When the Warning Signs are in the Data

Responsible gaming programs—especially online casinos & sportsbooks—must evolve from reactive intervention to proactive detection. Former casino executive Brian Carr discusses the way an operator approaches someone suspected of problem gambling.

The story of Terry Thompson reportedly losing $1.8 million to FanDuel has dominated headlines in recent months. According to reporting, his first wager with FanDuel came in 2020, when he began gambling through an app for the first time. He soon started placing microbets (in-game wagers) eventually wagering more than $18.5 million, resulting in a reported $1.8 million loss. 

That raises an important question.

What Should A Responsible Gaming Program Have Been Able To See?

Unlike a traditional brick-and-mortar casino, where a significant percentage of wagers are placed anonymously by guests who choose not to use a player’s card, every wager in an online casino or sportsbook is tied to a verified customer account.

The operator knows exactly:

• Who placed the wager.
• How much was wagered.
• Whether the wager won or lost.
• How frequently the customer plays.
• How wagering behavior changes over time.
• Lifetime deposits, withdrawals, and net losses.

Modern data analytics can identify behavioral changes that may warrant further review by responsible gaming professionals.  Large increases in wager size, rapidly increasing betting frequency, sustained losing streaks followed by larger wagers, repeated deposits in short periods of time, and wagering significantly above a customer’s historical patterns can all be identified automatically.

The technology already exists.

The data already exists.

The question is whether operators are expected to use it.

I spent more than 20 years in the casino industry, with much of that time leading or overseeing financial planning and analysis teams. During that time, one observation consistently stood out.

Most regular casino customers establish remarkably consistent patterns of play.

Consider a guest who typically budgets $200 per visit and comes once or twice each week.  That guest tends to follow a consistent pattern. They develop routines. They visit on the same days, play the same games, stay for roughly the same amount of time, and spend within a fairly consistent range. There are certainly exceptions, but the vast majority of frequent casino patrons establish behavioral patterns that remain stable over long periods.

When those patterns suddenly change, it may indicate that something has changed in the customer’s life.

Sometimes that change is positive—higher disposable income, a special celebration, or an extended vacation can all increase play temporarily.

What Are The Warning Signs?

Other times, however, dramatic changes can be warning signs.

In the brick-and-mortar casino, responsible gaming has never been solely about policies printed on brochures or signs posted near the cashier. It has always relied on people.

Casino employees are trained to recognize the signs of problem gambling. Dealers, slot attendants, hosts, cage personnel, and security officers spend hours interacting with guests every day. Through responsible gaming training, they learn to identify changes in a customer’s behavior, attitude, or demeanor that may indicate someone is no longer gambling for entertainment. It could be a guest making concerning statements about needing to win money back, displaying unusual frustration or desperation, extending play well beyond their normal routine, or exhibiting other behavioral changes that warrant concern.

Just as importantly, employees are trained on what to do next. They know who to notify, how to document their observations, and when to involve management or the property’s responsible gaming team. The goal isn’t to embarrass the guest or stop them from gambling altogether. It is to recognize potential warning signs and create an opportunity for intervention before the situation becomes more serious.

Online gaming removes virtually all those human interactions.

There is no dealer noticing a customer’s emotional state. No slot attendant observing someone who has been playing for twelve consecutive hours. No host recognizing that a regular guest’s behavior has changed dramatically over the past several visits. The opportunities for personal observation simply do not exist.

I am not suggesting that brick and mortar casinos have solved this problem.  I spent 20 years in brick and mortar casinos.  Every casino leader knows a story of a player who became a bigger and bigger part of a casino’s business only to flame out and “go bad”.  Hindsight is always 20/20.  On the national stage there have been several examples, none more prevalent than Terry Watanabe.  The former Oriental Trading Company owner who lost an estimated $204 million – $350 millon.  It is reported that at one point, Mr. Watanabe accounted for 20 percent of Caesars Palace gambling revenue for a year.  He even received a “special for him” level Chairman’s players card personally signed by Harrah’s CEO before he went broke.  During the ensuing trials and testimony, numerous stories came out that looking back should have been red flags.   

Because The Human Element Is Absent Online, Data Must Become The Equivalent Of The Casino Floor Employee.

If online operators cannot observe behavioral warning signs face-to-face, they should be expected to identify those same warning signs through customer data. Significant increases in wagering, rapidly escalating losses, unusual deposit patterns, dramatically longer playing sessions and other measurable changes in behavior can serve as the digital equivalent of the observations casino employees are trained to make every day. In the online environment, data analytics isn’t just another compliance tool—it is the primary means of identifying customers who may need responsible gaming intervention. 

The gaming industry already understands this concept in another area.

Anti-Money Laundering (AML) regulations require casinos to know their customers. Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), and Know Your Customer (KYC) requirements exist because regulators recognize that casinos cannot simply accept large amounts of money without asking reasonable questions about its source.

AML asks: “Does this financial activity present a risk that requires investigation?”

Years ago, casinos may have accepted a duffel bag filled with cash without much scrutiny. Today, that is no longer acceptable. Operators are expected to understand who their customers are, where the money comes from, and whether activity appears suspicious.

Responsible Gaming should evolve in much the same way.  RG should increasingly ask: “Does this gambling behavior represent a meaningful change that warrants review?”

Whether it is AML or RG, the system doesn’t automatically declare someone guilty of anything.

It identifies unusual activity that requires trained human review.  

It is important to note that not every change in gambling behavior represents gambling harm. A customer may increase their play because of a change in income, a special occasion, a vacation, or other legitimate circumstances. That is precisely why the objective should not be to have technology determine whether someone is a problem gambler. The objective should be to identify meaningful changes from a customer’s established pattern and give trained responsible gaming professionals the information they need to determine whether further action is appropriate.

Just like AML requirements, regulators should increasingly expect operators to demonstrate that they are actively monitoring customer behavior. Significant increases in wager size, betting frequency, total losses, repeated deposits, longer playing sessions, or other indicators of escalating behavior could automatically generate an internal review by the company’s Responsible Gaming or Regulatory Compliance team.

That review would determine whether the activity appears consistent with the customer’s historical behavior or whether additional responsible gaming measures are appropriate. The intervention could be as simple as a personal outreach, offering responsible gaming resources, recommending deposit or wagering limits, or temporarily suspending promotional offers while the situation is reviewed.

Technology Advancements Are Creating New Opportunities For Both Casinos And Regulatory Bodies To Become More Proactive. 

In a brick-and-mortar casino, implementing this type of proactive responsible gaming program has historically been challenging because much of the gaming activity remains unrated. If a customer chooses not to use a player’s card, the operator may have little visibility into that individual’s wagering activity, making it difficult to identify changes in behavior over time.  However, advancements in data analytics, artificial intelligence and other player-tracking technologies are creating new opportunities for casinos to identify behavioral patterns that may have previously gone unnoticed. Rather than relying solely on a customer asking for help or an employee recognizing a problem on the casino floor, operators can increasingly analyze changes in wagering behavior, session length, frequency of play, bet size and other indicators to identify potential risk earlier.

The goal should not be to use technology to label someone as a problem gambler. Technology (including AI) is creating opportunities to analyze large amounts of data quickly to identify potential warning signs that trained responsible gaming professionals can review and make informed RG decisions. 

Online gaming has demonstrated the potential of data-driven Responsible Gaming because virtually every wager and transaction can be captured. Land-based casinos have a more difficult challenge—but new technology is narrowing that gap.

The industry has already demonstrated that it can use this information to personalize promotions, predict customer value, identify VIP players, and maximize retention. Applying those same analytical tools to identify customers who may be experiencing gambling-related harm should not be viewed as an unreasonable expectation.

If regulators truly want responsible gaming to be more than a slogan, they should increasingly expect operators to demonstrate that their programs are supported by data, analytics, documented review processes and meaningful intervention standards.

The gaming industry has spent decades teaching its employees to recognize the warning signs of problem gambling. We now have the ability to teach our technology to recognize them as well.

The question is no longer whether the data exists. It does. The question is whether the industry is willing to use it.

Responsible Gaming cannot remain primarily reactive when technology increasingly allows operators to be proactive.

Brian R. Carr is a senior gaming executive and strategic advisor with more than 20 years of experience across the casino industry, including senior President, COO and CFO roles for Las Vegas Sands and Caesars Entertainment. With deep expertise in the Northeast gaming market, Brian helps gaming companies understand market dynamics, identify competitive threats, evaluate strategic opportunities and translate industry data and competitive intelligence into actionable operating decisions. Drawing on extensive experience leading casino operations, finance and strategy, Brian brings an operator’s perspective to complex business challenges—connecting market trends and financial performance to the decisions that drive growth, profitability and long-term competitive advantage.