We are aware that Virginia Lottery may be struggling with the dissonance between the comments of certain sports leagues and certain sports betting operators with respect to the need for real-time account level data sharing for the purpose of the leagues’ integrity monitoring effort.  We urge Virginia Lottery to consider the services already provided by the Sports Wagering Integrity Monitoring Association (SWIMA) which shares integrity concerns with the leagues and is used by licensees in every other state that has licensed sports betting.

In its code of conduct, SWIMA requires its members to monitor and report unusual or suspicious behavior at the event and account level.  SWIMA has a monitoring and alert platform that quickly and efficiently provides alerts to members of unusual or suspicious activity reflecting possible fraud or manipulation relating to sports betting.  SWIMA notifies gaming regulators and other external stakeholders including the sports leagues of such activity, subject to appropriate agreements relating to confidentiality and waivers of liability or indemnity.

J. Daniel Walsh

Farragut Partners

on behalf of IDEA Growth