ONE DAY DURING a recent college football bowl season, Las Vegas-based analysts tasked with monitoring for suspicious activity in sports betting noticed a sudden, dramatic change in the line for one of the next day’s games. The odds for a team that had been a significant favorite were dropping rapidly, and money was piling into the matchup.

“We saw tens of millions of dollars come in overnight,” said Matthew Holt, president of U.S. Integrity, the 14-person private company that contracts with sportsbooks, colleges, leagues, conferences and states to monitor betting lines and report suspicious behavior.

The next morning, news broke that several players on the favored team, including many starters, would not play because of COVID-19 protocols. Further investigation found that an equipment manager had leaked the news to bettors the day before, and their subsequent wagers moved the line, Holt said.

Holt declined to name the school. No criminal charges were brought, and the circumstances were never made public, in part because of confidentiality agreements between parties involved and U.S. Integrity. But Holt said the equipment manager was fired as a result.

In a sense, the system worked in that one case. But it’s anyone’s guess as to how many cases go undetected or how many get reported but don’t result in any action.

Sports betting has exploded into a multibillion-dollar business in just four years since dozens of states made it legal, but no single entity is responsible for making sure the wagering is fair. The industry successfully lobbied against legislation that would set federal standards or establish a national body for so-called “integrity monitoring” — the detection of match-fixing, inside-information leaks, athlete exploitation and officials on the take.

So U.S. Integrity and a handful of other private companies and nonprofits are attempting to fill the gap on an ad hoc basis. Absent federal standards, they must navigate a patchwork of inconsistent laws across states. Absent enforcement authority, they have to rely on their clients or on law enforcement to hunt down and punish cheaters. When integrity monitors find evidence of manipulation, where that information goes and whether it’s used to crack down on bad actors is unclear and often undisclosed by regulators, making it impossible for the public to know how often cases are suspected, investigated or prosecuted.

Oklahoma State University assistant professor John Holden, who has published research on match-fixing and other game manipulation and sports gaming regulation, said he believes integrity monitors catch some — but not all — low-level match-fixing. And Holden said a system that relies on private enterprise and not law enforcement to analyze gambling data has no chance against the sophisticated type of cheating that often happens outside the United States.

“There are some aspects of sports betting that would benefit from efficiencies in handling it at the federal level,” Holden said. “I think creating a federal entity to monitor market integrity, and which has the ability to conduct investigations across jurisdictions, is reasonable.”

While he said he didn’t think there was an “epidemic of match-fixing” going on, he added, “I think it’s laughable that we play — I don’t know — 4,000 college basketball games, and none of them would be fixed. I just don’t think that’s realistic.”

Holden said legalized betting comes with an expectation that games will unfold “according to a certain set of rules.”

“When it doesn’t, there is a disadvantage because they’re missing a key piece of information that someone else benefitted from,” he said.

AMONG INTEGRITY MONITORING services in this country, U.S. Integrity is unique among for-profit companies in that it doesn’t engage in other gambling-related activities. Sportradar and Genius Sports, for example, have monitoring services, but also sell data feeds to customers including sportsbooks. There’s also the International Betting Integrity Association, a nonprofit run by dues-paying sportsbook members who share reports of, and send out alerts about, suspicious activity. FanDuel and DraftKings are two of its biggest U.S. partners.

Holt said analysts for U.S. Integrity, which has more than 100 clients, review raw betting data, athlete performance data and officiating patterns, along with social media feeds and other sources of information, to assess what’s moving betting lines.

They’ll look for correlations between unusual wagering and possible anomalies in actions by athletes, officials or others, and whether news about injuries or player status was made public before or after bets started changing, giving them a hint to whether information was leaked prematurely to bettors.

Every case is different, but when analysts detect suspicious activity, Holt said the company alerts the clients involved, and, after further investigation alongside those organizations, decides whether the information needs to be passed on to state regulators or law enforcement. He said U.S. Integrity, on average, sends out about 15 alerts of suspicious activity per month, and that incidents most often involve misuse of inside information.

“The most common is the people who have access to the players themselves, who tend to get the injury information first. It’s equipment managers and trainers because either the trainer gets called and says, ‘Hey, don’t bother getting up at 5 a.m. to tape these ankles or do this. He’s not going to play tonight,'” or it’s an equipment manager who is told not to get an athlete’s gear ready, Holt said.

Analysts can find correlation and outliers in their data sources that point to suspicious activity. They can also get information from their sportsbook clients that tells them who places bets, where and how they’re placing bets, and, if it warrants, analysts will let the team, league or association know.

But not every U.S. Integrity report results in discovering the source of suspicious line movement. The company itself has no authority to take legal action or pursue any type of punishment, and it sometimes doesn’t always know what happens after it sends an alert to clients and regulators, who can access phone records, emails and compel people to talk.

In some cases, clients prefer to resolve the case by terminating an employee rather than pursuing criminal charges. “That often is the case because it avoids reputational harm,” U.S. Integrity chief operating officer Scott Sadin said. “You want to keep these things confidential and sensitive as possible.”

Holden said he worries about reports traveling on a “one-way street,” especially when it comes to contracts with leagues.

Matt Fowler, the director of integrity at the International Betting Integrity Association, said sportsbooks, for one, are financially motivated to report suspicious activity. “If they have invested significant amounts in getting their lines right, but then they’re the victims of corruptions, then they will be the ones who lose money on that,” he said. “A match-fixing scandal would have a huge impact on a sport league or club’s reputation.”

But Holt, U.S. Integrity’s president, argued that relying on sportsbooks to raise the alarm over suspicious activity can result in only certain cases coming forward, especially when they involve major leagues that are their corporate partners. Alerts typically involve “some ninth-tier tennis or sub sport in some far-off country in some far-off land because that doesn’t offend their corporate partners,” he said. The International Betting Integrity Association, for example, issued 39 alerts in the United States from 2017 to 2021 of suspicious activity, but none involving collegiate or professional leagues of major sports, according to its own data.

One of U.S. Integrity’s clients is the West Coast Conference. Commissioner Gloria Nevarez said she relies on the company to spot anomalies that could point to influencing outcomes of games, but also to monitor officiating, over which the conference has primary jurisdiction.

“If you look into the background of the official themselves, you look for any kind of connection with a common bettor, either at that geography, past dealings, increased cash purchases of luxury items,” she said. “Sometimes it’s just a statistical anomaly. Other times there might be something more there.”

Nevarez said an official who had worked conference games for several years started to make anomalous calls that affected the point spread of games. In this case, there was a history of fraud between that official and a bettor. When asked what happened to that official or what action the conference took, Nevarez said she was not at liberty to say. The WCC, like other sports conferences, is a nonprofit association and not a public agency subject to open records disclosure.

AFTER THE PROFESSIONAL and Amateur Sports Protection Act was overturned in 2018 to allow states to offer sports gaming, the industry and states successfully opposed proposed federal legislation that would have imposed nationwide integrity monitoring standards, Oklahoma State’s Holden said.

The bill had bipartisan sponsorship from Sen. Orrin Hatch (R-Utah) and Sen. Chuck Schumer (D-N.Y.) and would have, among other provisions, added extortion and blackmail to federal match-fixing prohibitions and established punishments for betting with wrongfully obtained nonpublic information. The bill also included a mandate for a national sports wagering clearinghouse that would have maintained records of sports betting data and suspicious transactions and alerted federal and state law enforcement of suspect trends and anomalies. The bill was introduced in the U.S. Senate in December 2018 but never made it past the judiciary committee.

“Too many states had already rolled out their own regulatory frameworks, and threatening to undo these new regulatory models or cut into projected state tax revenues was not going to be a politically expedient move,” Holden said in an email. “Another factor working against the bill was it was effectively trying to be proactive. There was no real catalyst (other than lobbying, I suspect), no integrity disaster spurring Congress on — it was just the federal government trying to get into the weeds of an emerging industry.”

A spokesman for Schumer’s office said the Senator still sees the need for federal oversight of sports gambling but, “absent a Republican co-sponsor,” doesn’t currently have plans to reintroduce legislation for it.

Aside from federal laws that prohibit match-fixing, laws banning illegal activity vary state by state, making the business of integrity monitoring even more difficult, Holt said. Enforcement of the rules is also inconsistent; state gaming associations, state and local police, colleges, casinos and sportsbook all have a hand in punishing bad actors.

“Not only do we have to try to identify all these things against people that are really good at hiding them, we have to do it 50 different ways in 50 different jurisdictions,” Holt said, adding that he’d like to see the United States adopt some national standards across sports betting.

As an example, in the case of the equipment manager who ended up getting fired, Holt said the law in that state — which he declined to name to ESPN — wasn’t clear about whether such activity was illegal, and there wasn’t enough to build a criminal case without proving intent.

Some states have laws that prohibit athletic-team employees from engaging in certain wagering activity, but most lack penalties for someone who would use their inside information to make bets or sell it to someone else making wagers. According to data compiled by LegalSportsReport, a site that tracks sports betting trends and legislation, 23 states and Washington, D.C., have laws that prohibit an athlete from betting. Eight states and Washington, D.C., explicitly ban the use of nonpublic information, the data show.

“What we don’t have is universal rules or laws across the board that say it is illegal for you to use inside information for the purposes of profiting off sports betting. We have that in the financial services world,” Holt said, citing insider trading laws. “I think we’re still on first base when it comes to getting all the laws and safeguards we need in place.”

States including Tennessee enacted laws or regulations to help prevent opportunities for manipulation. Several states limit or ban betting on certain teams or leagues or making certain wagers — such as in-play bets in college sports — to prevent people from trying to bribe or exploit athletes, officials or staff.

Tennessee, which Holt says has better-than-average laws, requires sportsbooks to be a member of an integrity monitoring association. Sportsbooks also must share information about any suspicious activity with the Tennessee Sports Wagering Advisory Council, an agency with regulatory authority but not law enforcement power, within 24 hours. Tennessee also has a law that makes it a criminal misdemeanor to share “nonpublic information for the purpose of wagering on a sporting event.”

Mary Beth Thomas, executive director of the council, used to work as general counsel in the secretary of state’s office, where she had some experience regulating daily fantasy sports in 2016. She said she’s met with local district attorneys and law enforcement to raise their awareness of misbehavior in sports betting.

“Just as a starting point to say, ‘Hey, you know, we’re here, we’re regulating this, regulating this industry. And in the event that there is an issue that is under the criminal purview of law enforcement, we would like to be able to send it to you,'” she said.

Chris Cylke, senior vice president of government relations with the American Gaming Association, the trade group for the casino and sports betting industry, said state laws could draw “brighter lines” to delineate activity in which someone simply has an edge versus improper use of information that “calls into question … the fairness of the system.”

Cylke said the industry could address imposing greater penalties for potential malfeasance. “We would always be open to a discussion of amending the laws or regulations in a way that would make it more clear and easy to prosecute anyone who has done something wrong or perceived to be wrong. Or let’s clarify what is right and wrong,” he said.

Harold Wafer, event wagering and fantasy sports administrator with the Arizona Department of Gaming, started his job as a regulator last year when the state approved sports betting. He was previously a sportsbook operator and was mentored by sportsbook giants Bob Gregorka and Muggsy Muniz. He worked the phone rooms and learned about “booking the faces,” knowing the customers and their betting habits by sight.

Like many regulators, he relies on integrity monitors and sportsbooks who, in many cases, are legally required to pass on reports of suspicious activity — although he said that’s not always well defined. In an interview from the FanDuel sportsbook at the Footprint Center in Phoenix, home to the Suns and the Mercury, where potential bettors have to pass through metal detectors and show identification, he said his own staff doesn’t have the resources to do that work. When asked what state laws would pertain to criminal match fixing, he said he’d have to consult the gaming agreement legislation that was “this thick” as he raised his hand several inches off the table.

Wafer has two agents, an analyst and an auditor, and he said the industry in Arizona has already outgrown his staff. He’s hoping to add an analyst and a couple of more agents to meet the current demand. And with plans by the Arizona Cardinals to get a stadium sportsbook, and by DraftKings to put a location on a PGA Tour golf course in Scottsdale, he said he’ll need even more.

IN 2018, IN response to the anticipated growth in state-by-state legalized gambling, the FBI started its Integrity in Sports and Gaming Program unit. The FBI has a long history of gaming enforcement, using statutes under bribery, corruption, fraud and interstate communications to catch match-fixing. It was the law enforcement agency that investigated former NBA referee Tim Donaghy, who pleaded guilty in 2007 to conspiracy to engage in wire fraud and transmitting wagering information through interstate commerce in a match-fixing scandal.

But the FBI task force doesn’t do its own analysis to catch cheaters and relies instead on tips, including those from private integrity monitoring firms, according to two members of the task force who spoke to ESPN. They declined to say how often they receive tips, but when asked to list cases that resulted in action by the U.S. Attorney’s Office, a spokeswoman pointed out two cases: one that involved a man threatening athletes, but with no apparent attempt to influence betting or manipulate a game, and another pertaining to Olympic doping issues.

“We’re not in a position to comment on any trends related to our investigations,” Erin Omahen, a management and program analyst with the FBI’s Integrity in Sports and Gaming unit, “but I can say, confidently, that industry research suggests gambling — both legal and illegal — has grown tremendously due to the pandemic. During that time, there were a lot of people at home and reports of many brick and mortar casinos closing.”

Sadin, U.S. Integrity’s chief operating officer, said that over the past few years the company has relayed at least three cases to the FBI. He said there have been “many other” cases involving local law enforcement, which include social media harassment of athletes.

Sadin described another incident in which a person was fired from a job because of “nefarious” betting activity: “We also thought there was sufficient evidence to take things further. Law enforcement did not think that there was a ‘smoking gun,’ and so the property that we worked with decided to terminate as opposed to pursue any further legal action,” he said.

ESPN REACHED OUT to regulators in all states that started offering sports wagering after May 2018, when the Professional and Amateur Sports Protection Act was overturned, to get a sense of the number of cases they’ve faced involving suspicious betting behavior. Of those 27 jurisdictions, not one pointed to an enforcement action or criminal charge made in response to an integrity concern raised with a U.S. sporting event pertaining to game manipulation or improper use of inside information.

That doesn’t mean there weren’t penalties or punishments imposed by a university, conference, sports association or professional league, as happened in March when the NFL suspended Falcons wide receiver Calvin Ridley for at least the 2022 season after he was caught betting on professional football games.

Some state and tribal regulators did not respond at all to requests for a number of reports or enforcement actions, and a couple noted cases that were under investigation, including one in Louisiana, but would not offer specifics. In Indiana, a representative said its statutes require it to keep reports from its private integrity monitor confidential and suggested reaching out to the monitoring company — U.S. Integrity — for more information. But U.S. Integrity has confidentiality agreements with states, including Indiana, that prevent the company and Holt from sharing information.

In New Jersey, which was one of the first states to offer sports gambling in summer 2018, a spokesperson declined to provide any reports to ESPN. It instead directed inquiries to the International Betting Integrity Association. The spokesperson also noted that when information results in public-facing action, it is disseminated by the agency, and, by example, provided a link to a July 2020 ESPN story about potential match-fixing in Ukrainian table tennis — a concern brought to regulators’ attention by an ESPN investigation published two months earlier. When pressed for further information on enforcement actions, the New Jersey Division of Gaming Enforcement spokesperson replied in an email, “You have our response.”

“I have no idea why the gaming commissions are so secretive,” Oklahoma State’s Holden said. “They refuse to answer just about anything from my experience. I mean, they’re public entities. … The idea is we deter it because you tell people we’re catching people doing this. So secrecy, if anything, hinders that.”

Cylke, with the American Gaming Association, said he personally feels that more transparency can help. While incidents might garner some negative attention, “it’s good from a deterrence standpoint,” he said.

ESPN reporter David Purdum and researcher John Mastroberardino contributed to this report.