Compliance Updates
Our UKGC consultation response: Failing to protect the vulnerable should not be the White Paper’s legacy
The dust has settled and the process is complete. The consultation on the proposed changes outlined in the UK Gambling White Paper is closed so now we just have to wait and see. Whilst we do so, we thought that in the spirit of transparency, we would share our own thoughts, more or less as they were communicated in our consultation response to the UK Gambling Commision.
Offering a real-time customer risk profiling tool, ClearStake’s focus was obviously on affordability checks. But then, much of the industry’s attention has been on this topic over the last few months. This is, to our mind, the single most important challenge facing the sector. Addressing it in the right way, a way that protects both punters and operators, will be the key to a sustainable, profitable future.
And with that goal uppermost in our mind, here is what we said:
1. Affordability checks must use real financial data
Certainly at the levels of spend proposed as meriting more thorough checks (£1,000 in a day or £2,000 over the space of three months), we don’t believe there is any real substitute for real financial data, by which we mean bank data. There is simply no other way of establishing whether a player can afford to lose this amount of money or not. Everything else – including data from credit reference agencies – is guesswork. We believe that the single greatest mistake that could be made during this process is not solving the problem of financial harm caused by gambling. That won’t be an issue if the government requires decisions to be made by operators in possession of a proper financial picture of their customers.
2. We can solve two problems at once
The consultation focused on affordability checks, but it would be almost perverse to ignore the wider reality at play here. Operators also have to perform anti money-laundering and source-of-funds (SOF) checks on their customers, and they do so by looking at bank statements. Given this is the case, it makes a lot of sense to us to effectively combine both these requirements within a single check.
3. At higher spend levels, it makes sense to keep customers connected
There has been a lot of talk about how frequently checks should take place, or to put that another way, whether it should be necessary to go back to a customer within six months or a year if they have already passed a check. To us, this rather misses the opportunity presented by Open Banking in particular. After the first check, assuming the player allows it, any checks in future can be entirely frictionless. The connection can remain in place and used when necessary (and only when necessary!) in order to make the ongoing compliance relationship as smooth as possible. We don’t expect ongoing connection to be mandated, but it should certainly be held up as best practice for all concerned.
4. Some of the proposed data points make little sense
When a solution that takes guesswork out of the equation is available, does it really make sense to suggest that postcodes and job titles are meaningful ways to determine an individual’s financial situation? We don’t think so. We believe that continuing to ‘lean in’ to data like this gives a misleading impression that it is good enough. It isn’t. Even as part of a broader decision-making process, it is very difficult to see where some of these data points fit in. You could say the same, of course, about missed loan repayments from three years ago.
5. The solution exists – why cobble together a new one?
Hovering behind the entire consultation process appears to be a not-quite-defined ‘solution’ to the affordability challenge. This is apparent in the various hints towards the use of CATO data (let’s just say it, even if the Commission aren’t willing to) and a hodge-podge of random data points in order to make affordability decisions, as part of a system that would have to be piloted in order to ensure a) it works and b) it doesn’t create data security issues.
Leaving aside the absurdity of asking us to judge the merits of an approach that hasn’t actually been defined, we would simply point out that in Open Banking, a solution to this challenge already exists. One that is already used by over 7 million people in the UK, by most UK operators to handle payments, and already used to handle affordability and SOF checks by forward-thinking operators. Why on earth are we re-inventing the wheel?
So there you have it. That’s what we told the consultation, albeit in language a little less colourful. I hope they listen.
The Victorian Gambling and Casino Control Commission (VGCCC) has fined the Werribee RSL $30,000 for failing to prevent 2 self-excluded customers from gambling.
VGCCC CEO Suzy Neilan said: “This is the first time the VGCCC has taken disciplinary action against a club or hotel for self-exclusion breaches.
“Self-exclusion programs empower people to manage their gambling by registering to be temporarily or permanently blocked from entering gambling areas of clubs, pubs and casinos.
“By failing to respect a person’s decision to self-exclude, a venue may put customers who have decided to take a break from gambling, or quit altogether, at risk of experiencing gambling harm.”
In January 2024, the VGCCC received an anonymous tip-off that a self-excluded person entered the Werribee RSL gaming room and used the poker machines. The venue self-reported a second breach in May 2024, after realising a different customer had gambled at the venue on at least 4 occasions between February and May 2024.
Ms Neilan said: “Taking disciplinary action is the last resort. We would prefer venues take their harm minimisation responsibilities seriously by complying with their legal obligations, including through the effective implementation of tools like self-exclusion.
“Venues and their staff are the last line of defence for self-excluded customers, who should be able to trust that their decision to self-exclude will be respected. They must have the appropriate controls in place to prevent self-excluded people from entering gaming rooms.”
The VGCCC acknowledged that Werribee RSL cooperated with the investigations and has since taken steps to strengthen its procedures. These include improved and regular staff training, daily audits of the self-exclusion register and greater use of technology to identify self-excluded customers who attempt to enter the gaming room.
This remedial action was taken into consideration in determining the amount of the fine.
The post VGCCC Fines Werribee RSL for Self-exclusion Failures appeared first on European Gaming Industry News.
Konami Gaming Inc. announced successful completion of Gaming-related Vendor Licensing in the United Arab Emirates (UAE), a key emerging market for commercial gaming. Konami Gaming is among the first in the industry to be awarded a Gaming-Related Vendor License by the General Commercial Gaming Regulatory Authority (GCGRA), an independent entity of the UAE Federal Government with exclusive jurisdiction to regulate, license, and supervise all UAE commercial gaming activities. A leading global provider of casino games and casino management systems, Konami has been awarded official license to serve the UAE’s developing gaming market with its award-winning products and services.
“Since Konami Gaming’s inception, our global growth has been achieved with an unwavering commitment to compliance. As the United Arab Emirates expands its economy to the regulated commercial gaming space, Konami is dedicated to supporting this market with the same integrity, innovation, and excellence we bring to all 431 gaming jurisdictions we serve worldwide,” said Tom Jingoli, president & chief operating officer at Konami Gaming.
For a quarter century, casino players have enjoyed Konami Gaming’s slot machines for the Class III gaming space, in which game outcomes are determined by random number generators (RNG). The company has since expanded its world-famous casino entertainment to online gaming and a variety of central determination market sectors. Additionally, Konami Gaming has spent over 20 years delivering its industry-leading SYNKROS casino management system to some of the largest and most diverse gaming destinations on earth, with ultra-reliable 99.99% uptime.
The post Konami Gaming Awarded Gaming-related Vendor License in the UAE appeared first on European Gaming Industry News.
The Australian Communications and Media Authority (ACMA) has issued ReadyBet with a remedial direction after the company marketed to customers who had registered with BetStop – the National Self-Exclusion Register (NSER).
An ACMA investigation found ReadyBet sent 273 texts and push notifications from its mobile app to self-excluded individuals.
Separately, the company also failed to promote the NSER in 2342 push notifications despite it being mandatory to promote BetStop in any marketing electronic messages.
The ACMA issued the remedial direction so that ReadyBet takes action to prevent it breaching the rules in the future.
Under the remedial direction, ReadyBet must commission an independent review of its marketing systems, including its use of third-party suppliers.
ReadyBet must also engage a provider to deliver training to its staff to avoid messages being sent to self-excluded individuals.
The ACMA may seek civil penalties if ReadyBet does not comply with the remedial direction.
The post ACMA: ReadyBet Breaches Gambling Self-exclusion Rules appeared first on European Gaming Industry News.
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