June 2009 – Study on regulatory and self-commitment options in online gaming

TÜV Rheinland Secure iT GmbH, a member of TÜV Rheinland Group, was commissioned by bwin e.k.(hereinafter “bwin”) to draw up an opinion on the possibility of anonymous online gaming on the Internet if relevant regulations and voluntary commitments are in place or whether anonymous gaming can be identified and prevented by implementing adequate technical measures.


In its opinion, TÜV Rheinland Secure iT GmbH examines the following questions:

  • How does Internet gaming work?
  • What methods of authentication and identification are available on the Internet?
  • What possibilities are there to verify that a customer is of age?
  • How to identify conspicuous customer behaviour (fraud, problem gambling) on the Internet?

In addition to the above questions, the opinion examines the risks and opportunities offered by the Internet as an online gaming distribution channel, focusing on online bets (sports betting, society betting), card games (poker, etc.) as well as on skill and casino games. Online role-playing games and computer games offered in casinos were expressly excluded from this opinion.

How can the gaming behaviour of an online gamer be monitored?

As inherent feature of the system, all the activities of an online player are recorded. Such data can therefore be reviewed for anomalies by using appropriate methods. In their own interest, i.e. to prevent fraud or abuse, various providers have established comprehensive methods of analysis to detect anomalies and exclude the players concerned from their gaming operations. In contrast to conventional casinos, where it is impossible to track all gaming activities, online gaming provides an ideal opportunity to monitor the gaming behaviour of players. By comparing this behaviour with the gaming behaviour of an entire community and with the gaming behaviour of a single player, accurate findings regarding potential problems such as fraud, money laundering, or gaming addiction, can be derived. Gaming addiction research provides indications on how problematic gaming behaviour is expressed. Certain behavioural patterns such as chasing losses may indicate problematic gaming behaviour. With online games, gaming behaviour is recorded completely, which allows a thorough check for irregular gaming behaviour and an opportunity to respond appropriately.

Is anonymous online gaming possible?

Players can register by providing false details in order to participate in games or bets. Money can also be deposited anonymously to gamble and bet. By using information service providers to identify customers, online gaming and betting providers however are able to verify in real-time whether the details provided by a customer are accurate or coherent. In this way, false information can be identified promptly and the relevant gaming accounts can be blocked. Furthermore, players cannot have any of their winnings from gaming or betting activities paid out without previously providing proof of their identity. A player is required to disclose his/her identity upon a payout at the latest. As it is impossible to have winnings paid out when gaming anonymously, there is no incentive for players to hide their identity.

How can we verify and ensure that an online player is of age?

In the identification process of players, a player’s age as well as any other master data can be reliably determined through adequate logic and cross-checks and by using the databases of external service providers. ID verification providers such as GB Group offer identity and age verification services, which can be used in real-time on the Internet, thus ensuring the protection of minors when providing such services.

Is it possible and expedient to set up a blacklist for all providers?

To verify the identity of players and betting customers it is necessary to use external information sources and databases. These databases contain sufficient information to clearly identify people. It is deemed to make sense to set up a separate blacklist for online gaming and betting; much rather, it would be preferable to provide feedback to the operators of said databases to allow for the (industry-wide as well as intersectoral) identification – taking into account the provision of privacy law – of conspicuous players and customers.

Please see link to full study

Please note that the translated document is an in-house translation and that the German version prevails