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Comlot
1) Short (TL; DR)
Comlot - the former inter-cantonal lottery and betting commission - was transformed into Gespa, the modern inter-cantonal oversight body for lotteries, sports betting and skill games (including online formats). Gespa sets rules, issues permits, monitors Responsible Gaming and AML/KYC, restricts illegal sites, and proceeds from lotteries/betting are directed to sports, culture and social projects. Casinos and online casinos remain the zone of the federal regulator ESBK.
2) Gespa's mandate and area of responsibility
What regulates:- Lotteries (including numerical, instant/scratch, circulation).
- Sports betting (retail and online).
- Skill games ("skill games") when they fall into the money circuit.
- Who is supervised: lottery and betting operators (including Swisslos and Loterie Romande), their channel partners (retail, web, applications), technology and distribution providers.
- Where valid: at cantonal level (through inter-cantonal agreement); coordination between all cantons is key to uniformity of rules.
3) Evolution: Comlot to Gespa
Comlot (Inter-cantonal Commission on Lotteries and Betting) carried out supervision in the era of the "two laws" of the 20th century.
With the "digital reversal" and the adoption in 2019 of a unified framework for money games, an institutional modernization was carried out: Comlot was transformed into Gespa - a body with an updated mandate, technical standards and online supervision tools.
Bottom line: a single inter-channel regulator for lotteries/bets/skill games, synchronized with the federal casino circuit (ESBK).
4) Role splitting: Gespa vs ESBK
Gespa (cantons): lotteries, sports betting, skill games; permits, advertising controls, RG/AML, online surveillance and block lists for these verticals; distribution of income for public purposes.
ESBK (federation): land casinos, online casinos, honesty of casino games, federal requirements for information security/AML/RG in the casino segment.
Joint tasks: fight against illegal online offer, unification of requirements for advertising and protection of players.
5) Legal and organizational framework
The inter-cantonal agreement (concordat) on money games is the source of Gespa's authority.
The modern 2019 "money games" law has integrated offline and online, strengthening the role of cantons in lotteries/betting and cementing the supervisory architecture.
Gespa internal regulations: permit procedures, technical requirements for sales systems, reporting, audit.
6) Product approvals and controls
Product expertise: draw/coefficient mechanics, randomization generation (for relevant games), return to player, transparency of conditions.
Distribution channels: retail (POS/terminals), online sites and applications - all under permission and technical control.
Responsibility for changes: any updates of mechanics, interfaces, advertising materials are agreed/declared according to the procedures.
7) Responsible Gaming (RG)
Player tools: age verification (18 +), deposit/bet/time limits, self-exclusion, "pauses," clear visibility of risks.
Operator processes: behavior monitoring, identification of vulnerable patterns (including frequent "catch-up" rates), documented interventions and routing to the assistance service.
Communications: honest information about the chances, a ban on misleading wording, understandable terms of shares and bonuses.
8) AML/KYC and financial circuit
KYC before access to online products and payments; for retail - proportional control mechanisms and prevention of sale to minors.
Transaction monitoring: anomaly flags, prevention of "structuring" and laundering, case management, reporting.
Payment providers: contracts, SLAs, logging and compliance audits.
9) Advertising and Marketing
Prohibition of hyper-advertising and targeting of minors/vulnerable groups.
Moderation and truthfulness: odds and limits should be transparent; bonus terms - explicitly prior to participation.
Responsible tonality: RG messages, access to help, balance "entertainment vs risk."
10) Online surveillance and countering the gray market
Blocking unlicensed sites in lottery and betting verticals; interaction with communication providers.
Signals to platforms: requirements for removing illegal applications/ads.
Coordination with ESBK: exchange of lists and practices on site and payment blocks so that there are no regulatory "gaps."
11) Community Mission and Revenue Sharing
Lottery and wagering revenues administered at the cantonal level (through Swisslos and Loterie Romande) are allocated to sports, culture and social projects.
The principle of legitimation: "games are allowed because they bring tangible benefits to society with high consumer protection."
12) Supervision tools and sanctions
Scheduled/unscheduled inspections, data requests, technical and compliance audits.
Measures of influence: prescriptions, fines, restrictions on the product line/channels, suspension of permits; in case of malicious violations - recall.
Publicity of measures: disciplines operators and increases the confidence of players.
13) Operator's checklist (practice)
People: designated compliance officer, RG/AML front and support training.
Processes: KYC/AML policies, RG intervention procedures, incident management, role-based access.
Technologies: logging, anti-fraud rules, data storage and backup, content version control and mechanics.
Communications: fair offers, visible bonus conditions, RG banners, age gates.
Suppliers: due diligence of sales/payment/IT channels, prescribed SLA and audit rights.
14) Maturity and Compliance KPIs
RG: proportion of players with active limits, speed and effectiveness of interventions, reduction of repeated risks.
AML: auto-approve share with low false positives, timeliness of STR/reports.
Advertising/UX: complaints about introductory communication → to zero; transparency of stock terms.
Technical circuit: MTTD/MTTR, absence of critical vulnerabilities in the product, completeness of logs.
Social effect: the volume of transfers to sports/culture/social projects, transparency of reporting.
15) The bottom line
Comlot's successor, Gespa, makes the Swiss lottery and sports betting market transparent, socially useful and technologically disciplined. Strict RG, reliable AML/KYC, moderate advertising and active online hygiene (blocking of "gray" sites) form the trust of players and society. In conjunction with the federal ESBK in charge of casinos, the Swiss model shows a rare combination of restraint of scale and high quality regulation.