In a recent discussion with iGB, Sean Coleman, the CEO of the Association of South African Bookmakers (SABA), elaborated on his earlier remarks regarding the enforcement landscape against illegal gambling in South Africa. Coleman emphasized that the current focus is primarily on advocacy and engagement with stakeholders. He stated, "At this stage, it remains largely within the advocacy and stakeholder engagement phase," clarifying that SABA's recent statement aimed to contribute constructively to a crucial national discussion about gambling policies rather than to indicate that legislative amendments are on the immediate horizon.
Coleman's insights further emphasize SABA’s position that the issue in South Africa arises not from insufficient laws against illegal online gambling, but rather from an absence of laws that empower effective enforcement. In the statement issued in July, SABA suggested six legislative changes that include revisions to the National Gambling Act, the Electronic Communications Act, and the Financial Intelligence Centre Act, alongside coordinated actions from the Reserve Bank and other regulatory bodies.
The scope of the black market that SABA has highlighted is alarming. According to a report from Yield Sec commissioned by the association, illegal gambling operators constitute approximately 62% of all online gambling activity in the country, leading to over R50 billion in gross gambling revenue being lost abroad each year. Roughly 16 million South Africans reportedly interacted with these illegal platforms in the last year.
Coleman noted that the extensive nature of the proposed reforms indicates a need for a unified approach. He explained, "Our proposals touch on gambling regulation, electronic communications, payment systems and financial intelligence legislation, which means that a coordinated approach will ultimately be required."
SABA has welcomed the National Gambling Board’s (NGB) call, published on 30 June, for expressions of interest from service providers who can effectively monitor, block, and report on illegal gambling websites. While Coleman acknowledged this as a positive step, he also pointed out that SABA had not received further specific details beyond what was publicly available. He stated, "Our understanding is that the National Gambling Board has commenced a procurement process for specialised services aimed at strengthening its capabilities in identifying and responding to illegal online gambling activities."
Coleman identified the recognition of technology's role in combating illegal gambling as a significant development, noting, "What is encouraging is that this reflects an acknowledgement that technology must form part of any meaningful enforcement strategy." However, he stressed that technology should be regarded as just one tool in a multi-faceted fight against illegal gambling. He mentioned, "SABA has consistently advocated for a multi-layered approach that combines technology, legislation and coordinated enforcement. Website blocking, while important, should not be viewed as a silver bullet."
The discourse around the enforcement of illegal gambling measures came to the forefront following a paper released by the Internet Service Providers’ Association (ISPA) on 2 July. The ISPA's chair, Sasha Booth-Beharilal, advocated for any internet service disruptions to occur within a clear legislative framework that upholds communication rights while addressing potential harms. Coleman noted that ISPA had not communicated further with SABA following their statement.
He clarified that the association does not expect ISPs to bear the sole burden of tackling illegal gambling. "Our position has never been that ISPs should bear sole responsibility for combating illegal gambling," he affirmed, advocating for a framework where legally mandated interventions are supported by legislative backing and are implemented alongside other enforcement strategies.
Coleman highlighted the distinctive challenges South Africa faces, differentiating its situation from Australia and the UK. He explained that gambling regulation in South Africa operates under a concurrent competence across nine provincial licensing frameworks, contrasting with countries that benefit from a unified national authority for online gambling. Additionally, he pointed to the aggressive localization tactics of illegal operators as a complicating factor.
He noted, "South Africa faces significant socio-economic challenges that make consumers particularly vulnerable to marketing narratives that present gambling as an alternative source of income or financial relief," underscoring the importance of consumer education. The cross-border nature of payment systems adds further complexity, as illegal operators can quickly adapt to enforcement measures.
When pressed on which intervention he would prioritize, Coleman acknowledged the necessity of a cohesive strategy but suggested beginning with creating an effective mechanism to disrupt consumer access to illegal platforms through coordinated technological enforcement. He stated, "If I were required to prioritise one intervention, it would be the establishment of an effective and legally certain mechanism to disrupt consumer access to illegal gambling platforms."
He emphasized the urgency of immediate action to protect consumers while broader reforms are being developed, stating, "Every day South African consumers are being directed towards illegal operators that provide none of the protections associated with regulated gambling."
Coleman firmly rejected the notion that SABA's efforts are geared towards insulating its members from competition, clarifying, "This is not a debate about protecting licensed operators from competition. It is about ensuring that South African consumers receive the protections parliament intended when it created our regulated gambling framework."
