The UK Gambling Commission recently released Raising Standards for Consumers, its enforcement report for 2017-2018. The report details the actions taken by the Commission during that two-year period and outlines the intent behind the publication in the introduction: “We want operators to pay attention to the lessons set out in this document.” This comes on the back of a new set of enforcement procedures outlined under previous Chief Executive Sarah Harrison’s jurisdiction.
These changes included a promise to hand out “higher penalties for breaches, particularly [over] systemic and repeated failings” and a plan to remove any bias towards settlements and include more direct license review, meaning operators should now consider themselves more at risk of a removal of license rather than a settlement or fine.
The UKGB has been active in handing out fines in recent years, and the document outlines the variety of circumstances in which this has taken place, detailing fines levied across multiple key areas of regulatory concern: anti-money laundering systems, customer interaction, the management of self-exclusion systems, ensuring that terms and conditions for customers are fair, marketing and advertising compliance, and penalties for illegal gambling.
Every significant communication made to operators over that year is detailed, with links included to original materials and documents detailing each specific major enforcement action taken. For example, within the anti-money laundering section, the Commission lists three major enforcement actions taken against operators: one against Silverbond Enterprises Limited, one against Stan James Online, and one against William Hill Group. The link leads to documents informing us that William Hill Group reached a settlement of around £6 million over anti-money laundering failings; we can, if we choose, go on to read about these failings in depth.
This is the first time the Commission has seen fit to publish such an annual review of its own enforcement actions, a move which sends a clear and very strong message to the industry.
The enforcement report, which is linked above, is fascinating and extremely detailed, and also contains a wide range of advice to operators on each of the above topics, including lists of sample questions which operators should be equipped to answer. The document is pitched directly at the industry, so simply reading through it and drawing up solid answers and approaches to every bullet point in it is probably an operator’s best route, or at least a beneficial one, to avoiding the risk of any potential enforcement action.
Neil McArthur, Chief Executive of the Commission, said the following upon release of the report: “We … want gambling businesses to collaborate and to invest the same amount of resources into data, technology and research into building better protections for consumers, as they do to creating new products, or advertising and marketing campaigns.
“This is a call to action to the leaders of operators to set the tone from the top, to lead a culture of compliance that puts doing the right thing for your customers first, and to strive to continuously raise standards for consumers.”
