Harris Hagan

19Oct

Harris Hagan retains Band 1 ranking in Chambers and Partners

19th October 2023 Harris Hagan 234

We are delighted to announce that Harris Hagan is ranked in Band 1 of Chambers and Partners UK 2024 for Gaming for the 20^th consecutive year.

“The team at Harris Hagan is comprised of experts in their field and is very accomplished at handling the complex landscape of gambling regulation in the UK.”

Partners John Hagan and Bahar Alaeddini continue to be recognised in Band 1. Consultants Julian Harris and Hilary Stewart Jones are ranked as Senior Statespeople. Senior Associates David Whyte and Gemma Boore, together with Associate Francesca Burnett-Hall, continue to be recognised as Associates to Watch. Together they constitute 7 of the 27 gaming lawyers recognised in the directory, befitting our status as a leading specialist gambling law firm. We were also invited by Chambers to write the introduction to the practice area.

We received many positive testimonials, including:

“The lawyers at Harris Hagan are top legal specialists in the remote gaming industry and have been able to assist with all our requests, with the ability to adapt to our business and commercial expectations.”

“John is the go-to person for reliable, practical and sensible advice. He has vast experience across the gambling sector and is able to draw on this to support our business.”

“Bahar is a master at solving complex issues and has an encyclopaedic knowledge of gaming laws and regulations.”

“David is very responsive and knows the industry, regulations and landscape well.”

“Gemma is very easy to deal with as well as very proficient in every aspect of her work.”

“Francesca is always available and very diligent.”

In view of the sensitive nature of much of our work, it is our long-held policy not to name clients in directories, but you know who you are, and we thank you for your continuing instructions and for helping us achieve these impressive rankings.

06Oct

Harris Hagan continues to be ranked Tier 1 in The Legal 500

6th October 2023 Harris Hagan 246

We are delighted to announce that Harris Hagan continues to be ranked in The Legal 500 2024 as Tier 1 for Gaming and Betting in the UK.

“There’s no one else to go to other than Harris Hagan for everything gaming. One stop shop for all your needs. They deliver trust, confidence and integrity.”

Managing partner John Hagan, alongside consultants Julian Harris and Hilary Stewart-Jones continue to be listed in The Legal 500’s Hall of Fame, and partner Bahar Alaeddini retains her listing as a Leading Individual.

David Whyte, senior associate, has been listed as a Rising Star and remains a key lawyer, alongside senior associate Gemma Boore, and associates Francesca Burnett-Hall and Jessica Wilson.

We received many positive testimonials, including:

“Market leader in gaming law.”

“The team is very knowledgeable about UK gambling laws and engaging with the regulator.”

“The individuals at Harris Hagan have a deep knowledge of not just the British gambling laws, but also of the way in which the regulator operates.”

“In-depth knowledge of gambling licensing in terms of regulations and how they are implemented.”

“Bahar Alaeddini and Jessica Wilson get full marks.”

“John Hagan, Julian Harris and Bahar Alaeddini are prominent leaders in the gaming law field.”

We wish to thank our clients and friends of the firm for their input and recognition of our work.

26Sep

Bahar Alaeddini named an Emerging Leader of Gaming 40 under 40

26th September 2023 Harris Hagan 224

We are very delighted to announce that Partner Bahar Alaeddini has been named an Emerging Leader of Gaming 40 under 40 by The Innovation Group, organisers of the Emerging Leaders of Gaming, and Global Gaming Business.

The programme recognises professionals under the age of 40 already making significant impacts in the global gambling industry, and the next generation of industry leaders.

This honour recognises Bahar’s continued exceptional impact on the gambling industry since joining Harris Hagan in 2012. Bahar advises many of the world’s largest online and land-based gambling companies, regulators, governments, financial institutions, and private equity firms on gambling law and regulation. Bahar is also at the forefront of thought leadership in the gambling sector, sharing her extensive experience and insight by authoring many articles on the topic, including acting as the editor of the Chambers Global Practice Guide on Gaming Law. Additionally, Bahar is General Counsel of the International Association of Gaming Advisors and top-ranked in Chambers UK and The Legal 500.

The group’s achievements will be celebrated at G2E in the Networking Lounge (Booth 5649) on 11 October 2023 from 4pm to 5pm. The reception is open to all registered G2E attendees, including past honourees and professionals across the Emerging Leaders of Gaming network.

22Sep

DCMS Committee inquiry on gambling regulation

22nd September 2023 Harris Hagan 288

In case you missed it earlier in the month, on 5 September 2023, the Rt Hon Stuart Andrew MP (Gambling Minster), Ben Dean (Director, Sport and Gambling at DCMS), Andrew Rhodes (Chief Executive, Gambling Commission), Sarah Gardner (Deputy Chief Executive, Gambling Commission) and Tim Miller (Executive Director for Research and Policy, Gambling Commission) appeared before the DCMS Committee examining the Government’s approach to the regulation of gambling. The Gambling Commission gave evidence in the first session at 10am, and the Gambling Minister and DCMS gave their evidence in the second session at 11.30am.

Watch the recording of the DCMS committee oral evidence sessions:

22Sep

Julian Harris wins VIXIO’s 2023 Compliance Lifetime Achievement Award

22nd September 2023 Harris Hagan 246

We are very delighted to announce that Consultant and Founder Julian Harris has been awarded the Global Regulatory Award for Compliance Lifetime Achievement by VIXIO Regulatory Intelligence.

This special award recognises Julian’s unprecedented work in trailblazing a “culture of compliance and regulatory standards within the industry” for more than 40 years. During that time, Julian has advised many of the world’s largest online and land-based gambling companies, regulators, governments, financial institutions, and private equity firms on gambling law and regulation. Julian has also been at the forefront of thought leadership in the gambling sector, sharing his extensive experience and insight on various gambling regulatory issues by authoring many articles on the topic, including acting as editor of global publications on gambling law, and in his speeches at conferences across the world. He also served as President of the International Association of Gaming Advisors, the first person to do so from outside North America, testament to the esteem in which he is held amongst gaming advisers worldwide.

Julian first came to specialise in gambling law in 1981 representing the Gaming Board for Great Britain (the then British regulator). He co-founded Harris Hagan with John Hagan in 2004, in anticipation of the Gambling Act 2005 and the expected growth of the gambling industry in Great Britain. It was a bold and inspired decision at a time when niche law firms were rare in the City of London.

Upon receiving this distinguished award, Julian commented:

“I am greatly honoured and humbled by this award. I have felt privileged to have enjoyed being a part of this exciting industry for some 40 years, working with industry, fellow advisers and regulators internationally.
To receive this award from such a distinguished panel of judges and from the most respected global regulatory awards is particularly gratifying.”

The 2023 Global Regulatory Awards will take place on 29 November 2023.

22Sep

White Paper Series: Defining the Future VIXIO Webinar

22nd September 2023 Harris Hagan 246

On 15 September 2023, Bahar Alaeddini appeared as a panellist on a VIXIO Regulatory Intelligence (formerly GamblingCompliance) webinar titled “UK White Paper: Defining the Future” together with Tim Miller from the Gambling Commission, Sarah Fox from the Department for Culture, Media and Sport and Dan Waugh from Regulus Partners. The panellists had an insightful and lively discussion about some of the proposals in the recent wave of consultations and next steps:

03Jul

White Paper Series: Low(er) stakes gambling in the high stakes White Paper

3rd July 2023 Harris Hagan 243

An objective of the review of the Gambling Act 2005 was to protect players from the risk of harm, and to address this, the Department for Digital, Culture, Media & Sport (“DCMS”) proposes in its white paper, High Stakes: Gambling Reform for the Digital Age, the implementation of a package of protective measures, including applying a stake limit to online slots.

Consideration was given to applying a stake limit to all online products, including all casino games and betting. However, evidence suggests that slots, which are defined in the Gambling Commission’s Remote Technical Standards as “casino games of a reel-based type (includes games that have non-traditional reels)” carry the greatest risk of harm. Slots have the highest average losses per active customer of any online gambling product, the highest number of players, the longest play sessions and the greatest potential for financial harm, as the nature of slots allows for frequent staking (the average spin speed for online slots is 7 seconds, although a game cycle can be as little as 2.5 seconds) with no statutory limit on the amount people can stake – at least not yet.

The Gambling Commission’s Advice to Government encouraged a stake limit for online slots and suggested several options, including:

a universal stake limit applied to all players on a precautionary basis;
tailored stake limits applied only to at-risk demographic groups or customers identified as being at risk of harm; or
a risk-based “smart stake” which allows a stake limit to be tailored to the player.

DCMS agrees that stake limits are needed, but while we know that stake limits will be coming, we do not know definitively where they will land, as DCMS will be consulting this summer on applying a stake limit to online slots which will be fixed somewhere between £2 and £15 for the general population, with a lower stake limit for 18-24 year olds which could be either £2, £4 or using a risk-based smart stake approach.

In the land-based sector, a reduced stake limit was applied to fixed odds betting terminals (“FOBTs”) in April 2019, lowering the maximum stake from £100 to £2 in an effort to reduce the risk of gambling related harm. This had a very significant effect on betting shops, which suffered a £763 million or 42% drop in machine sector gross gambling yield (“GGY”) between 2018/19 and 2021/22.

We think it is unlikely that the online slots stake limit will have parity with the £2 FOBT limit, and for good reason. Online operators benefit from the fact that their customers must hold accounts with them, giving them access to data which allows them to monitor their customers, track their play, and intervene where necessary. This is less easily achieved by land-based operators, whose customers can be unknown and where it can be difficult to track play as they move across machines. Additionally, the stake limit is just one of a number of protective measures that is proposed in relation to online gambling, meaning that there will be layers of protection for the customer.

That said, it is also unlikely that the stake limit will be set at £15. The nature of slots products is that they can be played very quickly and repetitively, with a new game round potentially every 2.5 seconds – even at a £15 maximum stake, this could quickly add up to significant losses.

Most likely, the limit will be set around the £5 mark. Indeed, this is the number that was leaked from an earlier version of the white paper in July 2022, and a cynic might say that reverse engineering is in play, and that by giving a range of £2 to £15, DCMS can say that they are being tough on industry by imposing a £5 limit at the lower end of the spectrum under consideration.

For the year 2021-22, online slots GGY was £3 billion. DCMS has calculated the financial impact of the proposed stake limit based on a fixed maximum of £8.50, which is the midway point between the proposed range of £2 to £15. This estimates a drop in online slots GGY of £135 million to £185 million, or 4-6%. If the stake limit is set at £5, the impact on the industry will be even greater.

DCMS’ consultation will take place this summer, and we urge you to get involved. Do get in touch if you would like any advice, or need assistance preparing a response.

26Jun

White Paper Series: DCMS speaks at IAGA 40th Annual Gaming Summit in Belfast

26th June 2023 Harris Hagan 247

On 21 June 2023, Ben Dean, Director of Sport and Gambling from the Department for Culture, Media and Sport (“DCMS”) participated in the International Association of Gaming Advisors (“IAGA”) 40^th annual International Gaming Summit in Belfast.

Dean delivered a keynote and joined the subsequent panel discussion on the Government’s plan for reform of gambling regulation following the review of the Gambling Act 2005, and its potential impact on the future of the regulated UK gambling industry. This was the first time that DCMS had spoken publicly since the publication on 27 April 2023 of its White Paper: High stakes: gambling reform for the digital age (the “White Paper”).

Keynote – White Paper on Gambling Reform in Britain – Overview and Next Steps

Dean recognised the importance of the gambling industry in Great Britain and that gambling is enjoyed by a large percentage of the population each month, with the majority of gamblers suffering no ill effects. He made clear however that gambling comes with risks and that problem gambling can have a devastating impact, noting it was important that Government put their best efforts into making gambling safer. Dean acknowledged the delay in publishing the White Paper, attributed to the numerous changes in Prime Ministers, and underlined that the many Secretaries of State he had supported during the Gambling Act Review had consistently pointed out that it is not the job of a Conservative Government to tell people how to spend their money.

A key challenge faced during the Gambling Review was finding the balance between freedom and protection. Dean said DCMS believes that the balance is probably right because campaigners complain Government did not go far enough and industry believe it went too far.

Dean highlighted DCMS’ strong desire to keep working with the industry, continuing to hear views on both sides, and recognised the importance of getting the detail right as the 62 measures come into force to protect those most vulnerable without interfering with the freedoms of the majority. He noted that the under-25 cohort was of particular importance and focus for DCMS, and said that the White Paper includes specific protections taking into consideration the continuing brain development of that group.

One encouraging remark by Dean, regarding the proposed frictionless financial risk checks, was that:

“We know how important the frictionless commitment is and have said the measures won’t come into force until they genuinely are frictionless.”

Though they will not of course be frictionless for those customers in respect of whom flags are raised.

Dean said DCMS will launch two of its consultations, including one relating to land-based modernisation measures, before the summer recess (July) and a further consultation immediately following that recess over the Summer. Government aims to implement the majority of key measures by Summer 2024, but Dean acknowledged this will require Government to “keep their feet to the fire” and those requiring primary legislation will likely take longer.

In conclusion, Dean praised submissions in the call for evidence for the White Paper and encouraged stakeholders to engage in the consultations and speak with DCMS directly so as to ensure the successful implementation of the commitments in the White Paper.

Panel – The Long-Awaited White Paper on Gambling Reform in Britain

Moderated by Dan Waugh from Regulus Partners, the following panel of experts then discussed next steps in Great Britain following publication of the White Paper:

Andrew Herd, Managing Director, Lancashire Court Capital Ltd
Antony Gevisser, Senior Vice President – Legal & Operational Affairs, Super Group
Ben Dean, Director of Sport and Gambling, DCMS
Helen Rhodes, Director of Major Projects, Gambling Commission
Wes Himes, Executive Director, Betting & Gaming Council

The panel discussion was a lively and engaging debate. The panel agreed that credit should be given when it is due: the White Paper was balanced, proportionate and evidence-based and had generally been well-received by the industry and its stakeholders as a whole. However, the focus now is on implementing the many commitments therein in both a timely and an effective manner.

Rhodes noted that 24 of the 62 measures in the White Paper were in the Gambling Commission’s court, with many not involving consultations and some measures requiring increased resources at the Gambling Commission. Rhodes was “very confident” with the Gambling Commission’s structured consultation programme, which will include pre-consultation briefings and a phased implementation to ease the effect on the industry, and emphasised the Gambling Commission would keep communication lines with the industry open and that it was “absolutely keen to collaborate”. She also confirmed that financial risk checks would be in the first batch of consultations this summer.

It was also interesting to find out that the long overdue response to the Gambling Commission’s consultation on customer interaction guidance (about which we have previously written) would be published before the further White Paper consultations were launched in Summer 2023.

Dean confirmed that the Secretary of State wanted to get the consultations within its remit out as soon as possible and that it would not wait to release the consultations in one batch, preferring instead to keep the ball rolling.

It was noted by the panel that frictionless financial risk checks involved competing interests which need to align prior to the introduction of that requirement – and that it would be important to test the accuracy of the final methods that would be used to determine financial risk. Herd described this as an “existential issue”, and Gevisser emphasised the “need for th industry to survive and thrive”.

Himes stated that one of the biggest challenges is that the technology relating to frictionless checks is still evolving, with the accuracy of such checks needing to be tested. Himes notes that if it can be done right, there will be a positive future.

Rhodes acknowledged that checks could not be frictionless for every customer but considered that, if implemented properly, the introduction of financial risk checks would represent a positive change for the industry as a whole and would affect only c.5% of customers. Rhodes also said that the Gambling Commission is 100% committed to working with the finance sector and the Information Commissioner’s Office to deliver the frictionless checks. It will be for the operator to use the results of those checks to support identified customers and reduce their risk profiles. Dean also recognised that creating and implementing a system for frictionless checks would not be easy, particularly given the importance of proportionality and the risk of driving people to the black market.

All panellists agreed that it would be paramount that the industry continues to engage, and encouraged those present to participate in the various consultations being run by DCMS and the Gambling Commission and also to contribute to any supplementary work undertaken by industry bodies, such as the Betting and Gaming Council’s work on industry codes.

We extend our thanks to DCMS, the Gambling Commission and other panellists for their valuable contributions.

13Jun

White Paper Series: DCMS speaking at IAGA 40th Annual Gaming Summit in Belfast

13th June 2023 Harris Hagan 244

We are very pleased to announce that Ben Dean, Director of Sport and Gambling, from the Department for Culture, Media and Sport (“DCMS”) will be participating in the International Association of Gaming Advisors (“IAGA”) 40^th annual International Gaming Summit at the Culloden Estate and Spa in Belfast, Northern Ireland from 20 to 22 June 2023.

This will be the first time DCMS has spoken publicly since the publication of the long-awaited gambling white paper (the “White Paper”) on 27 April 2023.

Ben will be discussing the White Paper and next steps in his keynote at 1.30pm on Wednesday 21 June 2023 and he will join industry experts in the following panel at 1.45pm:

The Long-Awaited White Paper on Gambling Reform in Britain

After nearly 30 months, six Gambling Ministers, three Prime Ministers, two Monarchs, 16,000 responses, several leaks, a World Cup and a global pandemic, this panel considers what the publication of the White Paper tells us about the future of the regulated market for betting and gaming in Britain.

Moderated by Dan Waugh from Regulus Partners, the panellists include:

Ben Dean, Director – Sport and Gambling, DCMS
Antony Gevisser, Senior Vice President – Legal & Operational Affairs, Super Group
Andrew Herd, Managing Director, Lancashire Court Capital Ltd
Wes Himes, Executive Director, Betting & Gaming Council
Helen Rhodes, Director of Major Projects, Gambling Commission

The keynote and panel are essential for anyone licensed in Great Britain or thinking about market entry, including through an investment or M&A activity.

Spaces are limited so please book your ticket to avoid disappointment!

As mentioned in our earlier blog in May, as a silver 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 Co-Chair of the Conference Programme Committee. Partners, John and Bahar, will moderate panels on What’s Happening in the Republic of Ireland and The Current State of Industry M&A. It is without hesitation that this Summit is commended to readers not least for the excellent quality of the content and networking events.

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!

18May

International Association of Gaming Advisors’ 40th Annual Gaming Summit hosted in Belfast

18th May 2023 Harris Hagan 272

The International Association of Gaming Advisors (“IAGA”) is delighted to host the 40^th annual International Gaming Summit at the Culloden Estate and Spa in Belfast, Northern Ireland from 20 to 22 June 2023. The Summit is understood to be the first such event held in Northern Ireland and has been warmly welcomed by Visit Belfast and Tourist Northern Ireland.

As a silver 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 Co-Chair 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 and Bahar will moderate the following panels:

What’s Happening in the Republic of Ireland

Moderator: John Hagan

Panellists: Sharon Byrne, Chairperson, Irish Bookmakers Association; Rob Corbet, Partner, Arthur Cox; Micaela Diver, Partner, A&L Goodbody; Mark O’Neill, CFO, BoyleSports.

The Current State of Industry M&A

Moderator: Bahar Alaeddini

Panellists: Leon Ferera, Partner, Jones Day; Paul Richardson, Partner, Partis Solutions; Sonia Vermeys, Shareholder, Brownstein Hyatt Farber Schreck; Daniel Vyravipillai, Managing Director, Morgan Stanley Investment Banking Division.

John will also host a fireside chat with Nigel Eccles, CEO of Co-Founder of Vault Labs. Amongst other accomplishments, Nigel also co-founded FanDuel in 2009 and Flick in 2018.

The first day of the Summit will conclude with the following panel on the White Paper:

The Long-Awaited White Paper on Gambling Reform in Britain

Moderator: Dan Waugh, Partner, Regulus Partners

Panellists: Antony Gevisser, Senior Vice President – Legal & Operational Affairs, Super Group; Andrew Herd, Managing Director, Lancashire Court Capital Ltd; Wes Himes, Executive Director, Betting & Gaming Council; Helen Rhodes, Director of Major Projects, British Gambling Commission.

Each day of the conference will be followed by high-quality social events featuring regional cuisine and the warm hospitality for which Ireland is so well known. This year’s President’s reception and dinner is being hosted at Hillsborough Castle, the British Royal Family’s residence, on the 22 June 2023. Optional social events have also been organised for 19 June 2023, including a golf tournament at Portstewart Golf Club, whiskey tasting at Bushmills Distillery and a tour of the Northern Ireland coast.

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!

Harris Hagan

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