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Harris Hagan

Harris Hagan

30Sep

Harris Hagan promotes Jessica Wilson to Senior Associate

30th September 2024 Harris Hagan Event, Harris Hagan, Uncategorised 130

Harris Hagan is delighted to announce that Jessica Wilson will be promoted to Senior Associate with effect from 1 October 2024.

Jessica has been a tremendous asset to the firm since joining as a newly qualified solicitor in 2019, working on the specialist due diligence and licensing aspects of some of the largest M&A transactions in the gambling sector in recent years, as well as advising our clients generally on gambling law and regulatory matters.

We congratulate Jessica on her achievement and we are confident that she will contribute enormously to the continued success of the firm.

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11Sep

Julian Harris to speak at the International Association of Gaming Regulators and International Masters of Gaming Law conference in Rome

11th September 2024 Harris Hagan Event 126

Consultant & Founder, Julian Harris will be speaking on the panel at the International Association of Gaming Regulators (“IAGR”) and International Masters of Gaming Law conference in Rome which takes place this year from 21-24 October 2024.

The panel, How do the regulator, the regulated and the interested and affected parties work best together? will seek to provide a fresh perspective on where the opportunities to work better together really exist, especially in light of the different values and goals that the gambling sector stakeholder ecosystem is trying to achieve.

Julian will be joined by fellow panellists on Wednesday 23 October:

  • Atle Hamar, General Director, Norwegian Gambling and Foundation Authority, Norway
  • Annette Kimmitt AM, CEO, Victorian Gambling and Casino Control Commission, Australia
  • Kevin Mullally, CEO, General Commercial Gaming Regulatory Authority, United Arab Emirates
  • Ewout Keuleers, General Counsel, Kindred Group, Germany

For further details and to book your tickets, see IAGR’s website.

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09Sep

Harris Hagan speaks at the Backing The Punt conference

9th September 2024 Harris Hagan Event, Harris Hagan, Uncategorised 134

Harris Hagan is delighted to join the leading Australian gambling law firm Senet, virtually, for their two-day conference, Backing the Punt. The conference will focus on the issues, challenges and opportunities facing the betting and racing industry in Australia.  

The event will take place on 11-12 September 2024 at the RACV City Club & Conference Centre in Melbourne. Partner, Bahar Alaeddini, will be joining virtually on 11 September 2024 to speak on the panel, International showcase – what are the trends and developments in international wagering, racing and sports betting?.

The panel will be moderated by Julian Hoskins, Principal at Senet, and the other panellists will include:

  • Ben Haden, Director of Research and Statistics at the British Gambling Commission
  • Scott Scherer, Shareholder at Brownstein Hyatt Farber Schreck
  • Joseph Borg, Partner, WH Partners

For full details and tickets, see Senet’s website. 

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02Sep

Global Gaming Women – Championing Inclusivity Webinar

2nd September 2024 Harris Hagan Event, Harris Hagan 134

On Tuesday 3 September 2024, at 12.45pm-2.15pm BST. Global Gaming Women (“GGW”) will host a webinar titled “Championing Inclusivity”.

The webinar will be co-moderated by Harris Hagan Partner, Bahar Alaeddini, and Christina Thor-Rankin (Principal Consultant 1710 Gaming).  Together with the panellists, they will discuss the opportunities and challenges faced by women of colour in the industry.

The other panellists will include:

  • Monia Shafaq, Chief Executive Officer at Gordon Moody
  • Natasha Whittaker, Director of People Strategy, Operations and Governance at Games Global
  • Natasha Harris, Executive Director for People Services at the British Gambling Commission
  • Pallavi Deshmukh, Chief Executive Officer at NetGaming
  • Stephanie Wong, Head of Policy at the Betting and Gaming Council

To attend, please register here.

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24Jul

White Paper Series: UK Gambling Act Review: What Now? VIXIO Webinar

24th July 2024 Harris Hagan Harris Hagan, White Paper 146

On 23 July 2024, Bahar Alaeddini appeared as a panellist on a VIXIO Regulatory Intelligence webinar titled “UK Gambling Act Review: What Now?” together with Tim Miller from the Gambling Commission, Sarah Fox from the Department for Culture, Media and Sport and Dan Waugh from Regulus Partners, and moderated by Joe Ewens, Global Managing Editor from Vixio.  This was the third webinar on the White Paper organised by Vixio. The panellists had an insightful and lively discussion about the current status of the White Paper proposals following the General Election:

Two earlier webinars took place on 16 May 2023, titled “The End of the Beginning”, 15 September 2023, titled “Defining the Future”. Please click on the dates to watch the earlier webinars.

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07May

International Association of Gaming Advisors’ 41st Annual Gaming Summit hosted in Washington D.C.

7th May 2024 Harris Hagan Event 149

The International Association of Gaming Advisors (“IAGA”) is delighted to host the 41st annual International Gaming Summit at the Ritz-Carlton in Washington, D.C. from 28 to 30 May 2024.

As a Bronze sponsor, Harris Hagan proudly continues its long association with IAGA, which includes Julian Harris and John Hagan serving as President in 2013 and 2019/2020, respectively, and Bahar Alaeddini serving as General Counsel and member of the Conference Programme Committee. It is without hesitation, therefore, that this Summit is commended to readers not least for the excellent quality of the content and networking events.

Partners, John Hagan and David Whyte will be on the following panels:

Sports Betting 101: Best Practices and Lessons Learned from Around the World

Tuesday, 28 May 2024, 8:45 – 9:45 a.m.

Moderator: John Hagan

Panellists: Khalid Ali, Chief Executive Officer, International Betting Integrity Association; Santiago Asensi, Managing Partner, Asensi Abogados; Atle Hamar, Director General, The Norwegian Gambling and Foundation Authority; Carlos Schneider, Director of Judicial Bodies, FIFA (Fédération Internationale de Football Association)

Addressing and Responding to Gambling Prohibitionists

Thursday 30 May 2024, 10:45 – 11:45 a.m.

Moderator: Dan Waugh, Partner, Regulus Partners

Panellists: David Whyte; Paul Burns, President & CEO, Canadian Gaming Association; Michael Dugher, Chief Executive, United Kingdom Betting & Gaming Council; Alfredo Lazcano, Partner, Lazcano Samano; Steve Ketteley, Partner, Wiggin

This year’s President’s reception and dinner is being hosted at TPC Potomac at Avenel Farms on the 28 May 2024. The closing reception will be held at the Spy Museum on 30 May 2024, where delegates can enjoy impressive views of the Washington, D.C. skyline. 

Please feel free to contact us if you would like to know more about IAGA’s work, membership and/or the Summit.  We very much hope that you can join us there!

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01May

Gambling Commission publishes Summer 2023 Consultation Response and Betting & Gaming Council announces New Industry Voluntary Code

1st May 2024 Harris Hagan White Paper 160

On 1 May 2024, the Gambling Commission published the Response to its Summer 2023 Consultation on Proposed Changes to the LCCP and RTS (the “Summer 2023 Consultation Response”), confirming widespread changes to the rules that regulate licensed gambling operators in Great Britain, including in relation to financial vulnerability checks and financial risk assessments; remote games design; direct marketing; age verification and personal management licences.

Meanwhile, the Betting & Gaming Council (“BGC”) on the same day published a new Industry Voluntary Code on Customer Checks and Documentation Requests Based on Spend (the “Industry Voluntary SR Code”), which will operate as a voluntary interim code on all aspects of social responsibility (“SR”) measures where, notwithstanding any other regulatory requirement, customer spend is the trigger for action. The purpose is to provide a more consistent approach to SR compliance, specifically customer checks and document requests based on spend until the financial vulnerability checks and the risk assessments described in the Summer 2023 Consultation Response are brought into force. The simultaneous publication is not coincidental as the documents are inextricably linked, as we explain below.

In this blog, we outline the changes proposed in the Summer 2023 Consultation Response and discuss these in the context of the announcement of the Industry Voluntary SR Code.  

The Summer 2023 Consultation Response

The Summer 2023 Consultation Response is the second consultation response to be published relating to the reforms outlined in the White Paper (after the Department of Culture Media and Sport published the response to its consultation on stake limits on 23 February 2024 – for further information, please see our blog: White Paper Series: DCMS announces online slots stake limits) – and the first to be published by the Gambling Commission.

The long-awaited response outlines the Gambling Commission’s plans to introduce changes to the rules set out in the Licence Conditions and Codes of Practice (“LCCP”) and Remote Gambling and Software Technical Standards (“RTS”) over the course of the next ten months – with changes coming into force in four stages: August 2024, November 2024, January 2025 and February 2025, to ease implementation.

The key changes are outlined below.

  1. Financial vulnerability checks and financial risk assessments

Changes

The Gambling Commission will introduce light-touch financial vulnerability checks, alongside a pilot of enhanced frictionless financial risk assessments. In line with the Government’s aims in the White Paper, the latter will only be rolled out if the pilot proves the checks can be carried out in a frictionless manner.

The light touch financial vulnerability checks will apply to gambling customers with a net deposit of more than £150 a month. The checks will involve the assessment of publicly available data (i.e. whether the customer is subject to a bankruptcy order, a county court judgment, an individual voluntary arrangement, a high court judgment, administration order or decree, or debt relief order – or equivalent). Following feedback from the industry, the new financial vulnerability checks will not require licensees to consider an individual’s personal details, such as postcode or job title.

With regard to enhanced financial risk assessments, the Gambling Commission will (as was previously announced on the regulator’s blog) carry out a pilot to test how frictionless assessments will work in practice, working with credit reference agencies (including Equifax, Experian and TransUnion) and gambling businesses to examine potential consumer impact. Through data collection, the Commission will also explore the exact financial thresholds at which assessments should be conducted – before they are rolled out in a live environment. It will also consider what actions should be taken while an assessment is taking place; and the validity period of an assessment should a customer meet thresholds again.

It is intended that neither the light-touch financial vulnerability checks nor the enhanced financial risk assessments will affect consumer credit ratings.

Timing

To ease introduction of the light-touch financial vulnerability checks (for both customers and licensees), the new requirements will initially come into force at £500 a month from 30 August 2024 before reducing to £150 a month from 28 February 2025.

The pilot (in which only operators in the three highest bands of operating licence fee categories will be required to be involved, i.e., J1, K1 and L1; alongside volunteers in lower fee categories) will last for a minimum of six months and involve testing data sharing in three stages:

  1. in relation to customer accounts that are not currently active;
  2. in relation to historical data relating to active customers; and
  3. on the first occasion a customer meets a threshold within the pilot period.

It is expected that the pilot will take place between 30 August 2024 and 31 March 2025. However, the Gambling Commission can extend the pilot period to the end of April 2025, should this be necessary for practical reasons.  

Relationship with Industry Voluntary SR Code

The publication of the Industry Voluntary SR Code on the same day as the Summer 2023 Consultation Response is no coincidence. It has been developed jointly between BGC members and the Gambling Commission – with the aim of operating as a voluntary interim scheme that will bring consistency across the regulated sector until the frictionless financial risk checks proposed in the Summer 2023 Consultation Response have been developed, tested and implemented.

Specifically, the Industry Voluntary SR Code sets out what actions a BGC member must take when customers wish to make net deposits of:

  1. more than £5,000 in a rolling month – in which case the operator must undertake a risk assessment of the customer to understand their financial situation and assess whether the customer is displaying any indicators of harm. It is intended that this will involve one or more of: a safer gambling interaction; a review of the customer’s affordability based on occupation, industry, job title and salary or savings/assets; a review of open-source information; a review of previous information obtained from the customer; and financial insights from third parties. As a result of the risk assessment, appropriate action must be taken when high risk activity is identified, which may include escalating to “a process of enhanced consideration”, which is similar to an enhanced due diligence check – where comfort cannot be obtained.
  2. £25,000 in any rolling 12-month period – in which case the operator must promptly undertake “a process of enhanced consideration”.

The £5,000 threshold will be halved to £2,500 for 18- to 24-year-olds.  

When determining whether a customer has met the relevant threshold, their overall net position can be ‘considered’ over the previous 180 days, which effectively means that recycled winnings within that period may be taken into account.

If risk assessments do not take place (for example, because a customer has not responded to a request for an interaction), the customer should be prevented from exceeding the relevant monthly threshold on deposits. If the customer hits the deposit limit in three consecutive months without a risk assessment taking place, the operator must restrict the customer until the risk assessment has been completed.

The Industry Voluntary SR Code also sets out a non-exhaustive list of examples of actions which could be taken by operators between the threshold for financial vulnerability checks (as mandated in the LCCP) and before the need for “enhanced consideration” as required by the Industry Voluntary SR Code, which include one-way notices and messaging, interactive questionnaires, surveys, PGSI surveys, telephone and live chat interactions, requests to set a deposit limit, and sending an activity statement with acknowledgement required – noting that these actions should not require documentation to be provided by the customer and operators shall be free to select the  action that best fits with their current tool kit of interactions and at the threshold optimised  for the customer.

BGC members should also note that it is intended that the Industry Voluntary SR Code will be supplemented by a BGC code on anti-money laundering checks (the “Industry Voluntary AML Code”), to provide the same consistency across the sector in respect of AML measures.  The Gambling Commission and the BGC are actively working on the Industry Voluntary AML Code.

Insight

The stance taken by the Gambling Commission in relation to light-touch financial vulnerability checks and financial risk assessments is fortunately, a far cry from what the industry feared when the Summer 2023 Consultation was first published. The Gambling Commission should thus be credited for genuinely listening to all responses to the Summer 2023 Consultation and adopting a sensible pragmatic approach.

Regarding the light-touch financial vulnerability checks, the Gambling Commission has helpfully reduced the range of flags to be taken into consideration and clarified that it does not consider all flags should result in one type of action – giving the example that a county court judgment for a parking ticket should not be treated the same as a bankruptcy. It will be up to licensees to tailor actions to the nature and severity of all indicators of harm for a particular customer. Affected licensees should therefore take steps now to review their existing responsible gambling policies and procedures to determine how, when and why they should be updated to take into account both the light-touch financial vulnerability checks proposed in the Summer 2023 Consultation Response and, if they choose to adopt it, the Industry Voluntary SR Code.   

Regarding the pilot for enhanced financial risk assessments, this is an undoubtedly a wise step by the regulator. Without a pilot, there was a significant risk of unintended consequences of the new rules, which may have been irreversibly detrimental for the industry. It is further positive that, in introducing the pilot in the Summer 2023 Consultation Response, the Gambling Commission has reiterated that the financial risk assessments should be frictionless for “the vast majority of customers who undergo them”; apply to “only the highest spending remote gambling accounts”; and “would not be a cap on gambling”. If the Gambling Commission can stay true to these aims, this is good for the remote industry, which has long expressed concern that such checks would encourage gamblers to move to the unregulated black market.   One critical aspect of the journey ahead will be interpreting what is meant by “vast majority” in the context of the frictionless nature of enhanced financial risk checks – as we expect the Gambling Commission and the industry may have different views. 

We also welcome the Gambling Commission’s confirmation that the new enhanced financial risk check requirements, once determined, will not apply to betting on a track or at local high street betting shops – presumably following extensive lobbying by the industry.

Any operators that are not in the three highest bands of operating licence fee categories but are interested in participating in the pilot scheme can express their interest by emailing [email protected].

  1. Remote games design – reducing intensity and increasing consumer understanding

Changes

New rules will extend requirements that already apply to slots to other online products and will ban:

  1. features which speed up the time for a result to be shown or can give the illusion of control such as ‘turbo’ or ‘slam stops’ (but these changes will not apply to bonus features where no additional stake is wagered, or prohibit “crash games” or “scratch all” features);
  2. game cycles of less than 5 seconds on casino products excluding slots (note that this is double the 2.5 second requirement that currently applies to slots under the RTS);
  3. autoplay – but the ban on autoplay will not prohibit auto-dabbing in bingo or auto-posting of blinds in peer-to-peer poker (NB – three card poker against house would, on the other hand, be caught);
  4. audio or visual celebrations of returns less than or equal to stake – extending an existing requirement that currently only applies in relation to slots;
  5. operator-led functionality which facilitates playing multiple simultaneous products such as roulette and blackjack tables – this requirement will not apply to bingo, virtual betting and peer-to-peer poker.

Further changes include requiring operators to display to consumers in real time their net spend, and time spent gambling.

Timing

The new remote games design rules come into force on 17 January 2025.

Insight

The Gambling Commission has decided to proceed to introduce all the proposals in the Summer 2023 Consultation relating to game design, with only minor amendments to clarify when the new requirements do not apply to specific products. Please see our previous blog for commentary on the original proposals: White Paper Series: Gambling Commission’s remote game design proposals – simply following suit?

  1. Direct marketing

Changes

Online gambling businesses will need to provide customers with options to opt-in to the product type (casino, betting and bingo) they are interested in and the channels (phone, email and text) through which they wish to receive marketing.

Timing

The new direct marketing rules come into force on 17 January 2025. However, customers will only be required to re-confirm their marketing preferences (consistent with the new rules) the first time they log in after the implementation date. Until then, marketing can continue based on the customer’s prior marketing preferences.

Insight

Notably, the Gambling Commission has, following feedback, removed:

  1. lottery as a product type (following concerns raised about the lottery sector’s ability to rely on legitimate interests for wider fundraising activities); and
  2. post as a channel for marketing (on the basis that this goes further than existing requirements under the Privacy and Electronic Communications Regulations).

It is also positive that licensees will be permitted to rely on previously indicated marketing preferences until the next time a customer logs into their online account – however, we query from a practical perspective how quickly and effectively operators are going to be able to communicate changes in marketing preferences to third parties that undertake marketing on their behalf.

There are, however, still many aspects of the changes which are controversial – particularly in relation to the effective removal of a “soft opt in” for gambling marketing – meaning that the industry now stands alone as the only sector where positive opt-in to marketing is always required. For discussion on the Gambling Commission’s original proposals in relation to direct marketing, please see our blog: White Paper Series: Direct marketing and cross-selling in the crossfire.

  1. Age verification – tightening verification in premises

Changes

New rules will require all land-based gambling licensees, including smaller licensees, to carry out age verification test purchasing. The newly affected categories of licensees include those that hold Category A and B betting, bingo, family entertainment centre (“FEC”) and adult gaming centres (“AGC”).

The LCCP will also be updated to confirm that it is best practice for casino, AGC, bingo, FEC and betting operators to require staff to check the age of any customer who appears to be under 25 years of age (rather than under 21 years of age) – e.g. Think 25.

Timing

The new age verification requirements come into force on 30 August 2024.

Insight

This was one of the less controversial changes proposed in the Summer 2023 Consultation and so it is unsurprising that it will come into force as originally proposed and within a short period (i.e. with just a four month lead-in – however, for testing purchasing, this date is somewhat artificial as results only need to be submitted within 42 days of the end of each financial year, meaning the deadline for testing relevant premises is actually 31 March 2025).

We recommend that licensees impacted by the new testing requirements (that have not already been voluntarily submitting test results) consider how they will comply with this requirement when it comes into force, how much that will cost and whether they involve an independent third party. Many such licensees may be able to access testing services via their trade association. Staff training will also be essential before the “Think 25” requirement comes into force on 30 August 2024.

For prior discussion on the Gambling Commission’s age verification proposals, please see our blog: White Paper Series: Time to think – Gambling Commission consultation on land-based age verification measures.

  1. Personal management licenses (“PMLs”) – extension of roles

Changes

The Commission has extended the management roles expected to hold a PML to include:

  1. Chief Executive Officers, Managing Directors and equivalent positions;
  2. Chairs of boards – unless that person only holds the position on a transient and short-term basis for individual meetings; and
  3. those responsible for AML and CTF, including the Money Laundering Reporting Officer and Nominated Officer.

Timing

The extended requirements in relation to PMLs come into force on 29 November 2024.

Insight

Again, this change has been introduced as originally proposed, with only minor clarifications to make it clear that the requirement for the Chair to hold a PML only applies to those that hold fixed or indeterminate office – a necessary change that PML applications often take months to be determined by the Gambling Commission.

For prior discussion on the PML requirements and corporate culture, please see our blog: White Paper Series: Transforming corporate culture by “driving personal accountability and responsibility” for lookers-on seeing most of the game?.

Next steps

We obviously recommend that all licensees familiarise themselves with the Summer 2023 Consultation Response and consider how the new requirements that are relevant to their business will be incorporated into their existing policies, procedures and controls in time for the deadlines. In addition, licensees should consider whether they wish to adopt the Industry Voluntary SR Code as an interim solution pending the introduction of formal financial vulnerability checks and financial risk assessments (once the pilot has completed).

This is a headline summary of today’s publications. We will be considering in depth and publishing further detailed insight into the proposed changes in the Summer 2023 Consultation Response in due course. Please sign up to our blog to receive further news, insight and analysis.

Please get in touch with us if you would like Harris Hagan to review your internal policies and procedures, provide PML training on the new requirements, or otherwise need legal advice on any gambling compliance matters.

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16Feb

Chambers Global 2024 Legal Rankings

16th February 2024 Harris Hagan Harris Hagan, Uncategorised 164

Harris Hagan continues to have four lawyers individually ranked for Chambers & Partners’ Global Market Leaders Rankings (Gaming & Gambling).

We are proud to have the quality of our work in the gambling industry recognised by the prestigious legal directories and will always strive for the highest standards for our valued clients.

John Hagan (Band 1) has been praised as a “leading practitioner” for gaming and gambling matters and recognised for often assisting with “high-value international transactions”.

Bahar Alaeddini (Band 2) has been recognised for her “specific expertise” with global gaming and gambling matters, including her frequent work on regulatory and licensing matters.

Julian Harris has been recognised with the esteemed position of Senior Statesperson and commended for his “wealth of experience” regularly assisting clients with licence reviews and compliance investigations. Commentary has praised Julian as “very switched on.”

Last, but certainly not least, Hilary Stewart-Jones also continues to occupy the position of Senior Statesperson and has been recognised as a “noted figure” in the industry. Commentary has emphasised her status as “very well connected and very knowledgeable for the UK market.”

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02Feb

International Association of Gaming Advisors and Gaming Regulators European Forum Workshop: Manipulation of sports contests

2nd February 2024 Harris Hagan Event 171

The International Association of Gaming Advisors (“IAGA”) and Gaming Regulators European Forum (“GREF”) are delighted to be host a workshop on critical issues surrounding the manipulation of sports competitions at the London Marriott Hotel Canary Wharf at 4pm on Monday 5 February 2024. The workshop will present a unique opportunity to hear from international experts on sports betting integrity and gambling regulation across two sessions and an interlude.

The workshop will consist of the following sessions:

16:00 – International Olympic Committee lecture: the Prevention of the Manipulation of Competitions

The lecture will include:

  • An introduction to the Olympic Movement Unit on the Prevention of the Manipulation of Competitions (“OM Unit PMC”) by Friedrich Martens (Head of the OM Unit PMC);
  • A review of the betting-related provisions in the Council of Europe Convention on the Manipulation of Sport Competitions (“Macolin Convention”) by Nicolas Saydé (Head of the Macolin Secretariat, Council of Europe Sport Division); and
  • A review of the Olympic Movement Rules related to betting and the OM Unit’s work with betting entities by Evangelos Alexandrakis and Aiden Young (OM Unit PMC).

16:45 – Joint comments from GREF and IAGA

Following the lecture, there will be a welcome to the workshop and introductory comments from:

  • GREF Chairperson Isabelle Falque-Pierrotin (the Autorité nationale des jeux, French regulator); and
  • IAGA former President and Trustee John Hagan (Managing Partner, Harris Hagan).

17:00 – Panel discussion: Working together to protect international sporting events and gambling integrity

With numerous major sporting events occurring in Europe in 2024, the roundtable will discuss a number of critical priorities for event organisers, including sports betting integrity, match-fixing, gambling advertising and sponsorship, ethics and regulatory compliance.

Moderated by John Hagan, the panel will comprise:

  • Dieter Braekeveld (Integrity in Sports Training Officer at INTERPOL);
  • Atle Hamar (Director General of the Norwegian Gambling and Foundation Authority);
  • Friedrich Martens (Head of OM Unit PMC);
  • Tim Miller (Executive Director of the British Gambling Commission); and
  • Nicolas Saydé (Head of the Macolin Secretariat, Council of Europe Sport Division).

Harris Hagan is proud to continue its long association with IAGA, which includes Julian Harris and John Hagan serving as President in 2013 and 2019/2020, respectively, and Bahar Alaeddini serving as General Counsel and member of the Programme Committee. We therefore strongly recommend this workshop to readers not least for the excellent quality of the content and networking opportunities with the high-calibre speakers and panellists.

Please contact us if you would like to know more about IAGA’s work, membership and/or the workshop. We very much hope that you can join us there!

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31Jan

White Paper Series: What’s next?

31st January 2024 Harris Hagan White Paper 182

In our last blog, we looked back at the last nine months. In this blog, we look forward at what lies ahead in 2024.

Open consultations

In the words of the previous Gambling Minister, Paul Scully MP, and as previously blogged by us, “ the industry to stay engaged as policies are refined, finalised, and implemented.” We continue to urge the industry to heed that imperative during 2024 and beyond, including on the following forthcoming deadlines:

  • 21 February 2024 – GC Autumn Consultation (on proposed changes to the LCCP and RTS) closes.
  • 15 March 2024 – GC December Consultation (on proposed changes related to financial penalties and financial key event reporting) closes.

The consultation phase is critical, with both Government and the Gambling Commission remaining under immense pressure to listen. We remain happy to assist clients with their responses where that would be helpful, as we did in the last once in a generation opportunity in 2005!

Closed consultations and forthcoming responses

We await responses (including implementation timeframes) on the following consultations:

  • DCMS Land-Based Consultation (closed on 4 October 2023)
  • DCMS Stake Consultation (closed on 4 October 2023)
  • GC Summer Consultation (closed on 18 October 2023)
  • DCMS Levy Consultation (closed on 14 December 2023)

What else is on the horizon?

February to March 2024 – Likely publication of Gambling Commission’s new three-year corporate strategy

March 2024 – Gambling Commission conference on illegal gambling

1 April 2024 – LCCP GAMSTOP and suicide reporting requirements come into force

TBC: Although the following items are expected, the timing is currently unknown:

  • DCMS consultation on Gambling Commission fees
  • Expected introduction of the statutory gambling levy
  • Establishment of a gambling ombudsman
  • Official launch of the Gambling Commission’s Gambling Survey of Great Britain
  • Extension of Gambling Commission powers to tackle illegal gambling (“when Parliamentary time allows”) Government review of the horserace betting levy
  • Government consultation on bringing remote gambling into a single tax structure

Want to hear more?

Please sign up to our blog to receive insight and commentary on the implementation of the White Paper during 2024, as well as other relevant industry news. 

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    Hamilton House
    1 Temple Avenue
    London
    EC4Y 0HA

    +44 (0)20 3334 8225

    [email protected]

    Legal notice

    Harris Hagan is authorised and regulated by the Solicitors Regulation Authority (SRA number 00401231)

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    Quick links

    Home
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