Government White Paper. Why are we waiting?
With our Compliance Forum and Workshop coming up we hand over to our MD Paula to set the scene and talk about a certain Government White Paper…
Government White Paper. Why are we waiting?
Is there a Government White Paper about to land that could have some serious implications for the future of the regulated UK gambling industry? Was that just a rumor or a crazy dream I had perhaps?
I was trying to recall when it was that we first started talking about the forthcoming overhaul of the 2005 Gambling Act. The last live event we ran before COVID hit was in January 2020 and we were definitely anticipating it then. I recall Jason Chess, Partner at Wiggin LLP giving an excellent regulatory review where he looked into his crystal ball and talked about the tide of negative press and public opinion and the impact it was likely to have on legislation. Brigid Simmonds, who at the time, was fresh in post as Chairman of the BGC also warned that a fragmented industry would not influence the new UK Gambling Act.
It was all systems go back then and change was imminent.
Fast forward almost two and a half years and we are still waiting. Oh why are we waiting? And just as important, is the question of what have we seen since then? The White Paper may be chronically delayed but there has been no such rest bite for the professionals across the industry whose job it is to keep crime out of gambling, ensure gambling is conducted in a fair and open way and protect the young and vulnerable from gambling related harms.
In fact since the beginning of 2019 we have seen the cutting of the maximum stake on FOBT machines from £100 to £2. Tightened rules around identity checks and age verification. Mandatory sign up for all operators to GamStop. Industry working groups coming together to tackle key issues like VIP schemes, game design and responsible marketing. Banning of gambling on credit cards. Implementation of guidance designed to protect customers during COVID lockdowns. New rules on game design for online slots. Updated UKGC guidance on fair and transparent terms of practice. A tightening of advertising rules designed to protect under 18’s. And new remote customer interaction requirements that will come into force in September this year.
Have I missed anything?
I’m sure I have but you get my point! On top of that little lot there have been loads of updates to AML/CFT guidance and POCA advice and guidance around sanctions and the war in Ukraine. Not to forget the day to day running of operations to contend with. Add into the mix the topics that come up on literally every event research call I do – affordability and the single customer view project. I think it is fair to say, this isn’t a line of work for anyone looking for an easy life!
So what of that tide of negative press and public opinion Jason Chess talked about? Has there been any let up there? I would say a resounding no! All of the work put in by the industry doesn’t sell papers so it doesn’t get a look in on the popular press narrative. The heavy influence of the prohibition lobby on the other hand has the ear of the reporters and the politicians alike.
I’m not saying these voices should not be listened to. Of course they should. Furthermore the tragic stories they represent are why this is so very important and has to be got right. It is also dangerous to try and regulate our way through this though. History tells us that prohibition doesn’t work.
The BGC has repeatedly pointed out the threat of pushing potentially vulnerable customers to the black market. I don’t disagree with them, I think the threat is very real. I also see the points they make about public finances derived from taxes raised through gambling and the jobs the industry provides. Of course it is not the simple picture we are led to believe that gambling is bad – far from it.
We were promised an evidence based review, is that what we think we will actually get? I’m not so sure. How much evaluation has taken place regarding the effectiveness of any of the measures I mention above and all the other great work that goes into combating gambling related harm and keeping crime out of the industry? It feels to me like we move on from one “silver bullet” to the next with no time to stop and reflect on the fact there isn’t a single silver bullet that will solve the problem.
Problem Gambling. A mental health issue.
I spent some time last week with the team at Gordon Moody and it is very clear talking to them that problem gambling is a mental health issue. The same message Certified Psychotherapist and Founder of The Infinite Recovery Project, Jason Shiers promoted when he spoke at our event in March, for many people who are suffering gambling is the solution – an escapist or avoidant behavior. We have to move away from this idea that the industry is bad. We have to involve all stakeholders and work together to address the problem.
Measures taken by operators to identify issues, intervene, provide safer gambling tools are effective and important. I see it as a staggered net that can catch and help people at all levels.
The work we do is not just about compliance, it’s about making a difference and to do that the compliance has to be right. That’s why we have a very practical focus at our next event The KnowNow Compliance Forum and Workshop which will be taking place on 28th and 29th June.
When will we get the White Paper? Your guess is as good as mine. However we do not have to wait until then to move forward and make a difference. If you are a Head of Responsible Gambling, Head of Compliance or MLRO – you’ve got a lot on your plate already. Let’s keep talking about those issues, roll up our sleeves and get on with the job at hand.
Compliance Forum and Workshop.