����vlog����

Preroll: PolicyCast explores research-based policy solutions to the big problems we’re facing in our society and our world. This podcast is a production of the Kennedy School of Government at Harvard University. 

Intro (Malcolm Sparrow): The second thing that’s worrisome about that is that their business model actually depends upon this irresponsibility. More than half of their revenues come from people- they might not past all of the clinical tests for problem gambling- but they’re somewhere on the at-risk spectrum. They’re suffering at least some consequence in their lives. They’re unable to stop. And if in fact we were to treat or somehow exclude all of those problem gamblers, the whole industry would collapse. So the business model depends on making sure that that is actually not fully controlled. 

Intro (Ralph Ranalli): Turbocharged by the internet and mobile technology, legalized gambling has exploded across the globe, leaving behind ruined lives, broken families and financial hardships. A four-year study by a public health commission on gambling convened by The Lancet, one of the world’s oldest and most respected medical journal, concluded that gambling should now be classified as a major public health concern. The commission found that net annual global losses by gamblers could exceed $700 billion by the year 2028, and that half of the gambling industry’s revenues are coming from people who have a gambling problem or are at risk for having one. Commission member and ����vlog���� Professor Malcolm Sparrow, a leading scholar on regulating societal harms, says that while 80% of the world’s countries allow some form of legal gambling, in reality the industry’s penetration is closer to 100% because internet- and mobile-based gambling can easily circumvent borders. Among the commission’s more concerning findings is that 1 in 5 teenagers had gambled within the past year, and 26% of those teens are at risk for compulsive or problem gamblers—significantly higher than the risk for adults. Sparrow says gambling’s harms are also widespread, since the suffering attached to each problem gambler affects, on average, six to eight people around them—ranging from spouses to relatives to friends to employers and co-workers. He joins me today to talk about the problem, and a number of policy solutions to mitigate the growing fallout from gambling expansion, ranging from limiting the speed and intensity of virtual gambling products to prohibiting gambling with credit cards and banning gaming companies from offering loans. 

Ralph Ranalli: Malcolm, welcome to PolicyCast. 

Malcolm Sparrow: Thank you very much. 

Ralph Ranalli: The report of the Lancet Public Health Commission on gambling, which was just released, says that, quote, the evolution of the gambling industry is at a crucial juncture. Decisive action now can prevent or mitigate widespread harm to population health and well being in the future. I really wanted to start with that. Why is this moment, as opposed to other moments in the evolution of the gambling industry, an inflection point? 

Malcolm Sparrow: I think because of three big trends that have been running pretty fast lately, and our suspicion is that the world doesn’t really understand the trajectory and just how broad and aggressive the growth of the industry is. And so there’s three components to it. 

First of all, around the world there is a general trend towards increased legalization where up to about 80 percent of countries permit some form of gambling or another. And the trend is still towards more rather than less. Second, the nature of the products are turning digital. So rather than have to go to a casino, have to go to a bookmakers, wander into the corner store to buy your weekly lottery ticket- which is the way things used to be- the casino is now available on your smartphone and it’s in your pocket and it’s available 24 hours a day. It’s available seven days a week, without those kinds of natural impediments to engage. And the third piece is deliberate and aggressive expansion into lower- and middle-income countries, where this is new to them, and they might not have a strong regulatory infrastructure or any regulatory infrastructure at all in relation to gambling policy, and it’s being pushed very aggressively. 

The combination of these three things means that, at the population level, the exposure to gambling, the pressures to engage, the normalization of gambling all of that is running apace. And what we’re eager to do—I’m fairly new to the public health literature—but one of the things that I understand in the literature on other unhealthy commodity industries such as alcohol and tobacco, a lot of commentators these days talk about the long wait. The very long period that it took us to really establish and to be able to prove the medical consequences of alcohol consumption and tobacco. And, even as controls kick in and global collaboratives are set up to help drive down the rates of these particular problems, that curve has done an enormous amount of damage in the meantime. 

Now, the field of gambling is not as mature- anything like as mature- either in terms of research studies available, the epidemiology, the global surveillance and monitoring systems, they’re largely not there or not as complete as we would like them to be. So there’s a lot we still don’t know. But we think that we can see enough about the trajectory to be alarmed, and that we want to alarm people before we have another long period, a long wait, before everything is proven and finally controls come into place. 

Ralph Ranalli: So I want to dive into some of the details on those various components of this, but I wanted to start with you. You have a very interesting background. You have background in law enforcement from the London Police. You’re also a PhD mathematician. You’re a specialist in regulatory policy. Tell me how that all came together to you working on gambling as an issue. 

Speaker: Thank you. 

Malcolm Sparrow: Gambling is merely one type of harm, and my business these days at the Kennedy School is harm reduction, or risk control, and specifically the role of regulatory policy and practice in the context of governments controlling risks or threats or problems to the community. So I’m not one of the experts on gambling that has spent a whole career studying gambling policy. I have this broader background which is weird and it’s serendipitous and it’s a product of various changes in my professional life that I took. Trained as a mathematician, I joined the police in England principally because I was interested in public service and public service now. Not advances that might pay off 300 years from now.

And then I came to the Kennedy School as a student on a fellowship while I was in the police, and was persuaded by some colleagues here at the Kennedy School, particularly Mark Moore, that he thought- and I believed him- that I could have more impact on the policing profession from outside the profession rather than from inside and with a broader reach around the globe. When I arrived at the Kennedy School, clearly with an interest in working on police strategy and tactics amongst other things, I discovered that the police profession doesn’t really move very fast, and it takes them ten years as a profession to absorb one really good idea. And they had two already at the time in 1988. And my phone wasn’t ringing, I, I wasn’t used to that. In the police, the issue is which phone do you answer next? It’s not, my phone is not ringing, what shall I do now? I never had that luxury before. 

So I started taking odd jobs, with no apparent connection. I worked with the Environmental Protection Agency on what they called intelligent use of environmental information. I worked with the IRS on compliance management strategy and also on fraud control, because my last job in the Kent police was head of the fraud investigation unit. 

So all kinds of miscellaneous compliance regulatory activities and it wasn’t very long at all—in fact the first time it occurred to me I was lying in the bath—and having dealt with the IRS and the EPA and the police profession, I thought: “Wow, there are extraordinary parallels between these fields in terms of their aspirations and their frustrations and the organizational puzzles that they’re dealing with, what kind of performance story do they want to tell.” They just use slightly different language or vocabulary to describe these concepts, and they never spoke to one another. 

So I started convening them here at Harvard—a great place for convening power—and so we brought together folks at conferences and enabled them to explore the lessons that they might learn from each other. And then as the years unfolded, more and more regulators came to me rather than me going to them, and they said, me too, me too. Please include us in this conversation. And it was clear by the year 2000 when I published “The Regulatory Craft,” that there were broad themes right across the regulatory frontier. And so I have, ever since then, taught and written specifically about the issues which are common horizontally across the whole regulatory frontier and without me having to claim that I’m an expert in any one of them. 

So I’m not an expert at gambling. If I were an expert at any of these, it would be fraud control, perhaps corruption control, from my police background—certainly crime control. I’ve learned quite a lot along the way about environmental protection. But this commission actually has a very interesting composition in that regard because, we have on the commission amongst 14 members, about six or seven that I would say have spent their entire professional careers focused on gambling or most of their professional careers focused on gambling and gambling policy. But we also have public health experts. We have a lot of people with experience with other addictions. So we have experts on alcohol and tobacco, and we have links to the World Health Organization which is essentially the world’s convener on such issues. 

Ralph Ranalli: Well, in terms of regulatory challenges, this is quite impressive that you decided to take this one because I was looking at some of the numbers and they almost seemed a little fantastical, because the commission report estimates that 46. 2 percent of adults and 17. 9 percent of adolescents in the world had engaged in gambling in some form within the previous year. That’s almost every other adult. 

Malcolm Sparrow: Yes. 

Ralph Ranalli: And it almost seems like, do we just not notice gambling anymore? Because it is so ubiquitous? 

Malcolm Sparrow: And you might also ask, do we believe those numbers to be true? So, I’ll tell you what they’re based on, and this commission, during its three and a half years, almost four years of work, commissioned some particular studies which scraped up information available all over the Earth, and then tried to do systematic analysis based on it. And one of those studies was on the epidemiology of gambling worldwide in a way that has not been done before. So the method was to find amongst all of the studies of gambling prevalence, those that actually relied on a random or representative sampling, a population level, statistically valid, and then using self-assessment, and there were more than 300 of those, and they do not cover the whole world, but they cover an awful lot of it. And by aggregating all of those study populations and then extrapolating to the global population, that’s how these figures were generated. 

Now, we should put some caveats on the figures. First of all, we don’t have data from some regions. The global monitoring system is really not complete. 

Ralph Ranalli: Right. 

Malcolm Sparrow: So we’ve got a lot more information about advanced economies and about European countries than we have about Asia and about Africa or Latin America. 

Ralph Ranalli: And that’s where the growth is, right? The growth now is in those low and moderate income countries too, where governments probably don’t have the bandwidth to really dive into what’s going on from a statistical standpoint. 

Malcolm Sparrow: Exactly. These are the expansion markets, and in some senses the most worrying. But the other thing about these aggregate statistics is that they rely on self report even in the context of an anonymous survey, and there is enough stigma still attached to being a problem gambler or recognizing that you have a problem with your gambling behaviors, that we know the estimates will always be conservative and that there’s a lot of under reporting. So, yes, we’ve got some missing regions. There may be regional bias. We’ve also got a pretty clear sense that these are likely underestimates. The most alarming of the statistics that you picked out there is the, I think it’s 17. 9 percent of, young people... 

Ralph Ranalli: Of adolescents, yeah. 

Malcolm Sparrow: ...of adolescents, that’s 10 through 19 in the public health world. 

Ralph Ranalli: The other one that jumped out at me was that online gambling could affect more than 26 percent of adolescents. That’s a quarter of adolescents. Yeah. Because we know adolescents are glued to their phones. And the phone has become one of the primary delivery vehicles for gambling. 

Malcolm Sparrow: Well, another thing that we know is that if there an international consensus on any aspect of gambling policy, it’s that young people shouldn’t be allowed, and they should be rigorously excluded. And this is an alarmingly high figure, given such a broad consensus that they ought to be effectively excluded. 

Ralph Ranalli: And I think that also goes, again, back to the technology of the delivery system. Because it’s a lot easier to exclude someone who looks too young from entrance to a horse track or into a Las Vegas sports betting parlor or a casino. But, there’s a lot of ways to fake who’s on the other end of the phone. Is the mobile gambling to you the most worrisome piece of this and to the commission? 

Malcolm Sparrow: Well, the digitization is a big piece, and the mobile or ubiquitous access all around the world. So, I said 80 percent of countries permit some form of gambling, but even in the other 20 percent that don’t you can’t stop people accessing the internet. It is a borderless phenomenon. So even in countries like Iran and Iraq and even in countries that under Islamic law prohibit gambling, because it’s forbidden by the Quran, there is an underground gambling community and there is an online access. I did an experiment on Google the other day. I said "If I’m in Iran and I want to gamble, where should I go? And up come a list of online gambling sites that are absolutely available, and they are trying to show that they’re reliable and fair, and some of them based in Malta, and other offshore settings, and a lot of them will ask you to use cryptocurrency to fund your gambling because it retains its anonymity. We had one commission member who was a psychiatrist in Indonesia, and in Indonesia gambling of all kinds is illegal. But they have a massive national problem with young people becoming addicted to online gambling. And short of taking utter control of the internet and using massive blocking systems, which they don’t do, this remains an unsolved issue. 

That’s not the only feature, though, of digitization that concerned us. The other major feature is the nature of the products that are being invented; a lot of the digital products are much more immersive. They’re fast moving. They can roll continuously. Sports betting, for instance, used to be that you could bet on the outcome of a match. Now you can bet every three minutes on some particular feature of it. Who’s going to win this? 

Ralph Ranalli: Almost an unlimited number of side bets. 

Malcolm Sparrow: Exactly. Is this person going to score this penalty or not? Who’s going to be the first to score from the other side? In which minute of the game is it going to happen? So very fast, you can lose money a lot quicker. And a lot of the products being designed now are immersive by design. They are trying to work out—this is the behavior of the global gambling industry, some people have referred to it as addiction by design—they want to produce an environment where you will get lost, where you will enter the zone, that you will lose track of time passing. 

Ralph Ranalli: Your classic casino tricks, the pumping in of oxygen, the arrangement of the machine so you can’t find the exit. No windows, no clocks, so you lose track of time. 

Malcolm Sparrow: Alcohol and tobacco available to you in that setting also. 

Ralph Ranalli: Right. It’s a stimulant and alcohol to lower your inhibitions. 

Malcolm Sparrow: So we believe that a lot of the new digital products are more dangerous. The most dangerous seem to be online casino games and electronic gaming machines. And you say, well, how come, almost half of the world is gambling? The answer is, well, lotteries is the most common participation product. And lotteries are not the most dangerous thing. But even lotteries now, it used to be once a week, and in a lot of jurisdictions, we’re now running them every hour. So, the opportunity for people to do what’s called chasing their losses. You lost some money, and in order to get even, you gamble more. And you always believe in the reversal of your fortunes. 

Ralph Ranalli: Even though, I think most frequent gamblers know the bottom line truth, which is that you lose. That statistically the system is set up so that over a long enough time period, you always lose, right? I mean, there may be temporary wins and maybe the statistically odd lucky person, but anyway, there’s the old saying that, you know, the gaming industry, you know, really creates two products, which is lies and losers. The lie is that you’re gonna be a winner. And they create losers. 

Malcolm Sparrow: Well, the only person that would ever win, and he’s a very rare individual, is somebody who wins big and then stops. That is an extremely rare, phenomenon, to win big and then stop. Okay, if you think that we’re all rational actors, of course we should all know that we’re going to lose in the end, otherwise this industry would not exist. But now look at the adverts and look at the messaging that the industry is putting out. 

I don’t know whether many people do this, but I roam Europe with a VPN looking for various sports that I love to watch, I watch tennis tournaments and some of them I can find in Romania on TV that I can’t find any other place. And you watch almost any sport in many of these European countries and all of the commercial breaks are gambling, gambling, gambling. And in some cases, it’s the same advert being shown two, three times in succession. And in fact, when Belgium tried to shut down recently gambling advertising on TV, they had a huge political objection from the TV industry, which was, of course, financially struggling anyway. And their argument was: We will go under if we don’t get these gambling adverts. But the nature of the gambling advert—it’s going to be a room packed with people, a happy social environment. They’re slapping each other on the back and having a jolly good time. And they’re celebrating win, win, win. 

Ralph Ranalli: You never see anyone lose on a casino commercial. 

Malcolm Sparrow: Well, particularly what you don’t see is a husband having to explain to the wife why there are no groceries. But the grocery money has gone. 

Ralph Ranalli: Right. And it’s more serious than groceries. The Commission report talks about, broken relationships, health effects, crime-related impacts. 

Malcolm Sparrow: Yes. 

Ralph Ranalli: Increased risk for domestic violence, increased risk for suicidality. How do you get that message out, that those harms are out there, and that they’re real, and they deserve paying attention to? 

Malcolm Sparrow: This is something that we wanted to try and do by the collection of evidence and all of the studies that were available. On the issue of suicide, we can’t claim a mortality rate like the alcohol problem can, three million people a year. But we’re learning, and one of our commissioners from Australia recently ran a systematic review of all of the completed suicides in Victoria, Australia, and established that in about 5 percent of completed suicides, gambling losses were a substantial factor. So it’s not theoretical. And we engaged not a systematic study of lived experience participants, but a collection of them that had stories to tell, and a lot of them referred to depression and anxiety and related suicidality. So, that’s one important message, the harms associated with gambling. I think the obvious one is financial loss and the possibility of financial ruin. But also we have all of these other mental health effects, possible relationship breakdowns, and, all kinds of adverse impacts on other aspects of your life. 

The financial imperative, of course, for a private corporation is to return maximum profits for the shareholders. They will achieve that by extracting from a gambler all the money that they have. But not stop there, all the money that they can borrow. So the harm is then more broadly distributed, and one of the common features—it’s actually part of the clinical checklist—is when other people end up bailing you out financially because of your gambling habit or your gambling debts. So that’s one piece. 

There’s a much broader range of harms experienced in many different dimensions of your life, including loss of employment. The other thing worth making plain is that for every problem gambler—and that’s a defined term, it’s part of the ICD-11 classification system, so it’s a recognized disorder—for every person in that category, studies have shown that on average between six and eight other people suffer. It’s not just the individual, it’s their family, could be their friends, could be their employer, it could be colleagues so there’s a much broader range of people involved and effect on communities and societies, not just families and individuals. 

Ralph Ranalli: Yeah, and economic effects too. At the workplace there’s loss of productivity. 

Malcolm Sparrow: Yes. 

Ralph Ranalli: Absenteeism. 

Malcolm Sparrow: Yes. 

Ralph Ranalli: So, let’s turn to the regulatory challenge here, because to me, just with my layman’s view of it from the outside, it seems like an enormous one. Starting with the fact that it’s growing because it’s popular with governments. I mean, it creates individual dependencies, but it also creates situational dependencies where, like you said, the television stations depend on the advertising revenue and the governments depend on the revenue from lotteries and also from taxes on casinos. I don’t think this is necessarily accurate, but it’s described as like an easy way to tax or a victimless way to tax. 

Malcolm Sparrow: And you have mentioned parts of what we call the commercial determinants of gambling harm, which are many and varied. And it’s not just the gambling industry, but they are, of course, closely aligned now with major sporting bodies, they are deeply embedded with media outlets. They have to be tied into international financial systems, otherwise they can’t clear their transactions. So, there’s a huge commercial infrastructure that surrounds it. Now in terms of legislation and what’s been driving it lately—this is apart from the epidemiological aggregation that the commission did—another major study that we commissioned and then have absorbed into the report is an examination of all of the legislative changes around gambling in the last five years—that’s from 2018 onwards. And there were 80 legislative changes in various jurisdictions that we could find, and we actually read through the text of all of these documents to find out, well, what was driving them. That’s often displayed in the preamble or in accompanying white papers or whatever. They say why we’re going to do something, and by the way, here’s the new policy. And the major—you’ve mentioned some of the major drivers—and important thing to establish is not only what are the major drivers, but how are they ranked? Which ones take precedence? Which is the dominant force? 

So one theme is health, and that means potential for addiction and gambling disorder and providing medical options; protection of public health. Another is the integrity of the gaming to make sure that it’s fair and that consumers aren’t being cheated by the nature of the game, either by the operators or by other players. A third one is the elimination of crime. The involvement of organized crime pops up in gambling all over the world. And gambling can be used for money laundering very effectively with a variety of techniques. So, to keep that out. And then there’s economic growth and prosperity and employment opportunities, and on the economic front, governments actually using this as an alternate to general taxation. 

Ralph Ranalli: Right. The money goes to schools, to education, the money goes to public safety, those sorts of pitches. 

Malcolm Sparrow: That makes it smell nice. If the revenue that you raise through a lottery is actually designated for socially attractive purposes. But even there, you have to take into account, I think we should take more into account, the fact that this is a regressive form of taxation, The burden falls disproportionately on those who are least able to afford it and not all, but a very significant proportion of people using government run lotteries are already facing financial stress of one kind or another. 

Ralph Ranalli: And it only makes sense if you are trapped in a low-income job with very few prospects for advancement and increased wealth, why wouldn’t you grab at this—even if it’s ephemeral—chance to get out of the hole, to break out of your economic straits. 

Malcolm Sparrow: Well, that argument is actually a very major component of the way gambling is pushed in African countries, very poor countries with an awful lot of poverty. People in poverty will gamble because they think there is a chance that they will win big, stop, and change their life. And of course, the majority of them don’t, and the more they lose, the deeper the pocket into which they find themselves. And there’s an irony there. Suppose somebody in Africa does win big and stop and changes their life. They are the best possible advert for other people all around them to gamble. This could happen to you too. 

Ralph Ranalli: Exactly. 

Malcolm Sparrow: So from the gambling industry’s perspective, the existence of such a person is a massive, boon. 

Ralph Ranalli: So in terms of the regulation, there’s this dichotomy between the need to address irresponsible gambling or problem gambling or disordered gambling. And not to necessarily focus on, what is referred to in the report as population level approaches, population level regulations. Can you explain the difference between those, that individual focus and the population level? 

Malcolm Sparrow: Yes. Background, the sort of orthodox beliefs about gambling change over time. And I don’t know exactly how far you have to go back in America before gambling was basically dishonorable and happened in dens and you associated it with criminality and it wasn’t something that you’d talk about as an ordinary citizen. That’s all changed, huge efforts to normalize this, portray it, the industry loves to portray it as harmless entertainment enjoyed by many, and they recognize gambling harms, but they want to say that those are utterly concentrated in a very small group of people who unfortunately can’t control their impulses. 

So they call them the “irresponsible gambler.” They like to present a picture where there’s two classes of gambler. There’s the recreational gambler for whom this is just another form of entertainment and isn’t any kind of a problem. And then this tiny sliver of people called irresponsible or problem gamblers or those suffering gambling disorder, to use a technical term. And they say, well, we’re concerned about those people too and we’re going to help them and we’re going to offer them therapy programs and have self-help devices like limiting your losses and limiting your time on the app and so on. And that’s the way they’d like everyone to understand this problem. There’s a whole host of things worrisome about that particular orthodoxy or portrayal of the system. And the first, probably the biggest one, is it completely deflects attention away from the corporate behavior. It puts all of the responsibility on some gambler at a low level who’s fallen foul and now is suffering. 

Meanwhile, what are the corporations up to? Well, they’re designing products which are addictive and immersive by design. They’re hunting diligently for heavy gamblers. If a heavy gambler stops gambling, they go after them with personalized offers and bonuses and here’s some free money. You know, here’s $500 of free bets. Please come back. We’d love to see you again, Malcolm. And they know full well that you’ll not only lose this $500, but then you’re back in and you’ll go on and lose your own money. And if that weren’t the case, they wouldn’t do it. So they are making sure that heavy gamblers cannot escape and doing everything that they can to keep them in the fold. 

The second thing that’s worrisome about that is that their business model actually depends upon this “irresponsibility.” More than half of their revenues come from people—they might not pass all of the clinical tests for problem gambling—but they’re somewhere on the at-risk spectrum. They’re suffering at least some consequence in their lives. They’re unable to stop. And if in fact we were to treat or somehow exclude all of those problem gamblers, the whole industry would collapse. So the business model depends on making sure that that is actually not fully controlled. 

Another thing we know about the help that they offer—the self-help opportunities to go for counseling, to impose limits—very few people take up those offers. The uptake rate, for people that should take help is 8 to 10 percent according to different studies. So most don’t, and that’s presumably partly because of the stigma as well as continuing denial that you really have a problem. And notice, that those that do take these forms of help have usually hit rock bottom already. So the damage is already done. And there’s no undoing it. So the industry is helping people and making a show of helping people when actually the damage is already done. 

Ralph Ranalli: So these more universal measures that the commission is favoring, what do they include? What is their effectiveness? How are they more effective in at least limiting the harms that are coming from the industry? 

Malcolm Sparrow: Let’s start with an analogy. If you’re worried about the adverse effects of alcohol consumption, one thing that you can do is offer treatment to individuals who have become addicted to alcohol and maybe it’s gone as far as cirrhosis of the liver or whatever other medical condition arises from it. So that’s an individual level, after the fact, reactive response. And of course it’s important that those therapies and treatments are available. But when the world puts its head together and says, no, this is an unhealthy commodity, we start thinking about population level exposure, and all kinds of methods to reduce deliberately both the demand and the supply of alcohol or tobacco products. 

So it’s unapologetic, the public health approach. If you look at the framework convention on tobacco: it’s a UN treaty, 2005, it has 180 country signatories and it is quite unapologetic about their goal. They want to reduce collaboratively both the demand and the supply of tobacco. Now of course that’s anathema to the gambling operators. It’s basically an undoing of their whole reason for existence and so of course they would hate it. And when you take that kind of approach, then you have to be very careful to make sure that the powerful influence from the industry is somehow excluded from policymaking, the powerful effects that they can have in managing what kinds of research get done and what kinds of research finding get published. You have to insulate research and policymaking from the self-serving interests of the industry. 

Ralph Ranalli: It was interesting because I had a little experience that called that to mind when I was doing some research for this show because I wanted to see if I could find numbers where that compared relative to say an industry like manufacturing how many jobs are actually created by the casino industry? I did a Google search, and I got pages and pages and pages of gambling industry generated happy news about what an economic boon gambling was. So it was clear to me just from that one experience that, they are incredibly influential, and they work very hard to not be regulated in that way. So where do you start? Where do you start from a real-world regulatory strategy standpoint, how do you start this journey towards, regulating gambling the way we regulate alcohol and the way we regulate tobacco? 

Malcolm Sparrow: Well, the population level controls, there are analogs exactly from those other fields. So you would move to an emphasis on the whole population exposure. You would limit marketing, sponsorship, arrangements, the normalization. You would counter the industry’s message about normalization with a counter message, powerfully delivered. You would do early childhood preventive education—about middle school seems to be the important moment—before they get sucked into it in high school or college. No, this isn’t normal, and no, whatever your friends tell you, you don’t have to do this. There would be rigorous controls on the protection of vulnerable groups, especially young people. 

So, where do you hope to go in the long term? Well, let me be really ambitious on behalf of the commission. What’s the biggest long-term thing that we could hope for? That we would establish gambling as a UCI, as opposed to the industry’s story of harmless entertainment and economic opportunity. 

I thought it was pretty interesting, I went and looked up the UN Framework Convention on tobacco control. It came into force in 2005 with this unapologetic goal of reducing demand and supply. They lay out principles. Number one, protect public health policies from commercial and other vested interests of the industry. Protect people from exposure to tobacco smoke. Now that’s interesting, because that’s a secondhand effect for others around a smoker. Which is also one of our points. So, I see these six to eight other people adversely affected by anyone that falls into problematic gambling. Regulate the contents of tobacco products—so one of the things that we’ve done is try to figure out criteria that make one gambling product more dangerous than another and urge countries to start regulating dangerousness of the products. Germany is ahead on that, but it’s pretty rare. Warn people about the dangers, ban tobacco advertising, promotion, and sponsorship. A lot of countries do ban gambling advertising. 

Even though the trend still is towards greater legalization, it’s not ubiquitous, it’s not inevitable. I mean, in America, the federal restriction on online sports betting was lifted in 2018, and since then, 38 states have legalized it. But that’s not 50. It’s 38. So 12 have said no. Two states in America don’t allow any form of gambling, and they are Utah and Hawaii. 

Ralph Ranalli: Hawaii, right. 

Malcolm Sparrow: Utah for religious reasons, Hawaii for cultural and social reasons. There are four or five other states that restrict most forms of gambling, usually allowing government lotteries and a few other things. 

Ralph Ranalli: Malcolm, this is the part of PolicyCast where we get down to the policy nitty gritty and talk about specific policy solutions. What are the policies that have been proven to work that you would prioritize doing right now? 

Malcolm Sparrow: Well there’s an awful lot of possibilities worth examining, ’cause you just look around different countries and there’s a million different ideas. There are relatively few interventions that have actually been subjected to rigorous academic study and where we can say we have evidence that this works. But for some other ones we do—there’s some population level controls and there’s some individual level controls that do work. Population level controls, enforce rigorous enforcement of legal age limits—that’s clearly not happening if 17.9 percent of adolescents worldwide have gambled sometime in the last 12 months. The American figures are higher than most other countries for that. 

Limiting bet sizes. Now we’re quite accustomed to one of the self-help options being, before you begin your gambling episode you can establish a limit and it will stop at that point. But mandatory limit setting is much, much more effective. There’s a set of European countries, at least four, where they keep a central registry of gamblers, and you can’t gamble with any commercial company without registering centrally with the regulator or the government. And then they keep track of your losses, and they establish aggregate loss limits for the whole year. So, you’re not allowed to lose more than 1,800 euros in a year, for instance. Notice that that doesn’t rely on an individual to uptake the offer of assistance and control. These are government enforced restrictions. 

We know that limiting the speed and intensity of certain gambling products can be very, very useful, particularly because it addresses the most dangerous products and the most addictive products. And we know that it’s important to keep ATMs away from gambling locations. We know that it’s important to prohibit gambling on credit or with credit cards. 

Brazil is a fascinating case study. They authorized online gambling in 2018 or 17. And they have faced a massive invasion of gambling companies wanting to come and operate in Brazil. So much so that the minister of finance in September, just a few weeks ago, announced publicly that, in his view, Brazil was suffering an epidemic of family financial catastrophes as a result of this this wave. And there’s two things working in concert together: widespread availability of gambling options and very easy credit. So easy, in fact, that some of the gambling sites would actually give you a loan. So when you finished your gambling session, not only had you lost your money, but you also walked away with enforceable debt that you had now established. And as of October, I believe they put a moratorium on any new gambling companies coming and getting authorization to work in Brazil. And they’re also putting in place regulations to unwind the loan availability from the gambling opportunity, prohibit those companies from offering loans. And they want to prohibit gambling on credit. We know it works if you distance loan opportunities from gambling. We know it helps if you ban smoking and alcohol at gambling venues, and we know it’s important to keep gambling opportunities away from educational establishments. Those are some of the population level ones. 

At the individual level. There are some methods. There are many things touted, but not many of them turn out to be effective. And a lot of the reason for that is late and low uptake rates. Things that do work: tracking of a gambler’s, behavior, with the offer of personalized feedback and an intervention from a regulator. You look like you’re headed for trouble and here’s an opportunity to beware. Cognitive behavioral therapy has proved to be quite useful when people do come and ask for help. Support groups such as Gambler’s Anonymous—mixed evidence, but there does seem to be a small effect there. And a wide variety of educational programs. They vary enormously, so it’s actually hard to make an aggregate assessment, but some of them have been potentially effective. 

Ralph Ranalli: Well, this sounds like you have your work cut out for you and it’s a terrific challenge and I wish you all the best of luck with it. So thanks for being here. Malcolm Sparrow: I appreciate your interest in it. Thank you very much. 

Outro (Ralph Ranalli): Thanks for listening. If you liked this episode, please don’t forget to subscribe to PolicyCast on Apple Podcasts or your favorite podcasting app, so you don’t miss any of our important upcoming episodes. And please leave us a review while you’re there. And until next time, remember to speak bravely, and listen generously.