iGaming Daily

Anaya McDonald (00:02.391)
Good morning and welcome to the iGaming Daily brought to you by Optimove, the number one CRM marketing solution for the iGaming market. Today we are going to be talking about the rise, the alarming rise of fake games and we have with us, we are joined by Duncan Garvey, the head of ADR services at CasinoReviews.com to tell us more. Duncan firstly, thank you ever so much for joining us. How are you today? How are you doing? How was your start to the year been?

Joe, before Duncan replies, can you re-record that for me and move your mic a little bit closer? Closer? Yeah, thank you. As in, say it directly into the mic. okay.

Duncan Garvie (00:32.135)
I

Duncan Garvie (00:44.58)
Hahaha

Anaya McDonald (00:54.093)
Good morning and welcome to the iGaming Daily brought to you by OptiMove, the number one CRM marketing solution for the iGaming market. Today's episode is a really special one and a really important one. Not a special one. Sorry, it's too close now to just get you just pop in a little bit. Thank you. Okay.

Duncan Garvie (01:08.566)
Okay, tschüss.

Anaya McDonald (01:18.455)
Good morning and welcome to the iGaming Daily brought to you by Optimove, the number one CRM marketing solution for the iGaming market. Today's episode of the iGaming Daily, we are going to be taking a closer look at the alarming rise of counterfeit games, following on from an iGaming expert feature with Duncan Garvey. And we're joined by the man himself, the head of ADR services at CasinoReviews.com, Duncan Garvey. Duncan.

Thanks for joining us, how are you doing today?

Duncan Garvie (01:49.598)
I'm very well Joe. If you see my arm moving it's because I have a cat sitting on my knee right now so who isn't happy with a cat on their knee?

Anaya McDonald (01:56.845)
Yeah, exactly. That's the best way to end the day for sure. yeah, this is a really important story. We had a lot of feedback to your interview on igamingexpert.com Duncan. was really shining a light on a really worrying issue when it comes to counterfeit games or fake games. Firstly, can you just tell us how you kind of...

came to know of fake games and counterfeit games.

Duncan Garvie (02:28.164)
If you've been working within dispute management and Serving as a player watchdog for over the last eight nine years You'll certainly have come into contact with players who have identified fake games. You'll have seen some of the Dispute resolution communities casino Meister casino guru

LCB, Gamblers have all run stories where they've identified gambling operators who are using counterfeit games to defraud players. So this has been an issue that has been slowly building over the last decade.

But it's growing in prevalence. The frequency that fake games are being deployed by unlicensed operators is escalating rapidly. And that should be a worry to every legitimate stakeholder in the sector.

Anaya McDonald (03:32.021)
And just to break it down, to bring it back, fake games, they are ripping off players how exactly?

Duncan Garvie (03:41.08)
Well what happens is that a fake game developer will go and identify a major slot scheme. They will strip all the art assets out of that game and then they will build their own game engine and deploy these stolen art assets over the top of the engine.

Now the problem with that is the legitimate version of the game has to be licensed and has to be tested by testing labs, has to adhere to the return to player figures that they publish in the game help files. Everything has to be shown to function correctly. With the fake version, nothing is tested. There's no

there's no guarantee that the game functions in any particular way. In fact, it can actually be maliciously coded to do the opposite. For instance, what could happen is the developer could look at the pay table and say, well, we don't want to pay out big wins, so we're just going to make the top wins on this game inaccessible, so nobody can ever hit them.

The player doesn't know the difference because they look at the game and they see the same game that the legitimate provider is providing but they can't hit the big ones. Alternatively what they can do is they can set more detailed traps. So for instance they could program the game where if the player gets ahead by more than a threshold X

that the game stops paying out any more than a threshold Y until the player drops back down below that win threshold. There's lots of different ways that they can manipulate the game because there's no testing and there's no oversight of it to result in players losing far more, far faster.

Anaya McDonald (05:40.353)
Yeah, that's, you know, that's fraud. That's being fraudulent to players, right? Do you kind of have reason to believe that that is happening on the black market?

Duncan Garvie (05:48.842)
definitely is happening. There's no two ways about it. All the major software providers are well aware of this problem. Many of them have invested large amounts of money trying to chase down the fake game developers. Because it's alongside defrauding players en masse.

This is also tarnishing the IP of the original game developer. It's taking money straight out of that developer's pocket but it's very challenging to track these these individuals down, these developers down. They tend to operate in jurisdictions where it's very hard to reach them legally which makes this a huge, huge battle.

between the legitimate providers and the fake providers.

Anaya McDonald (06:39.319)
So that discretion of them being in jurisdictions where they can't be reached, that makes this a real hard challenge for operators or suppliers, suppliers I guess, going out and kind of tracking these guys down.

Duncan Garvie (06:53.843)
absolutely, as we've seen with other aspects of this industry.

They create layers and layers of shell corporations within jurisdictions with weak rules or oversight, lack of general lack of transparency. So it can take a long, long time even to identify who's behind these operations, a lot of work to identify these people. And even if you can identify the people, challenging them via the legal system is very difficult. Even if you do manage to get there.

resources they're hosting and whatnot taken down they will pop up again under a different name the next week. We've seen this challenge with the black market throughout the history of the remote gaming industry. This is just a new facet and it's one that's particularly dangerous to players.

Anaya McDonald (07:59.053)
Are there any markets or regions specifically that you know of that these guys kind of hide out and you use as a shield if you like?

Duncan Garvie (08:06.186)
Well, we've certainly, I personally have certainly seen enough evidence to convince me that a number of these developers are based in Russia. I've seen, I've also managed to trace one of them back to Singapore and I know from conversations with other knowledgeable people in the sector that quite a few of them are traced back to Singapore.

Anaya McDonald (08:35.543)
Wow. And this is really worrying. It's a lot to digest. In terms of the IPs, are there any specific IPs that you've seen that have been singled out? It's the big names, right? The big slots that we kind of know.

Duncan Garvie (08:51.908)
I wouldn't want to suggest that any one provider was more vulnerable to this than any other. They're not. I have seen both big and small providers having their games ripped off in this manner. What tends to be the case however is that the the fake game developer will target games that are very popular.

so the bigger providers tend to be targeted more and what they do is they then illicitly market their fake versions of these games to unlicensed and black market gambling operators offering them a steep discount over what the legitimate games would cost them.

Anaya McDonald (09:39.063)
And as a player, you know, even a casual player, let's say as a passionate slots player or somebody that plays slots, often you really enjoy slots. Do you think you would have the ability to notice that the game was fake or how deceptive are these games?

Duncan Garvie (09:59.744)
And in the early days there were visual cues, the graphics weren't quite as good, the loading screens weren't identical to the original games. Today I would say for the average player there's next to no chance that they could tell the difference between a legitimate and a fake version of a game.

Anaya McDonald (10:21.112)
Wow, yeah, it's concerning. I guess the other one of the other key real issues here and forgive me for kind of going over old gram. We have spoke about this before, but the audience that these games target because they're on the black market, because the operators that they will be with will just be completely illicit. will be bad actors.

The audience that these games are targeting is the most vulnerable audience, which makes this a far worse issue for the industry, right?

Duncan Garvie (10:57.604)
without question. We recently conducted some research to basically look at black market operators and see what proportion of them we could identify as likely offering fake games.

One of the sectors we looked at were casinos that were marketing themselves as not on Gamstop. Now for those in the audience that don't know, Gamstop is the UK's national self-exclusion scheme. So what happens is a player basically registers with Gamstop and they are banned, they are prevented, excluded from all licensed operators in the UK. They have self-identified as feeling at risk from gambling.

We then see this black market emerge where affiliates target search terms like casinos not on Gamstop. Now we know from the intent of that search term that this is people who have registered on Gamstop and are now wobbling or falling down and they're trying to go back to gambling.

When we looked at the casinos being marketed by these affiliates, we identified over 70 % of them as likely offering fake games. So you then have this double whammy where these operators are specifically marketing in a way that is targeting the most vulnerable subset of consumers.

and then once those consumers come through to them they're ripping them off with fake games that will accelerate the harm far far faster than the legitimate game would. And we saw similar trends in a lot of the the streamers that are operating and if we consider the recent research published by the betting and gambling or betting and gaming council in the UK

Duncan Garvie (13:03.688)
the black market we can see that the audience for streamers is predominantly younger. In fact there's indications that large proportion or large sections of that audience may actually be underage. So we have streamers who are targeting younger audiences

and we identified over 50 % of the gambling operators being promoted by these streamers were also distributing fake games so we're targeting, we're channeling young people, another very highly vulnerable subset of consumers straight through to operators that are ripping them off with rigged and cheating games.

Anaya McDonald (13:47.53)
Yeah, this is a really horrible issue and just the notion that advertising as not on Gamstop casinos is already horrific. Then to kind of use this product that's, you know, just going to siphon money away from these the most vulnerable players even faster is even worse. Duncan, I want to follow up. We're going to go for a quick break and I'm going to follow up on the role of streamers and affiliates because I think that's really important. So.

Duncan Garvie (14:00.414)
yeah.

Duncan Garvie (14:14.116)
Mm-hmm.

Anaya McDonald (14:17.42)
We'll be back in just a moment to continue a really quite shattering conversation, to be honest.

Anaya McDonald (14:28.204)
Thanks again Duncan. I want to tap into what you said about streamers and affiliates. We know that they have a role in kind of bringing this product to the masses. This quite horrific product to the masses. How important is it that... Where does the responsibility sit with streamers and affiliates? Specifically streamers actually because we know the type of audience that streamers get.

Duncan Garvie (14:34.564)
Mm-hmm.

Duncan Garvie (14:40.761)
day.

Duncan Garvie (14:58.104)
This is a challenging question to answer.

I have quite strong feelings on this particular subject. I don't feel that we within the responsible stakeholders in the market have necessarily treated affiliates with the respect or inclusive dialogue that they should have been.

and that's resulted in a lot of affiliates behaving in a counterculture, rebellious way where they push back against basic consumer protection issues. So while streamers and affiliates are certainly, they bear some responsibility for this, the rest of the stakeholders in the sector need to wake up to

their role in creating this antagonistic dialogue with those parties. So that's a broader sort of comment on the overall subject, but yes, if we want to talk about streamers specifically, we need to see streamers stepping up to the plate, frankly. We need them to start taking care with

the gambling operators that they are marketing to their audience and sometimes these audiences are huge they're in the millions of viewers at times. We need these streamers to step up and market responsibly. There's plenty of money to be made by looking after their consumers, looking after their viewers, channeling their viewers through to gambling operators that will actually take care of them and this is on

Duncan Garvie (16:52.248)
This is in every respect, this isn't simply about making sure they're offering genuine games, this is about making sure that they're well licensed and that there are fallback, there's regulation to support the consumer if things go wrong, there's basic consumer protections, there's responsible gambling protections, we need to see streamers taking far, greater care.

to make sure that their audience isn't simply treated as a commercial commodity that they want to milk for as much as they can get, but rather that they are channeling their players through to the right operators, to the operators that will look after them.

Anaya McDonald (17:35.02)
Yep, yep I agree and you know they definitely have a responsibility to you know not be promoting things that are just pure harmful you know they're purely harmful.

This is an ex... from your understanding this is an exclusively black market problem. Is that correct?

Duncan Garvie (17:55.692)
it depends on your definition of black market and it exclusively might be a little bit of of a stretch mostly mostly during during the research we undertook it was unlicensed operators or operators that displayed no verifiable licensing information we certain that were that were

Anaya McDonald (18:01.419)
Okay.

Anaya McDonald (18:20.738)
black or grey market would you say?

Duncan Garvie (18:22.636)
yeah, that were definitely distributing fake games. We certainly did encounter a few operators that were... that held licenses that were from some of the less well regulated jurisdictions like Kurosawa and Anjuan.

So I wouldn't want to go to the point of exclusivity. What we certainly we didn't find, we found no indication of operators in.

more stringently licensed markets like any of your national market regulatory schemes like the UK, Sweden, Germany, Holland. We didn't find anything there. We didn't find anything in the better international regulated operators so Gibraltar, Malta. So there is a line and if players want to stay safe they should stay within better or play with better regulated operators.

Anaya McDonald (19:23.99)
Yep, that makes a lot of sense. But this issue is growing, right? This issue is getting worse. Is there a danger that this kind of crosses over into the more regulated markets? And just how bad could this become?

Duncan Garvie (19:39.832)
I wouldn't want to suggest it could never happen, but I would be very, very surprised. Within the better regulated markets, there are strict licensing conditions that licensees can only accept games, take games from licensed distributors, so the software providers have to be licensed as well.

any gambling operator that held a reasonably high quality license would be risking their license to deploy fraudulent games in this manner.

Anaya McDonald (20:22.821)
Okay, and.

This issue for the industry in 2025, we are at the start of the year. So I guess my question, because it seems like you've touched on it. seems like such a hard one to hit on the head to really pin down. What can we do? can these big suppliers as well that are kind of having their games ripped off, that having their games ripped off. What can they do? What can be done?

Duncan Garvie (20:46.414)
The,

Duncan Garvie (20:50.466)
Well, there are a number of steps we can take to combat this. Firstly, the suppliers need to go to greater length to make their games verifiable.

and every well-right licensed jurisdiction, I'll use the UK because that's the system I'm most familiar with. If you are a licensed gambling operator you have to display the gambling commission seal. It has to link to your license page on the gambling commission's website.

There's no reason that the gambling games couldn't be verified in the same way. So Playtech or NetEnt has a seal on their game that links back to the Playtech or NetEnt website where it verifies that this operator is approved to offer this game. That's certainly one.

avenue we can pursue we need to be louder about outing the operators that are identified as distributing fake games. The only way we protect consumers is by educating them that these operators are ripping them off.

And I've certainly, in the last few days, become aware of a new project that's coming to market in the near future that is going to be investigating and identifying the servers on which games are distributing and is going to be verifying whether those servers are legitimate servers directly with the provider or not and providing this information to consumers. That sounds like a really positive step forward to me.

Anaya McDonald (22:33.413)
Yeah, me too. you know, we'll have to talk more about that when you go live with it. Definitely on iGaming experts. yeah, an important step being taken. So credit to you for that, Duncan. And a massive thank you for your time today. Really informative, really important and also very concerning. But yeah, let's hope the correct steps are taken in the year ahead to mitigate this problem and to eventually eradicate it.

Duncan, thanks so much. I will leave the last word with you.

Duncan Garvie (23:07.03)
thanks very much for your time today Joe. It's great to see an iGaming expert taking the interest in this topic and helping distribute this information to a large audience. This is an issue that needs more attention.

Anaya McDonald (23:24.421)
Couldn't agree more. Thanks ever so much.