The National Platform: Exchanging key information

It also ensures that the objectives set forth in the Macolin Convention are properly implemented at the national level in accordance with existing legislation. These objectives, which are highly relevant to the lottery and sports betting sector, include but are not limited to: the detection of betting irregularities; criminal, administrative, and disciplinary investigations; reporting; sanctioning; and education and awareness training; within the wider context of sports manipulations.

There are multiple stakeholders in the fight against the manipulation of sports competitions and illegal sports betting. Among these are: public authorities (including all relevant ministries, law enforcement agencies, prosecutors, government legal advisors, legislators, betting and gambling regulators), and lottery and sports betting operators. Each of these stakeholders has different jurisdictions, different roles, and access to different intelligence and information. For various reasons, these stakeholders are often not accustomed to working together, especially in the area of information sharing. Most notably, law enforcement agencies are typically prohibited by law from sharing information with private and third parties not formally participating in an ongoing investigation. As such, cooperation, and exchange of sensitive data between these stakeholders is not always easy. National Platforms aim specifically to address this problem.

Other relevant stakeholders include representatives from the world of organized sports – from national and international sports federations to referee unions, on through to competition organizers. While the Macolin Convention sets guidelines for regulatory authorities and operators, these should work closely with other stakeholders in tackling the manipulation of sports competitions. Competition organizers, for example, are important in the investigation of suspicious betting activity and the Macolin Convention encourages a positive obligation on states to facilitate a better relationship between competition organizers and betting operators.

Additionally, the National Platform:

• promotes and coordinates awareness raising through educational and training programs on the manipulation of sports competitions and the integrity of sports;
• conducts research, identifies trends, and compiles data relevant to the manipulation of sports competitions and illegal sports betting;
• disseminates information relevant to the manipulation of sports competitions and illegal sports betting; and
• creates a single point of contact for international and national stakeholders.

The establishment of a National Platform, and the implementation of the Macolin Convention’s objectives is the best deterrent to criminal elements seeking to corrupt the integrity of sports and damage the reputation of the sports betting industry. In many cases, state lotteries are an integral part of the National Platforms, given their status.

Who leads the National Platform?

The Macolin Convention recommends that a public authority lead the National Platform given the positive obligation, neutral position, and decision-making powers that public authorities have. The nature of the public authority may vary from country to country, depending on their priorities. The lead may be supported by a different coordinating entity at the national level, who may receive a special mandate to coordinate the activities of the National Platform.

In order to establish a National Platform a jurisdiction must first identify the key stakeholders within its borders. A lead entity and a coordinator for the National Platform should be elected. The name and contact details of the National Platform should be communicated to the Secretary General of the CoE – this makes the National Platform official at international level, once the country has ratified the Macolin Convention.

The country should then assess its priorities and carry out a full risk analysis.

Such an evaluation would include:

• The risks and vulnerabilities (often financial)
• The legislative strengths and gaps
• Investigative techniques
• The country’s potential to work with other nations (mutual legal assistance, treaties, cooperation with international or regional mechanisms, etc.)

If they have not already done so, the country’s stakeholders should endeavor to have their government legislators ratify the Macolin Convention. The National Platform should not be considered in isolation of the Macolin Convention. In providing a legislative framework, the Macolin Convention strengthens the legitimacy of the National Platform and provides it with guidance as to its proper functioning. Without the legal basis that the Macolin Convention provides, the work of the National Platform can only go so far before legislative constraints arise.

In the exchange of key information, it is important to understand both the role that sports betting plays in the manipulation of sports competitions and the wealth of information that lottery organizations possess that would be useful in the fight against corruption in sports and illegal betting. It is therefore imperative the WLA lottery members play an active role in supporting the ratification of the Macolin Convention in their respective countries.

The Group of Copenhagen: The network of National Platforms

Communication between the various National Platforms is achieved through a network known as the Group of Copenhagen. The Group of Copenhagen was established in 2016 by the CoE at the initiative of a number of member countries that were originally seeking a way to promote the ratification of the Macolin Convention.

The Group of Copenhagen has since expanded worldwide bringing together 33 countries represented by their National Platform coordinators. Among the Group of Copenhagen’s objectives are:

• to identify and promote best practices;
• to serve as a network for the existing National Platforms and provide them with practical support in helping them consolidate and improve their systems; and
• to support countries in creating their National Platforms.

In pursuit of these objectives, the Group of Copenhagen lays the foundation for transnational cooperation, for enabling the exchange of information, and for sharing experiences and expertise essential in the fight against the manipulation of sports competitions and illegal sports betting.

On June 24, 2021, the Follow Up Committee of the Macolin Convention – also known as the T-MC Committee – officially made the Group of Copenhagen an Advisory Group under its authority. The T-MC Committee is the CoE body that is mandated to monitor the implementation of the Macolin Convention. It is made up of the state parties to the convention and observers to the convention. As of September 2021, the state parties to the convention are Greece (Chair), Portugal (Vice-Chair), Switzerland, Moldova, Italy, Ukraine, and Norway. The observers to the convention are the United Lotteries for Integrity in Sports (ULIS), the International Olympic Committee (IOC), Interpol, FIFA, and UEFA.

Under the aegis of the T-MC Committee, the Group of Copenhagen is now formally structured and has received a term of reference. As such, the Group of Copenhagen will be better able to achieve its objectives and help countries establish National Platforms within their borders.

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Without the legal basis that the Macolin Convention provides, the work of the National Platform can only go so far before legislative constraints arise.