SBC News Martin Lycka - Santa’s correspondence with Gambling...

Martin Lycka – Santa’s correspondence with Gambling…

In the latest of a series of columns on international gambling legislation, Entain Group’s recently promoted Senior Vice President of US Regulatory Affairs & Responsible Gambling Martin Lycka shares another letter to Santa…

SBC News Martin Lycka - Santa’s correspondence with Gambling...
Santa Claus – Christmas Inc

The other day, a letter came through our letterbox which was stamped ‘North Pole’. Within the gilded envelope made of silky smooth paper, was this message:

“Dear Martin,

I am writing to you to thank you for your letter of 10 December 2019. I am sure you will be delighted to hear that it has helped me set my gambling regulatory objectives for the year.

My audit office has reviewed my performance against the KPIs you and others have challenged me to achieve in this respect; you will find conclusions of the audit review on page 34215 of the Santa Claus Annual Performance Report (the “Santa Report”). The Santa Report is appended to this letter. 

I hope you will be pleased with the progress of the regulatory agenda. Please feel free to write again this year. 

All the best and Merry Christmas,

Saint Nicholas 

P.S. Always Gamble Responsibly!” 


Martin Lycka
Martin Lycka – Entain Plc

I did not hesitate for a split second, plucked up the courage and decided to write back to the big man. 

“Dear Santa,

Thank you for your letter of 4 December 2020. I am glad to have helped alleviate some of the objectives-setting pressure last year. I know from experience that it is no walk in the park – moving goalposts, conflicting interests, economic and political considerations, this year compounded by the pandemic. 

As usual, the year has been full of ebbs and flows. The industry has pulled together in the face of the virus-induced adversity and has further upped the ante as regards responsible gambling and long-term sustainability. 

Having granted its first-ever online sports betting licences, Germany is firmly on course to bring into effect regulation that will have permitted all online gambling verticals from 1 July 2021 onwards. The Netherlands is in the throes of putting together a solid plan designed to allow for licensing throughout next year. Additional jurisdictions, such as Ukraine, the province of Ontario, Bolivia and crucially even more US states, (will) have taken the plunge and regulate online gambling. 

On a less positive note, Spain has chosen to follow the Italian example and introduce severe restrictions on gambling-related advertising, arguably going beyond what is necessary to achieve effective funnelling of gambling demand into controllable channels. Sweden would appear to be going down a similarly restrictive route, which may, unfortunately, lead to additional market inefficiencies. Not everything has gone to plan. 

So, if you’ll indulge me, Saint Nick – of course, provided that you think I have been good this year – looking ahead at 2021, I have but a few wishes that I dare raise your attention to:

    1. UK Gambling Act review – the existing legislation dates back to 2005, so arguably does need a new coat, or perhaps even a full revamp. Proposals as to the potential content of these changes have been put forth and will be debated throughout the upcoming review. I strongly believe, Santa, dear friend, that for the review to be successful it will require to feed off sensible arguments and hard data, as opposed to sentiments and potential bad blood at both sides of this particular divide.
    2. New kids on the US block – in another flurry of regulatory activity, Louisiana, South Dakota and Maryland have obtained a mandate from their voter to regulate internet gambling in their respective territories (or parishes in the case of Louisiana). These states will join the ranks of the likes of Massachusetts, Maine or Ohio where legislation is already being debated. The one for you, Father Christmas, is to sound out the Lone Star, Empire, Sunshine as well as the Golden State as to whether they’d like to play the betting ball, too.
    3. The German “Behoerde” – the sixteen German gambling kings have entrusted the regulatory powers into a new regulatory authority, or “Behoerde”, if you will, in Saxony Anhalt. The regulatory authority does not exist yet; it is intended to be set up throughout next year, with the process potentially spilling into 2022. The one wish I have in this regard, Nicky, is for Saxony Anhalt to take a good look at what has been achieved in the good old Hesse to see to what extent there is any need to be reinventing the German gambling wheel.
    4. Full steam ahead in Canada – Ontario announces regulation, tick; a bill to remove the federal ban on single sports wagering, tick. This will be a great start to 2021, dearest Santa Claus. Yet, I would summon you to help us from the sidelines to call the right plays over the four quarters of next year to score a convincing regulatory victory crowned by allowing the industry to get licensed.
    5. Brazilian conundrum – when it comes to sports betting regulation, Brazil has been at it since late 2018. The direction of travel is clear, i.e. towards licensing in a foreseeable future; and yet according to the regulatory ship’s log, there have been a few storms along the way that have not yet allowed it to safely land. I would like to call upon you, Saint Nicholas, to use your power of positive intervention to help us bring home the bacon here before next year is out. 

I sincerely hope these suggestions will be helpful. If you have any questions please let me know. Be careful when flying that sledge of yours and have a fantastic Christmas. 

Truly yours,



Martin Lycka – US Regulatory Affairs & Responsible Gambling

SBC News Martin Lycka - Santa’s correspondence with Gambling...

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