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9/9/20  11:43 am
Commenter: U.S. Integrity

Data-Driven Integrity Monitoring


In an effort to assist the Virginia Lottery in implementing, regulating and monitoring statewide legal sports gambling, U.S. Integrity respectfully suggests certain language to be incorporated into the relevant sports wagering legislation. We believe the principles embedded within the proposed language are significant in ensuring the successful maturation of the sports gambling market in Virginia and the integrity of the applicable contests wagered on in the state. Most importantly, it provides the Lottery practical and efficient methods of monitoring and overseeing said integrity and maturation, thus benefitting the Commonwealth of Virginia and ensuring integrity in all forms of legalized sports gambling.

Specifically, the non-invasive transfer of data from sportsbooks to regulators will equip Virginia with the information required to – among other things – efficiently resolve customer disputes, identify and investigate suspicious activity and report data-driven market insights to stakeholders across the industry.

Pertinent Language

Below is certain verbiage that incorporate the tenets above:

  • All licensed operators in the Commonwealth of Virginia should be required to contract an approved integrity provider. In order to be an approved integrity provider, the entity should be, among other things, free of any conflicts of interest.  This means that the integrity provider must abide by certain limitations:
    • It should not operate a sportsbook or be involved in any creation or distribution of odds.
    • It should not participate or be affiliated with any services or activities that are involved in any form of illegal or unregulated sports wagering.
  • Additionally, integrity providers seeking approval in the Commonwealth of Virginia should be able to successfully demonstrate to the Lottery the following:
    • A proven track record of identifying patently nefarious or suspicious behavior in the US-regulated sports wagering market.
    • Internal policies and procedures indicating their commitment confidentiality and ethics.
    • Examples of education and awareness workshops, specifically targeting student-athletes, coaches, referees, trainers, collegiate athletic officials and professional sport employees.
    • Proven technology that promptly notifies relevant authorities and sports betting operators of potentially suspicious activity.


  • All licensed operators in the Commonwealth of Virginia should be mandated to provide said approved integrity provider with sufficient information to ensure they can properly monitor sports-betting information, including:
    • Time of wager;
    • Odds of wager;
    • Location of wager (while labeling relevant wagers “mobile” if applicable);
    • Amount of dollars wagered;
    • Win amount of wager;
    • Wager type (e.g., straight bet, parlay, point spread, total, moneyline, etc.) and
    • Team, side or total that the wager was placed upon.    

Five Factors to Support Suggested Integrity Language

I. More Efficient Customer Dispute Resolution

  • There is currently a significant amount of legwork involved in customer dispute resolution. Regulators need to:
    • Receive and analyze the complaint
    • Submit a request for information, usually to multiple sportsbooks
    • Work with relevant sportsbooks to receive it in particular, digestible form
    • Analyze data internally
    • Follow-on request for more data (if applicable)
    • Write a report with summary and conclusion
    • Relay determination to affected parties
  • This process takes longer than it needs to. Not only does it frustrate the stakeholders involved, it also is a publicity nightmare. The media is hungry for sports gambling-related scandals and storylines, and they are relentless in their coverage of procedures that should be streamlined.
  • If a state already had access to certain data, they could quickly and efficiently leverage it to inform their report and determination.

II. Independent Investigations into SARs

  • With certain data at their disposal, regulators will be able to independently identify and investigate suspicious activity and other integrity-related matters.
  • More data and more independently-investigated irregular activity will result in the significant dissuasion of match-fixing, point-shaving, game manipulation, and the misuse of insider information.
  • Expedited investigations will free up important resources that can be allocated to licensing, new market approvals, and the creation of favorable business regulation.

III. Data-Driven, Efficient and Informative Reporting

  • With data at their disposal, regulators will be able to more quickly report the betting activity in their state. In addition to transparency for the public, these reports provide a strategic roadmap to other jurisdictions who have identified legalizing sports gambling as a potential source of revenue.

IV. Lessen the Burden on Sportsbook Operators

  • Although the proposed integrity language herein requires a near-term technological integration, in the long run, it will save sportsbooks time, resources, and capital.
  • With regulators being able to independently investigate customer disputes and suspicious activity, there will be far fewer requests for information from operators.
  • Additionally, because regulators will be identifying suspicious behavior autonomously, sportsbooks can allocate less time and money to integrity monitoring endeavors.
  • Sportsbook compliance professionals will no longer need to be ever-present in their replies to ineffective forums.


  • These proposed regulations provide a mission that every stakeholder can throw their support behind. Because of the mutually beneficial outcome resulting from regulators having access to more data, the industry can treat is a symbol of progress, success and maturation.
  • This symbol can be leveraged in appealing to bettors to come onshore and in proposals for partnerships with professional and collegiate sports leagues and conferences.


CommentID: 84560