needed, will help take the work forward and strengthen that international approach, which is needed if we are going to be serious about tackling this issue.
Lord Hannay of Chiswick: Could we move on to tennis now?
The Chair: Sorry, Lord German had a quick supplementary.
Q12 Lord German: Yes, I just wanted to pick up on the policing issue in relation to Europol. We have British police officers based in The Hague, so that we are embedded in Europol there, but there are no Europol officers in the United Kingdom, which was part of the leaving agreement that the previous Prime Minister agreed. How restrictive is that? Is that causing you any problems in how you get the international information? Would it be better if we had Europol officers here in the United Kingdom, where you could work with them directly?
John Pierce: I am fully supportive of any work that we can do to strengthen the intelligence flow between different agencies. If that move then led to increased investigation opportunities or intelligence opportunities, I would absolutely welcome that. At the moment, the big focus internationally tends to be around intelligence sharing, and to take this work forward on an international level we need to push forward the enforcement aspects.
In relation to the work that the Gambling Commission does in this space, we take forward investigations. As a commission, we have a prosecutorial arm that is available to us. The issue is, once you start stepping and going across borders, as I am sure everyone in the Room knows, it then becomes more and more difficult to bring people to justice. Certainly, that is the next stage after signing up to this and ratifying the convention. That will build on what has taken place, and there has already been some great work. There is an awful lot more that we and the law enforcement community can do, both nationally and internationally, to take the work forward.
Karen Moorhouse: I echo John’s comments on sports corruption being international. It is inherently international. Some 47 individuals were sanctioned under the tennis anti-corruption rules last year. For the vast majority of those, matches were played in one jurisdiction, players were from another jurisdiction, the bets were placed in a third jurisdiction, and, to the extent that we knew who they were, the corrupters were in yet another jurisdiction. It means that no one organisation or one country can tackle all different parts of that on its own. It is absolutely essential that we have international co-operation and sharing of information. We already work really closely with betting regulators, betting organisations and law enforcement agencies around the world, but what we can do is sometimes limited by legal frameworks or by the ability to share data, so anything we can do to enhance that and make it simpler and easier to share information, the better that is in terms of protecting sports and ultimately protecting the participants in those sports.
Q13 Baroness Lawlor: I am very interested in this cross-border thing. It strikes me that, sometimes, the Council of Europe conventions cannot deal with a global problem. We have Interpol, Europol, the G20 principles and a lot of activity, and UK Ministers are clear that we have robust sanctions here and internationally. Would not adding ourselves to yet another Eurocentric convention simply be duplication and lead to more bureaucracy, but not necessarily less effective pursuance of criminality as now, with the agencies we have?
Lord Hannay of Chiswick: In contrast to that, I would say that the G20 has no operational follow-up function at all.
Baroness Lawlor: Yes, but it has co-operative and high-level principles on tackling corruption in sport, and it matters. These are serious players. I am talking about a global market, where 35% of it happens in Europe, 15% in North America and roughly the same in South America. The rest is in Asia on online betting, and the betting markets are largely in Asia. That is why I come back to this. We need global co-operation and to concentrate on our global arrangements.
The Chair: That is a reasonable point. The question coming up next might allow you to answer that in a bit more detail, but is the Macolin convention enough? Maybe, Nigel, we could go to you? If you want to, you can go back to Lord Hannay’s original question.
Nigel Mawer: I echo a lot of what has been said. I predominantly work with international sports governing bodies, and I had a recent case where the events were in the UK and Europe. Predominantly, the betting was in the Far East, and in the Far East there is not the same “know your customer”: you can bet through agents, and you cannot gather the material that you would traditionally gather in a match-fixing investigation. There are some very interesting dynamics that take it much broader than just in Europe. As Karen said, it can be across various different jurisdictions.
The plus factor for sports governing bodies, though, is that the players are subject to the sports governing body rules. Certainly, the sports governing bodies that I work with are subject to English law, so it means that all our cases are run in England, irrespective of where the player has transgressed the rules. That was just a slight aside in support of Karen’s point.
The cross-border piece, again going back to cases that I have directly been involved in, gets an awful lot of involvement from the Far East, where there is some very heavy gambling on sports generally. It goes back to the point I have just made: it makes it a lot harder to deal with. Certainly, from a law enforcement perspective, with jurisdictional issues and issues with gathering evidence, broadly, outside Europe, it makes the problem much harder to resolve.
Lord Anderson of Swansea: Related to that, one of our witnesses in our last meeting said there should have been a UN convention rather than the Council of Europe convention. Does that make sense?
Nigel Mawer: Sometimes it is good to have some steps in the right direction, and whether it should be the UN or the Macolin convention, it a step in the right direction, as far as I am concerned, from a sports governing body perspective, because it provides a framework that we can work within and is supportive of what we are trying to achieve. But I do not argue with the fact that it is a worldwide problem. It is not solely the UK and Europe.
Lord Hannay of Chiswick: The chances of the present US Administration allowing the UN to legislate in this sense are close to zero, are they not?
Nigel Mawer: Yes, but interestingly, I am dealing with a case at the moment where the betting is in America, and I have the full data from the betting operator provided to me. Obviously, that enables me to conduct the full investigation and, hopefully, to deliver a result in a match-fixing case. Sometimes, it is more when you get into governmental organisations rather than when you are dealing with betting operators and with sports governing bodies.
The Chair: Thank you. We will move on to the next question, because all this ties back together.
Q14 Baroness Anelay of St Johns: So far, we have heard your clear understanding of and work with a framework. Nigel, you mentioned that this is a framework convention that can be helpful, but there can also be glitches or omissions. What are the convention’s strengths, from your point of view and for your own organisations? Are there any avenues that you can think of that those who are working with the convention can go down to make the whole thing stronger and work? May I start with John Pierce? I have a small supplementary question relating to the work that you have done. Thank you for the written submission and the work that you did more broadly and internationally about the behaviour.
John Pierce: Thank you very much. In terms of areas where there are clear strengths, from our perspective, the Group of Copenhagen is to strengthen the governance and operational capacity of national platforms. If you look at the model that has been built in GB and replicate it internationally, that is a real strength, as a network where we are able to share intelligence and showcase examples of cases that various teams have been involved in. That is a real strength, because, inevitably, the way cases are investigated or taken forward on an international basis will be different. Anything that we can do to showcase when we are able to take a case forward is important, and the network obviously gives us the opportunity to do that.
The other key thing with this is speed. If you are not able to react quickly, obviously, there is real potential for some of these issues to spread, so we are talking about improving the intelligence around the types or level of sports that are being targeted. I am sure that Karen will talk about that. With tennis, for example, there are real issues at certain levels, where match-fixing has been more prevalent. The opportunity to share what is going on on an international basis is a positive.
In terms of what could be improved, there is a real difference between taking this from intelligence to action, and that is an area that, internationally, we need to try to focus on and build. The work that we are doing in the Gambling Commission in taking some quite significant cases forward will hopefully help to showcase to other teams internationally what is possible. When you move from intelligence to actual enforcement activity, that is an area where we can develop post ratification to strengthen the international approach and be more co-ordinated than we are able to at the moment.
Baroness Anelay of St Johns: Let us hear from Karen, then I will go to Nigel, and then I will return to John on that particular issue.
Karen Moorhouse: From our perspective, one of our limitations is that we can only take action on our rules against people who are bound by our rules—be that players, officials or coaches. It is very rare that they are the ultimate corrupter and that they are actually placing the bets and making the money at that level. So, the real strength for us is the recognition that this is a shared responsibility and that to get to the right outcome, everyone needs to utilise their powers against the people that they have jurisdiction over. Otherwise, we can keep taking action against athletes or players, when oftentimes, they are, in effect, victims themselves, because they have been corrupted by someone who has preyed on their vulnerability to get them to corrupt something in a sports event. Once they are identified and removed from the sport, the corrupter will just move on to the next player, so we need to work together to make sure we are actually dealing with the root cause rather than just someone within that chain.
On improvements or areas to watch out for, John referred to it in relation to speed: it is important for us that this framework is set up and delivered in a way that means that things can move at pace. When we work with law enforcement, because its target is different to ours, we have to find a way of working together in a way that means that we both achieved the outcome we want. That means them taking action under their criminal rules against the ultimate corrupters and means that we can, in a timely way, take action against the participants and remove them from the sport.
It is important that it continues to evolve. One thing I think we have all learned over the last few years is that the betting markets and how things work will change, so we just need to ensure that the framework is flexible enough to deal with what we discover in two, five or 10 years’ time.
Baroness Anelay of St Johns: Thank you very much. Nigel, what are your views about strengths and improvements that could be made?
Nigel Mawer: It is a step in the right direction in that we are joined up with the countries that have ratified, which will help the exchange of information and co-operation with the countries that are party to the agreement. If we sit outside that, there is a risk that we will not get that benefit.
We have for some years, since 2018, been working as if we have ratified the Macolin convention in that the Sports Betting Intelligence Unit and the Sports Betting Integrity Forum have been working along the lines of and taking the approach of Macolin. From that, you can tell that, broadly, we have a lot of support for this. But I do take the point that, as with any step forward, we could go further.
Lord Hannay of Chiswick: Presumably, that would cover the prosecutorial—
Baroness Anelay of St Johns: Sorry, David, could I just go back, as I said I would earlier? It is a specific issue with regard to the work of the Gambling Commission.
I notice that the work that you have done is to try to ensure that Governments overseas can try to build resilience in their own systems to be able to deliver a more honest way of dealing with those who are basically trying to destroy the whole system by using their illegal betting systems. I am trying to be very diplomatic. There is one particular issue that arose about Malt, which the Gambling Commission assisted to have proper systems in place. Malta has now said that it is concerned that, in doing that, its current licensees would find themselves out in the wild, so it will not be ratifying. It also means that, subsequently, the EU will not be ratifying. We are looking at the EU’s ratification. Thank you for what you have done so far. Are you able to do more to give some resilience to Malta to ensure that it can actually put it into the fold?
John Pierce: The Gambling Commission supports other regulators internationally. We would be very happy if Malta wanted to reach out to discuss the existing set-up and framework or the approach that we have within GB. That is an offer that is available to them. We would be very happy to support them, as needed in that space.
Q15 Lord Hannay of Chiswick: Could I just ask you about the prosecutorial functions? Presumably, within the European Union at least, the existence of Eurojust is a help in pursuing cases where there might be doubts or discrepancies between the prosecutorial aspects of each country.
John Pierce: In relation to the cases that have been taken forward so far by the Gambling Commission, there tends to be a UK element to the offending: there tend to be suspects that are based in GB. That has been the big focus of the existing cases that the team are looking at at the moment. It is absolutely an area of growth for the Gambling Commission. I am sure everyone is aware of the additional funding that has come across to the commission—£26 million. We want to use part of that funding to strengthen our investigation approach and our prosecutorial approach in future. That could potentially lead to more cases coming through the system, but we want to make sure that we, as an organisation, are at the forefront and able to tackle some of these issues. Once you start to get to the cross-border type issues, that is an area that we want to develop and try to take forward, post ratification, to see where we can take that.
Q16 The Chair: Lord Anderson has a question hovering. But with these new prediction markets, as opposed to going to betting shops—Ladbrokes, Betfair or whatever it is, where I would assume there is a high degree of transparency—is it not starting to become almost impossible to track who is making an illegal bet?
John Pierce: There are a number of difficulties. You mentioned the traditional betting market. Even within a traditional betting market, if somebody went into a bookmakers and paid cash, that would be difficult to trace. It is not impossible. We have had cases where we have had information that suspicious bets have been taking place on a betting premises, and we have been able to secure CCTV and take cases of that nature forward, so it is not impossible.
On the remote space, there is obviously a requirement to register for an account. We get an awful lot of information about an individual. There are some difficulties around that if it is unlikely that somebody would place the bets themselves—it could be a family member or somebody that they know. But a big element of the work that the sports betting intelligence team do will be to try and identify and analyse those links where we have concerns about a specific betting market.
In relation to some of the emerging markets, and particularly the illegal markets, that is where there is a real danger, because as soon as you step outside of the regulated space—
The Chair: That was my point, yes.
John Pierce: —our first line of defence is a regulated operator. They will provide data to us when they spot issues relating to an event. There is the potential that we would not see that data, and we would be relying on the sports bodies to identify where some of those issues are and where they are taking place. The work that we are doing to try to disrupt the illegal market space is really important, not just for the benefits of trying to damp down that marketplace, but because of the impact it would have on sports betting in GB.
Q17 Lord Anderson of Swansea: I have a question on the impact of the convention, which was concluded in 2014 and came into effect in 2019. Is it too early to assess the impact? Is it relevant that many countries have signed but not yet ratified? Some, as Nigel has said, may not have ratified, but they implement the convention. What has been the impact so far?
John Pierce: From a GB perspective, Nigel covered it very well. We have worked on the basis that we need to get a lot of the implementation and the aspects of the convention now, and that has been in place for a significant period of time. That work has developed over a number of years.
The benefits of the clear channels of communication that we have set up with other national platforms are really important, as is the improved sharing of information, but a lot of ground has been covered. Ratification is all about moving it from a position where we are doing things predominantly through consent, by speaking to other countries and by trying to support each other with the work. This is formalising that and, in my view, it is the next step that we need to take to tackle this international issue.
Karen Moorhouse: I think John has probably covered it. I just reiterate that the wider ratification should strengthen that international network, and therefore, that should help in dealing with what is, at its core, an international issue.
Lord Anderson of Swansea: Has the impact been limited by the slowness of some countries to ratify, including the UK?
Nigel Mawer: It is difficult for us, because we have adopted Macolin, and we have been running with it. As John said, it is run by consent rather than by the framework. We have not suffered particularly because of that, but it is hard to say until the other countries ratify and become part of it. That, you would hope, would increase the benefits as it becomes bigger. But I have not seen a direct problem from the slowness of the ratification.
Q18 Baroness Bonham-Carter of Yarnbury: You have probably answered the question I was going to ask, but where will further steps be needed to ensure full compliance, if and when the UK ratifies the agreement? I have a supplementary question, but this is probably for Nigel.
Nigel Mawer: As I have already touched on, we have had the Sports Betting Integrity Forum, although it had a different name at the beginning. The tripartite group has been in place since 2012 and was a result of the Parry report from 2010. Since 2015, we have published sports and sports betting integrity action plans. The plan and approach reflects the objects of the Macolin convention.
Basically, we fulfil the criteria that is required by Article 13 with our national platform. That is largely with the big support of the Sports Betting Intelligence Unit and the Gambling Commission, because they put an awful lot of effort into this to help us to be compliant before we have ratified.
There are some positives that have come out of it, because we have lots of stakeholders, and all those stakeholders are relevant in this field. Player associations, betting operators, gambling regulators, police agencies, CPS, Government and DCMS are all involved in the Sports Betting Integrity Forum and are all working towards the action plan, so a lot of that is already in place. That supports the process.
We have the SBIU in place, and there is a requirement for suspicious activity to be reported to it. There is an additional requirement for it to support sports governing bodies in breaches of their rules. There are an awful lot of things in place that already go towards what would be required with the ratification.
Baroness Bonham-Carter of Yarnbury: So there are a lot of things in place, but we are not at the end.
Nigel Mawer: Yes.
Baroness Bonham-Carter of Yarnbury: Sorry, I was not here last week, so if I am asking something that was already asked, I do apologise. Does age verification come into this?
John Pierce: In terms of bets that have been placed, yes, there will be checks on individuals that are placing bets. If you open up a remote betting account, you will need to go through that verification process. I am not aware of any specific match-fixing cases where children, for example, are involved. On seeing examples of accounts being opened by people that are underage, I have not seen that as an issue at all. We do sometimes see things such as smurf accounts being created and false details being used to open accounts. That is where the industry needs to be alive to the dangers, because that would be a way of extracting money from the system.
Baroness Bonham-Carter of Yarnbury: That is what I was referring to, thank you.
The Chair: What Nigel was talking about goes quite neatly on to Lord Stevenson’s question.
Q19 Lord Stevenson of Balmacara: Although, that having been said, I think you have answered some of the questions already. The point I was going to try and make is that—I wonder if John and Nigel could agree—you have been achieving a great deal without a legal framework, which is now being proposed and being brought forward. You have said, in effect, that you are doing most of what is required. Could you narrow that down and just be a bit more specific about what additionality will come from the ratification process? Perhaps Nigel should go first.
Nigel Mawer: The key part is that an awful lot of it at the moment is within anticipation of ratification. A lot of the support that we have and a lot of the things we are doing come as a result of us signing the convention and now moving towards ratification. It is quite hard to assess what the position would be if we were not in that position. I do not know if John has a view on that.
John Pierce: I completely agree with Nigel. From our perspective, a lot of the work that has been achieved is because we have been moving towards ratification, as a number of other countries have too. If we decided not to sign up to that, that could have an impact on the current approach and the work that is taking place today.
On the potential gaps, if there are any, obviously, in terms of our compliance with it, we are in a strong place. There is more that can be done from an enforcement perspective. Ratifying the Macolin convention will really allow us to take that next step forward. For example, we have a member of the CPS who sits on SBIF, so we have some of the components in place already, but I would like to move from a mature intelligence environment around sports betting and match fixing to actual targeted action, and that cannot just sit with the Gambling Commission. It is something that we absolutely need to take forward nationally to other law enforcement teams as well.
Nigel Mawer: It is fundamental to success that we do not just focus on the participants in sport, which is where the sports governing bodies come in. We need to go to the corruptors, the people who are co-ordinating the activity, but the dilemma for sports governing bodies is that we cannot touch them. So it is essential that we involve law enforcement, who can spread the net wider and get behind it to get the more serious offenders in this area.
Lord Stevenson of Balmacara: That seems to be quite an important point. We cannot cover it today, but perhaps you could get together and give us a little note about that particular aspect which we might be able to use.
The Chair: John, you mentioned some quite useful statistics at the beginning about international betting and the rise in match fixing—25%, I think, or something quite significant. Can we make sure that we include some of these useful statistics in our report?
Q20 Lord Hannay of Chiswick: Could I put the question the other way round? All the questions that we have asked you about the international dimension relate to the way in which we are able to pursue these crimes. How much would ratifying Macolin help other ratifiers of Macolin pursue these crimes in a way that they cannot do now?
John Pierce: We have probably covered the question of taking this forward post ratification. Certainly Nigel has covered it. In my view, it is still at the early stages and a lot of that work still needs to be done, but post ratification it is all about trying to strengthen the existing approach that we have at the moment. It is great that things are working well and there are lots of examples of cases that we are able to take action on. Where we need to move to next is trying to build that enforcement model and share those experiences and successes on an international basis to really try to drive the international enforcement approach, which in my view is not quite joined up enough at the moment. Moving forward to ratification is the next stage for other countries that are involved with the convention.
Once we get past ratification, we will have a seat at the table. We will be able to try to drive through some of the areas of concern or change that we think are necessary to really take this work forward. We should not underestimate that as a key area that we would really be able to take forward once we move forward to ratification.
Q21 The Chair: Thank you for the evidence that you have given. I have two questions as we come to an end. First—and you have probably heard a bit of the tone of this in the room—how useful is the convention itself? By signing up to it, are we thinking, “Hey, we’ve done a great job, we’ve signed the convention, and now it’s somebody else’s problem”? The reality, as we heard last week and this week, is that it is about enforcement. Unless you invest properly in law enforcement, whether you are in the convention or not, you still have collaboration with other countries, as Baroness Lawlor said, and so on. Is this really just a “nice to have”? Are we missing the point by spending a lot of time focusing on it, or do you think it really is relevant in driving the cross-border co-operation that we need in order to crack this problem?
John Pierce: In my view, it is highly relevant. I look at the work that the Sports Betting Intelligence Team has done over the last few years in this space, working alongside Nigel with the SBIF group. For me, it is one step on a much longer process, but it is one that I absolutely think we should be taking. There are huge benefits from being part of the convention. We can really continue to drive that sharing of intelligence. We benefit from that as a country, as much as we share with other countries as well. It will not be the final outcome. I very much see it as a step on a journey that we need to take. We will need to continue to put resource, effort, time and dedication into trying to make a difference in this space. That needs not just the Gambling Commission but colleagues around this table and obviously the forum as well.
Q22 The Chair: Thank you. My final question, as we have about three minutes left, is about Malta, which was raised by the noble Baroness, Lady Anelay. I am interested in why this is such an issue for Malta. Is there anything that could be an issue for our betting industry? I have an interest in a technology business that makes settlement bots for all these different companies. We would not want to find that we had accidentally limited legitimate activity through this, whereas Malta clearly thinks that it has, which is a weakness because then the EU is not signing up to it. Could you just explain in layman’s terms why it is an issue for Malta and what we should be aware of?
John Pierce: I am not aware of specific issues in relation to Malta but I can certainly comment on the GB marketplace. Requirements for the GB licence are covered through licence conditions and, obviously, through our strategic objectives around keeping crime out of gambling. That network has been in place for a significant period of time already. We still get the intelligence flow from industry as is required, and we have not noticed or been aware of any concerns around that model.
The Chair: So it is not a massive compliance cost, like some of these money laundering restrictions are for legitimate businesses. You have not found that to be the case.
John Pierce: Absolutely not, no. It is very much dependent on operators having the right systems and software in place, but they need those systems and software in place anyway because they need to comply with, for example, AML requirements. They have to have those strong systems in place and be vigilant. That is a requirement. I do not think there will be a cost as a result of ratification. It will just be a continuation of the work that those operators do at the moment.
The Chair: Thank you. Nigel, any comment on Malta?
Nigel Mawer: No, I do not have any direct knowledge of Malta.
Q23 Baroness Bonham-Carter of Yarnbury: On that point, there is the question of Northern Ireland as well, which is outside the Gambling Act 2005. Can you comment on Northern Ireland’s regulatory framework?
John Pierce: The remit of the Gambling Commission does not cover Northern Ireland, which, from what you said, I am sure you are aware. It could be that the Northern Ireland devolved Assembly might need to review Section 13 of the Betting, Gaming, Lotteries and Amusements (Amendment) Act 2022 to make sure that it sufficiently addresses the issue of cheating offences in Northern Ireland in line with the convention. So there is something there that could potentially need to be looked at, but it is difficult for me to comment because it falls outside our area. However, in terms of the impact on the GB market that the Gambling Commission is responsible for regulating, we are not anticipating any issues.
Baroness Bonham-Carter of Yarnbury: You do not anticipate issues?
John Pierce: No.
Lord Hannay of Chiswick: Presumably the ratification by the United Kingdom of the Macolin convention will include Northern Ireland.
John Pierce: It would.
The Chair: I should know this. There is a Northern Ireland gambling commission, a separate entity.
John Pierce: Yes, it is by PSNI. We have a network where we are able to share information and intelligence with Northern Ireland.
The Chair: So you collaborate. It is not an issue, is it?
John Pierce: No not at all.
Baroness Bonham-Carter of Yarnbury: So you are saying it is not an issue.
The Chair: We have come to the end, unless any of my colleagues have any other supplementary questions.
Q24 Baroness Lawlor: As you have asked me, what extra intelligence sharing would we get by joining the treaty?
John Pierce: In my view, by joining the treaty, we are going to increase the speed. That is where it is going to be really important. In my view, there is a massive opportunity for countries that are signed up and fully ratified to share things on a much faster basis and, as the work of that group starts to take pace, we will be able to increase that speed. For me, that is one of the key components.
Baroness Lawlor: So it is not about what is shared but how quickly it is shared?
John Pierce: Yes.
Karen Moorhouse: To illustrate that, we had a significant number of sanctions recently that came out of work with the Belgian law enforcement agency. Ultimately, we ended up sanctioning 72 individuals for breaches of our rules but, because of the fact that their proceedings took precedence, we were not dealing with those cases until a number of years down the line. To protect the sport, you want to be able to take action as quickly as you can and remove people from the sport, so speed is essential in protecting the integrity of the sport.
Baroness Lawlor: But it will not help with the online or Asian betting markets.
John Pierce: Potentially not. It depends where the bets are being placed and where the activity is taking place. It is certainly an international issue and there will inevitably be some gaps, but my view is that this is one step in the right direction.
The Chair: Thank you very much indeed. Please send us any supplementary information that might have to help us in our inquiries.
