Mapping a route to compliance amid ongoing uncertainty

As operators wait with baited breath as to when the white paper into the Gambling Act 2005 review will be released, there are several rumours flying around as to what regulatory changes there will be and how long the UK Gambling Commission will give operators to fall in line with the changes.

Within this piece we will examine what these requirements could be and how operators will need to adapt to become compliant with them.

Let’s first focus on the new player monitoring requirements.

The Gambling Commission has made clear that it expects operators to properly map out processes for player monitoring and to introduce automated systems if they have not done so already.

The entire customer journey must be fully documented so that operators can evidence how they are monitoring players and what happens in the event they hit a threshold or trigger a marker or markers of harm.

They must also show exactly how each player was communicated to and the effectiveness of said communication.

This means being able to spell out exactly what is done at every single player touchpoint while the player is engaged with the online operator’s sportsbook or casino, from onboarding through to payments, gaming activity, bonusing and customer support.

The challenge for operators is to ensure they are compliant with these new, stringent requirements while not interrupting the player experience. Anything that adds more friction to the user journey significantly increases the risk of players wagering elsewhere.

To overcome this, operators should look to solutions that allow them to hard-wire risk levels and triggers and combine this with automation to ensure real-time engagement and interaction with players that could be displaying early signs of problem play.

Automation removes the reliance on humans, and this mitigates an operator’s exposure to human error. If a player triggers a marker of harm, the required action happens automatically, and this means that compliance managers can sleep soundly at night.

Of course, in order to set relevant markers and triggers for each player, operators must first ascertain the customer’s standard playing patterns. Each player is different and that must be taken into account here.

For example, it might be that it is entirely normal for Player A to deposit £1,000 at the start of each month and then play slot games each night of the week between the hours of 9pm and 11pm with stakes varying from £0.50 to £1.

For Player B, standard gambling behaviour might be depositing £10 on a Saturday and then placing five accumulator bets each with a stake of £2.

Once the player’s standard gambling behaviour has been understood, operators then need to set markers and triggers that alert them if the player begins to deviate away from their norm.

Automation advantage

This is actually fairly straightforward – it just means setting hard rules that are monitored and if these rules are broken then a predetermined action takes place automatically. This is why automation is so important, and why the Gambling Commission now requires operators to use it.

And it is no wonder given the sheer number of transactions that operators process – to monitor these manually is simply impossible. It is worth noting that some operators already use automation, but their systems might not be as efficient as they could be, nor meet the regulator’s new requirements.

For example, they might have a system in place that can automatically pull a report, but it might be 24 hours after a player’s gambling session. It could also be the case that it takes several individuals from several departments to put the report together.

Not only is this inefficient for the operator, but by the time the report on the player has been compiled the damage can already be done. This leads to players slipping through the gaps, and this can lead to the Gambling Commission handing out fines for non-compliance.

The new requirements brought in on 12 September should be seen as a positive move and so too should any changes that come out of the government’s review of the Gambling Act 2005. Ultimately, we need to protect players but also remember that we are in the entertainment business.

Striking the balance between the two becomes more challenging regarding affordability. When it comes down to it, the regulator will likely expect operators to ascertain how much a player earns to be able to determine how much they can afford to gamble.

The only way to do this accurately is for the operator to access a player’s payslip or bank statement, and obtaining this information adds major friction to the onboarding process and overall user journey.

There is a tool that can do this in the background, which is used in a wide range of industries to determine affordability but has been restricted for gambling operators to access for the time being.

This really does make it difficult for operators and should be cause for concern for the wider industry. Players are often unwilling to hand over payslips and bank statements and will move from brand to brand until they can deposit and play without having to do so.

This often means they end up landing on an unlicensed online sportsbook or casino where there are little to no protections in place. Of course, this scenario is the exact opposite of what regulators such as the UK Gambling Commission are hoping to achieve with the tightening of their requirements.

Adam Doyle possesses over 13 years of experience in identity management and fraud specialising within the gambling industry. As RiskNarrative’s head of gaming (LexisNexis Risk Solutions), his experience, knowledge and contacts in the gambling sector is outstanding.