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9/9/20  4:10 pm
Commenter: Kambi

11VAC5-70-220. Integrity Monitoring.

11VAC5-70-220. Integrity Monitoring.


Kambi submits that the sharing of information with other permit holders should take place via the permit holder’s integrity monitoring association or integrity monitoring system provider rather than through the permit holder’s own integrity monitoring system procedures. The permit holder’s integrity monitoring association/system provider should also be accessible to the Director via remote access in place of the permit holder’s integrity monitoring system.


We see no benefit to the integrity of sports to require permit holders to share this information directly when the permit holder’s integrity monitoring association/provider holds this information and is in the best position to ensure sports wagering integrity and is able to share the relevant information accordingly.


Most U.S. regulated sports betting operators are already members of integrity monitoring associations such as the Sports Wagering Integrity Monitoring Association (SWIMA), who work with a number of regulators and are well equipped to report fraud and other illegal or unethical activity related to betting on sporting events.


Thank you for your consideration.


Tommaso Di Chio

Associate General Counsel

On behalf of Kambi

CommentID: 84573