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RiskNarrative: impending UK regulations to take protection to the next level

Fresh rules set to be introduced next month by the UK Gambling Commission are a “positive move,” noted Adam Doyle, Head of Gaming at RiskNarrative, but there’s a fear that operators “will rush to make the necessary changes to ensure compliance”.

The comments come amid a pending introduction by the regulator, from September 12, 2022, as part of an “ongoing drive to make gambling in Britain safer,” with the rules aiming to be stronger and more prescriptive.

They include further information for remote gambling businesses on identifying vulnerable customers; indicators of harm they must monitor for, including what is considered strong; when to use automated systems and processes; and how to evaluate the impact of customer interactions.

Doyle voiced optimism at the directives, noting that the current regulatory framework is “doing a good job” of ensuring a fun yet safe experience, but adding that “there is always room for improvement”.

“I think the new regulations coming into force in September will certainly take protection to the next level,” he commented.

“This will be achieved by monitoring a specific range of indicators, as a minimum, to identify gambling harm, flagging indicators of harm, acting in a timely manner and implementing automated processes for strong indicators of harm, among other things.

“Ultimately, these new regulations are designed to bridge the gap between technology and responsible gambling, and that is a good thing.”

Despite acknowledging that operators have known about the regulatory changes for a number of months, Doyle continued by suggesting that implementing these could prove a lengthy and costly process.


Answering “yes and no” when quizzed on if operators have been afforded adequate time to implement the range of provisions stipulated, he said: “This is certainly the case when it comes to legacy technologies and internal protocols.

“Of course, those that are struggling to implement the changes in time should take a closer look at why this might be the case as regulation often changes and operators must be ready at the drop of a hat to meet any new requirements that come into force.

“This is certainly the case in the UK where the Gambling Act is currently under review, with yet more changes undoubtedly set to come.”

With the greatest challenge to be encountered identified as being experienced in making sure that various systems are speaking to one another, especially if they are siloed.

“The costs of compliance are increasing significantly, not only to meet the new requirements being rolled out in September but generally and certainly for international operators that are active in multiple markets,” Doyle stated.

“In order to clear this hurdle, operators should look to an orchestration platform, and this requires investing in best-in-class technologies rather than simply throwing people at the problem and tasking them with finding a solution with what they have been given.”

Upon previously disclosing the fresh introductions, the UKGC added that licensed incumbents must have in place effective systems and processes to monitor customer activity, use a range of indicators relevant to their customer and the nature of gambling provided, take appropriate action in a timely manner, and tailor the type of action they take based on the number and level of indicators.

Indicators that must be used to identify harm or potential harm include customer spend, patterns of spend, time spent participating in the activity, gambling behaviour indicators, customer-led contact, use of gambling management tools and account indicators.


Furthermore, licensees were also reminded of the importance of preventing marketing and the take up of new bonus offers where strong indicators of harm have been identified. They must also implement processes to understand the impact of individual interactions, and take all reasonable steps to evaluate the effectiveness of their overall approach.

Continuing his examination of the new rules, Doyle looked at if the raft of introductions could have any potential negative impacts: “There is a risk that operators will rush to make the necessary changes to ensure compliance, and this could negatively impact the player experience.

“Any added friction during the onboarding and monitoring process can and often does mean that players drop off, which obviously has a negative impact on new customers and ultimately revenues.

“What’s more, regulations are always open to interpretation, and each operator will likely take a different stance on what they believe is expected of them.

“This will undoubtedly lead to some implementing more stringent responsible gambling processes than is actually required under the new regulations, and this could see them lose out if, again, this adds unnecessary friction to player onboarding and monitoring.”

Ahead of the September 12 cut-off, and in an attempt to eliminate any wasted time in aligning with these fresh rules, Doyle points to the group’s Transaction Monitoring solution.

This, he added, allows operators to set triggers and threshold alerts for key activities including customer spend, patterns of spend, time spent gambling, gambling behaviour indicators and customer-led contact.

“This ensures that operators are monitoring the areas required by the new UKGC requirements while also leveraging the power of rules, data, machine learning and human intuition to stop fraud, money laundering and bad actors impacting their business and at the same time affording players the highest level of protection,” he ended.


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