Update on GAMSTOP

by Francesca Burnett-Hall, Associate

The new national online self-exclusion scheme, GAMSTOP®, is expected to be fully operational and available to consumers by the end of 2017.

GAMSTOP® has been designed by the Remote Gambling Association to aid operators in complying with their responsible gambling requirements and, specifically, social responsibility code 3.5.5 of the Commission’s Licence Conditions and Codes of Practice which sets out that “Licensees must participate in the national multi-operator self-exclusion scheme”. This provision applies to all remote operators who offer consumers online gambling products, other than society lottery operators who do not offer instant win games.

Operators must ensure that they register with GAMSTOP® in advance of the scheme launching. Registration is free and you can sign up on the GAMSTOP® Operator Portal, here.

GAMSTOP® will allow UK consumers to exclude themselves from all online gambling operators licensed by the Gambling Commission by way of a single website registration. Consumers will also be signposted to advice and support services to help them manage their gambling.

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Let’s talk about responsible gambling

Today marks the first day of Responsible Gambling Week, a cross-industry initiative to promote responsible gambling, with the theme “Let’s Talk about Responsible Gambling”. The initiative is organised by the Industry Group for Responsible Gambling (“IGRG”), chaired by John Hagan, and is intended to be a genuine and engaging conversation with customers, the wider public and other stakeholders to raise awareness of responsible gambling.

Responsible Gambling Week is a fantastic opportunity for the gambling industry to raise awareness of what tools are available to help people gamble responsibly, and share information on how to access help and support, for those who need it. What makes this week unique is that it will be the first time the industry has come together to speak with one voice to raise awareness.

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The Final Countdown – will Sweden adapt a more viable gambling law?

Guest post by Maria McDonald of Nordic Gambling

On 31 March 2017, a Swedish official inquiry regarding new gambling legislation was submitted. The inquiry has been unusually well received, and the majority of stakeholders have welcomed the much-needed changes to the market. And indeed, on paper, the suggestions do look promising.

Basic Licence Conditions

Based on the Danish model, the system will allow foreign gambling companies, Svenska Spel (gambling monopoly) and ATG (the Swedish horse racing monopoly) to seek licences for the competitive section of the market. The products included are online casino, online poker, online bingo as well as online and land-based betting. B2B-operators and certain other suppliers will also be obliged to hold licences.

No limitation on the total number of licences has been proposed, and there will not be any application window outside of which new licence applications cannot be submitted.

The proposed tax rate applicable to the competitive sector is 18 percent of the gross gambling revenue.

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Responsible Gambling Week

John Hagan spoke on 7 September 2017 at the KPMG eGaming Summit in the Isle of Man, on the subject of Responsible Gambling Week. The full text of his speech is replicated here.

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Upcoming conferences

Harris Hagan will be attending three conferences in the coming month or so.

On 7 September 2017, John Hagan will be attending the KPMG Isle of Man eGaming Summit where he will be presenting on the inaugural Responsible Gambling Week, which will take place between 12 and 18 October 2017. In addition, John will be participating in a timely session on the regulatory and political climate in the UK.

John will also be speaking on responsible gambling at the ‘Social Responsibility’ session at the IMGL conference in Copenhagen on 12 September 2017.

Finally, John and Bahar Alaeddini will be attending G2E in Las Vegas between 2 and 6 October 2017, where John will moderate the IAGA Best Practices: Responsible Gaming for Operators and Manufacturers panel on 2 October 2017 at 4.15pm.

Please get in touch with either John or Bahar if you would like to meet at one of the conferences they are attending.

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888 licence review and the Commission’s enforcement strategy

by Melanie Ellis, Senior Associate

The latest in a series of public statements relating to compliance failings revealed that 888 has been heavily penalised by the Gambling Commission for failing to protect vulnerable customers. The total financial penalty of £7.8m (including a payment of £4.25m in lieu of a fine and £3.5m in reimbursements to customers) represents by far the largest penalty against a licensee to date.

The issues

The Commission considered there was a breach by 888 of three social responsibility code provisions: (self-exclusion), (customer interaction) and (identification of individual customers). There were two key areas of failings:

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The chips don’t lie…online gambling in Colombia

guest post by David Collins and Estrellita Ramirez of Dentons

The evolution of the market

It has been widely reported that Colombia, and South America as a whole, are being targeted by major gambling industry players seeking to broaden their geographic reach and attracted by the perceived demand for online gambling services in the region. No doubt, there has been a rapid increase in the number of gambling operators and service providers interested in investing in those markets.

In October 2016, Colombia became the first South American jurisdiction to approve national online gambling legislation. Coljuegos, Colombia’s national regulatory body, believes the market could generate around COP8 bn ( approximately US$ 2.7bn) in revenue during its first year of operation, and that there will be at least seven licensed operators in the local market by the end of this year. To date, Coljuegos has approved one online gambling licensee, Aquila Global Group’s, which commenced its local online operations in June.

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Changes to Commission’s AML guidance

by Melanie Ellis, Senior Associate

by Melanie Ellis, Senior Associate

The Gambling Commission is consulting on revisions to its AML guidance for casinos, following the implementation of the new Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017(the “MLRs”) on 26 June 2017.

Given that the MLRs are already in force, this is a short consultation and responses must be provided to the Commission by 8 September 2017.

Some of the key changes proposed to the Commission’s guidance relate to:

– the customer due diligence threshold, which is now crossed by any transaction over €2,000, not just depositing or exchanging that amount for chips (for example a large win or series of wins would now be covered);

– the definition of and procedures for dealing with PEPs (politically exposed persons); and

– the fact that the nominated officer role may no longer be outsourced.

The new provisions of the MLRs are discussed in more detail in my recent article in iGaming Business, a copy of which can be found here.

Please get in touch if you would like our assistance with reviewing your AML Policy.

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Resolver: “Putting consumers first”

by Bahar Alaeddini, Partner

by Bahar Alaeddini, Partner

For some time, the Gambling Commission (the “Commission”) has emphasised to the industry the “importance of putting consumers at the heart of business culture and practice.” As part of its own commitment to achieving this, it approached the team behind Resolver to make it available for gambling consumers to use. From 1 August 2017 gambling consumers are now able to raise complaints against operators via Resolver.

Most readers are likely to have heard of Resolver, if only from the recent industry press attention it has attracted. It was first mentioned in the Commission’s March 2017 publication Complaints processes in the gambling industry a review one year after the introduction of the ADR scheme. At the time, and as remains the case, the Commission message was very clear; it wanted to see operators striving for excellence in handling consumer complaints and not merely focusing on meeting legal and regulatory requirements. The recent launch has prompted us to pop up the hood and take a closer look. If you are an avid Harris Hagan blog reader, you may notice that this blog post has been amended in light of a recent Resolver news alert.

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Proposed changes to society lottery codes of practice

by Melanie Ellis, Senior Associate

by Melanie Ellis, Senior Associate

The Gambling Commission wants lottery operators to be more open with customers as to what proportion of proceeds (ticket sales) go to good causes and which causes benefit. To this end, it has launched a consultation exercise on proposed changes to the Licence Conditions and Codes of Practice which apply to lottery operators.

At least 20% of lottery proceeds must go to good causes, but the Commission has made the point that this should be treated as a minimum rather than a target. As with other areas of gambling, the Commission wants to see standards being raised.

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Gambling Commission to hold second “raising standards” conference

The Gambling Commission has announced its second annual ‘Raising Standards Conference’ will take place on Tuesday 21 November 2017. Last year the news that the Commission would be revising its enforcement priorities was announced at this conference. This year, we anticipate that the focus on consumers will continue, with discussion of the fairness of T&Cs and complaints processes. The Commission has announced that key themes will include the ‘commercial logic of putting the consumer first’ and how raising standards across the industry starts with business leaders.

Last year’s conference was oversubscribed so we would advise reserving a place early and we look forward to seeing you there! You can book a place by contacting

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Harris Hagan attending iGaming Super Show

Harris Hagan will be attending the iGaming Super Show in Amsterdam from 11th – 13th July 2017.

Bahar Alaeddini will be speaking on the panel Regulatory Update: Europe, discussing the regulatory landscape for the alternative lottery market in Europe. This panel is part of the Global Lottery Messenger Forum and is at 9:30am on 11 July 2017.

Tom Edmonds will be speaking on the panel Liability of operators, suppliers and affiliates, discussing how the regulatory burden is increasing for operators, suppliers and affiliates. This panel is part of the IMGL series of seminars and is at 10:30am on 13 July 2017.

Please let us know if you are also attending and would like to meet up for coffee, beer, glass of wine or just a chat to talk through any legal questions you might have in relation to Great Britain, by contacting us at or

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