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Harris Hagan

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08Oct

Reminder: Changes to specified management offices come into force on 29 November 2024

8th October 2024 Chris Biggs Harris Hagan, Uncategorised 111

Licensees are reminded that on 29 November 2024, the Gambling Commission will update licence condition (“LC”) 1.2.1 of the Licence Conditions and Codes of Practice (“LCCP”) to clarify and extend the roles captured as ‘specified management offices’ (“SMOs”) under this requirement. Licensees impacted by this change should take action now to ensure relevant individuals are granted personal management licences (“PMLs”) before the new requirements come into effect.

Background

Earlier this year, the Gambling Commission published its response to the Summer 2023 consultation (“Consultation Response”) in which it confirmed that it would proceed with changes to the LCCP to clarify and extend the roles captured as SMOs, which from 29 November 2024 will include:

  1. Chief Executive Officers, Managing Directors or 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.

For further background and discussion please see our previous blogs: White Paper Series: Transforming corporate culture by “driving personal accountability and responsibility” for lookers-on seeing most of the game? and Gambling Commission publishes Summer 2023 Consultation Response and Betting & Gaming Council announces New Industry Voluntary Code.

New Requirement

From 29 November 2024, LC 1.2.1 (2) will read:

1.2.1 (2). The specified management offices are those offices (whether or not held by a director in the case of a licensee which is a company, a partner in the case of a licensee which is a partnership or an officer of the association in the case of a licensee which is an unincorporated association) the occupier of which is by virtue of the terms of their appointment responsible for:

a)  the overall management and direction of the licensee’s business or affairs (this is likely to be the Chief Executive Officer, Managing Director or equivalent).

b)  chairing the Board (where the licensee has such a body) where that appointment is held for a fixed or indeterminate term of office, unless:

        1.  the position is held only on a transient and short-term basis for individual meetings; and
        2.  the licensee retains evidence in support of point 1.

  ….

i)   the licensee’s anti-money laundering and counter-terrorist financing function as head of that function his is likely to include the following:

a)   for holders of casino licences, the person responsible for compliance with the relevant regulations (and appointed in accordance with those regulations); and the person responsible for submission of reports of known or suspected money laundering or terrorist financing activity under the relevant legislation (and appointed in accordance with the relevant regulations)

b)   for holders of licences other than casino licences, where an individual has been appointed to submit reports of known or suspected money laundering or terrorist financing activity under the relevant legislation, that individual.

As regular readers will be aware, the Gambling Commission consulted on the proposal that the Board Chair be required to hold a PML “to ensure that those responsible for scrutiny, strategy and leadership at the most senior level within the organisation”. This means that, where licensees sit within corporate groups, the obligation to hold a PML could be extended to the Board Chair of the top parent company, and CEOs or Directors of parent companies, due to the level of influence those individuals are able to exercise over the licensee. It is therefore important that licensees with extended group structures: (1) consider which individuals within their wider group may be impacted by the new requirement so any necessary PML applications can be made as soon as possible; and (2) if there is uncertainty, proactively contact the Gambling Commission for clarification in advance of the requirements coming into effect.

Next Steps

The changes come into force on 29 November 2024, meaning PML applications for these positions must have been granted before this date. On the basis that it can take eight weeks for the Gambling Commission to process a PML application (assuming there are no issues with the application), PML applications need to be submitted as soon as possible. If affected individuals do not hold a PML before 29 November 2024, the licensee will be in breach of LC 1.2.1 (2).

Please get in touch with us if you have any questions about PMLs, if you would like assistance with PML applications, or if you are interested in our PML training services.

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02Oct

Global Gaming Expo 2024: Bahar Alaeddini to moderate a stellar panel of regulators

2nd October 2024 Harris Hagan Event, Harris Hagan 117

From 7-10 October 2024, the Global Gaming Expo (G2E) will make its grand return to The Venetian Expo.

In partnership with the International Association of Gaming Advisors (“IAGA”), it will host the panel Where Sports Betting’s Growth Sits on the Regulatory Agenda, which will be moderated by IAGA General Counsel and Harris Hagan Partner, Bahar Alaeddini.

The panel will examine the rapidly expanding US-based betting landscape after the pivotal overturn of the Professional and Amateur Sports Protection Act 1992 by the US Supreme Court, and feature insights from the following stellar panel of regulators:

  • Andrew Rhodes, Chief Executive, British Gambling Commission
  • Dennis Mullen, General Counsel, Indiana Gaming Commission
  • Kirk Hendrick, Chairman, Nevada Gaming Control Board
  • Marcus Fruchter, Administrator (Executive Director), Illinois Gaming Board

Please see the below details for your calendar:

Date: Monday 7 October 2024

Time: 09:00 – 09:50 PST

Location: Bellini 2101, The Venetian Expo

Over the course of the conference, IAGA will also be hosting a wide range of sessions focused on other key issues facing global gaming.

Bahar will be attending G2E with John Hagan. Please get in touch if you would like to arrange a meeting.

Register for your tickets on G2E’s website – we look forward to seeing you there!

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30Sep

Harris Hagan promotes Jessica Wilson to Senior Associate

30th September 2024 Harris Hagan Event, Harris Hagan, Uncategorised 118

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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09Sep

Harris Hagan speaks at the Backing The Punt conference

9th September 2024 Harris Hagan Event, Harris Hagan, Uncategorised 122

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 120

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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30Jul

Gambling Survey of Great Britain: Publication of first annual report

30th July 2024 Chris Biggs Harris Hagan, Responsible Gambling, White Paper 154

After more than 3 years of development and significant industry scrutiny, the Gambling Commission published the first Gambling Survey for Great Britain (“GSGB”) Annual Report on 25 July 2024 (“GSGB Annual Report”).

In a press release announcing the publication, the Gambling Commission stated that this first edition features responses from 9,804 people “but will increase to around 20,000 by next year.” The Gambling Commission goes on to state that the GSGB Annual Report provides greater insight into attitudes and gambling behaviours:

“presenting a fuller picture, illuminating participation rates, the type of gambling activities participated in, experiences and reasons for gambling, and the consequences that gambling can have on individuals and others close to them.”

We have previously explained the GSGB’s structure and purpose in our blog Gambling Survey of Great Britain: Gambling Commission’s new approach to collecting gambling participation and prevalence data.

We now turn to the key facts outlined in the GSGB Annual Report and consider the information published by the Gambling Commission to support the GSGB.

Key Facts

The GSGB Annual Report highlights key facts from the data collected from adults aged 18 years and older living in Great Britain, summarised below.

Participation

  • 48% of GSGB participants participated in any form of gambling in the past four weeks. This figure dropped to 27% when those who only participated in lottery draws were excluded.
  • GSGB participants were more likely to gamble online (37%) than in-person (29%), however this difference was largely accounted for by people who purchase lottery tickets online. Excluding those individuals, GSGB participants were more likely to gamble in-person (18%) than online (15%).
  • The most commonly reported gambling activities were the National Lottery (31%), purchasing tickets for other charity lotteries (16%) and buying scratchcards (13%). The average number of activities for those who had participated in gambling in the past 4 weeks was 2.2 activities during that period.

Experiences of and reasons for gambling

  • 41% of GSGB participants who had gambled in the past 12 months rated the last time they gambled with a positive score (6 or above on a scale of 0 to 10), 37% expressed they neither loved nor hated it (score of 5) and 21% gave a negative score. When participating in lottery draws was excluded the pattern displayed a slightly higher proportion of positive scores, with 50% positive, 31% neutral and 19% negative.
  • The most common reasons that GSGB participants gambled were for the chance of winning big money (86%), because gambling is fun (70%), to make money (58%) and because it was exciting (55%).

Figure 11 of the GSGB Annual Report displays the full list of reasons for gambling in the past 12 months surveyed, represented below where the percentages comprise individuals who reported ‘sometimes’, ‘often’ or ‘always’ as a reason for gambling for each statement.

Notably, GSGB participants were also surveyed on the types of leisure activities in which they participated in the past 4 weeks. The vast majority of participants indicated they spent time with friends and family (98%), watched TV (95%) and listened to music (91%), with many also reported shopping (80%), eating out at restaurants (73%), participating in sports or exercise (64%), doing DIY or gardening (61%) or going to pubs, bars or clubs (50%).

Consequences from gambling

  • GSGB participants who had bet on non-sports events in person were over 9 times more likely than average to have a score of 8 or higher on the Problem Gambling Severity Index (“PGSI”), which represents problem gambling by which a person will have “experienced adverse consequences from their gambling and may have lost control of their behaviour.”
  • GSGB participants who had gambled on online slots were over 6 times more likely than average to have a PGSI score of 8 or higher.
  • 41.4% of GSGB participants with a PGSI score of 8 or higher reported experiencing at least one of the severe adverse consequences asked about.

The severe adverse consequences surveyed required ‘yes’ or ‘no’ responses and consisted of: (1) losing something of significant financial value because of gambling; (2) relationship with spouse or partner or family member breaking down because of gambling; (3) experiencing violence or abuse because of gambling; and (4) committing a crime to fund gambling or pay gambling debts. Overall, 2.8% of GSGB participants who had gambled in the past 12 months reported experiencing at least one severe consequence.

The Gambling Commission also highlights that the GSGB is the first time that it has collected data on the consequences of someone else gambling. 47.9% of GSGB participants reported that someone close to them gambled. The most reported severe consequence of someone else gambling was the breakdown of a relationship with a spouse, partner or family member (3.5%).

Gambling Commission Guidance

To accompany the GSGB Annual Report, the Gambling Commission released Guidance on using statistics from the Gambling Survey for Great Britain (“GSGB Guidance”). The purpose of the GSGB Guidance is to ensure the GSGB data is reported correctly, with the Gambling Commission reiterating that these official statistics are new and are collected using a different methodology than previous official statistics.

The GSGB Guidance therefore lists the purposes for which the GSGB can and can’t be used, as well as where it can be used with some caution, in relation to the data on: (1) gambling participation; and (2) the consequences of gambling within the GSGB Annual Report. Of note, the GSGB can be used:

  • to look at patterns within the data amongst different demographic groups;
  • to assess future trends and changes in gambling participation and consequences of gambling, measuring changes against the 2024 baseline; and
  • to describe the range of consequences that someone may experience as a result of their own gambling and as a result of someone else’s gambling.

The GSGB can be used with some caution “until further work is completed”:

  • to provide estimates of gambling participation amongst adults in Great Britain;
  • to provide estimates of PGSI scores amongst adults in Great Britain; and
  • to provide estimates of the prevalence of consequences of gambling amongst adults in Great Britain.

The GSGB should not be used:

  • to provide direct comparisons with results from prior gambling or health surveys;
  • as a measure of addiction to gambling; and
  • to calculate an overall rate of gambling-related harm in Great Britain.

The GSGB Guidance also addresses the misuse of GSGB statistics. The Gambling Commission encourages the use of the statistics to support the understanding of important issues relating to gambling, but expects that “anyone using official statistics should present the data accurately and in accordance with the guidelines presented .”

Reiterating the message issued by Andrew Rhodes, Chief Executive Officer of the Gambling Commission, in his open letter to the industry in August 2023, if an individual or organisation is found to be using the GSGB inaccurately, the Gambling Commission “may contact them and request that they correct the statistics.” In “severe cases or continued misuse of official statistics”, the Gambling Commission may refer the individual or organisation to the Office of Statistics Regulation (“OSR”).

Whilst the Gambling Commission’s expectations for the use of the GSGB statistics have been made clear, it has not defined what it considers a “severe” case of misuse. However, the Gambling Commission’s Executive Director, Tim Miller, stated during the VIXIO Regulatory Intelligence webinar on 23 July 2024 that the Gambling Commission will challenge any misuse “in an appropriate way” such as by referral to the OSR, which has included “some examples in recent months where has taken those sorts of approaches.” We therefore encourage the industry to ensure its adherence with the GSGB Guidance.

Strengths and Limitations

The Gambling Commission has acknowledged that measuring adverse consequences from gambling in surveys is a challenging task, and cites Professor Patrick Sturgis’ statement in his Assessment of the Gambling Survey for Great Britain (GSGB):

“Given the widespread negative social norms around gambling, particularly harmful gambling, obtaining representative samples and accurate response data is at the more difficult end of what survey researchers seek to measure in general populations.”

Furthermore, the Gambling Commission states in its press release that Professor Sturgis warned that estimates of problem gambling rates should be used with caution due to the risk that the new methodology “substantially overstates the true level of gambling and gambling harm in the population.” The Gambling Commission updated its Gambling Survey for Great Britain – technical report to include a list of the GSGB’s strengths and limitations and caveats for the interpretation of PGSI score estimates produced in the GSGB.

Having set out these strengths and limitations, its expectations for the correct use of the GSGB statistics and the consequences for misuse, the Gambling Commission has seemingly attempted to temper the industry’s concerns about the accuracy and reliability of the new official statistics. During the VIXIO webinar, Miller stated that the Gambling Commission has listened to “recognised experts in data and statistics in developing the GSGB methodology”, as well as the GSGB Guidance. Acknowledging that all methodologies have limitations, Miller stated that a key difference is that the Gambling Commission is “very open and transparent about what the GSGB’s current limitations are”.

Miller defended criticism of the GSGB’s methodology and noted that the Health Survey for England is not without significant issues, having presented an “inflexibility” to update questions for relevance and an inconsistent method for the Gambling Commission to collect data on gambling activity. Miller confirmed the Gambling Commission continues to invest “a significant amount” into the GSGB methodology and is “confident that as to develop , this will become the new gold standard”.

Next Steps

The Gambling Commission explains that in a typical year, there will be four wave-specific publications from the GSGB, plus an annual report. In his blog accompanying the GSGB Annual Report, Ben Haden, Director of Research and Statistics at the Gambling Commission, explains that the GSGB removes its over-reliance on the PGSI as a “proxy for harms” and, even at a headline level, “a more general analysis of wider consequences and behavioural symptoms will give a far more nuanced picture than ever before.” Haden also states that two “in-depth reports” will be released before Christmas as the Gambling Commission commences its deeper analysis of the GSGB statistics.

Where the Gambling Commission acknowledges that the GSGB may overstate the true level of gambling and gambling harm in Great Britain, the release of the GSGB Annual Report will not calm industry concerns about the accuracy of these official statistics. Indeed, we share this concern where the proposals outlined in the White Paper may be evaluated, and potentially derailed, by these statistics. The Gambling Commission promised a “gold standard population survey for the whole of Great Britain”, in its effort to improve the quality, robustness and timeliness of official statistics on gambling behaviour in Great Britain: this is no doubt a challenging task. Therefore, noting Miller’s confidence in the GSGB as the Gambling Commission continues to develop the methodology, we will continue to follow the GSGB closely with the hope that the Gambling Commission moves closer to its aim.

Please get in contact with us if you have any questions about the GSGB Annual Report, the GSGB Guidance or how these statistics may impact your business.

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30Jul

Baroness Twycross announced as new Gambling Minister

30th July 2024 Chris Biggs Harris Hagan, Uncategorised 107

On 26 July 2024, the Government announced that Baroness Fiona Twycross was appointed Minister for Gambling, in addition to her roles as Baroness in Waiting (Government Whip) and Parliamentary Under-Secretary of State at the Department for Culture, Media and Sport (“DCMS”).

Baroness Twycross has been a member of the House of Lords since November 2022 and previously held the roles of Opposition Whip and Shadow Spokesperson (Education) from February 2023 until the election. Prior to this appointment, Baroness Twycross had not contributed to gambling-related parliamentary debates, nor voted on any gambling-related legislation in the House of Lords.

However, in yesterday’s parliamentary debate on the Horseracing and Bloodstock Industries, Baroness Twycross made her first comments on the new Labour Government’s position regarding the horseracing betting levy, stating:

“… the previous Government undertook a review that concluded only in April. I am committed to working with noble Lords across the House to make sure that we get the right arrangements for the industry and the levy is administered efficiently to best support racing. It is too soon, however, for me to commit to the shape of future policy.”

Baroness Twycross also briefly addressed the topic of gambling reform and gambling-related harm:

“As stated in the Government’s manifesto, we are absolutely committed to strengthening protections for those at risk. The Gambling Commission’s new survey which came out last week really helps to show the wider picture of gambling behaviour across Great Britain, and we will consider its findings very carefully.”

The news of Baroness Twycross’ appointment followed a fortnight of industry speculation that Stephanie Peacock MP, who has also been appointed as a Parliamentary Under Secretary of State in DCMS, would also be appointed the gambling ministerial portfolio. Peacock was tipped for the role, having previously been the Shadow Minister for Media, Gambling and Sport and having recently contributed to parliamentary debates on the topic of gambling, including on the Football Index collapse and gambling advertising in sport, and having made a speech at the AGM of the Betting and Gaming Council in February.

Baroness Twycross’ comments in yesterday’s parliamentary debate come ahead of the House of Lords recess at the close of business today. The House of Lords will return on 2 September 2024.

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26Jul

Account withdrawals: The mask operators cannot hide behind

26th July 2024 Jessica Wilson Harris Hagan, Responsible Gambling, Uncategorised 131

On 18 July 2024, the Gambling Commission published a blog by Chief Executive, Andrew Rhodes, on its expectations on account withdrawals, which comes a year after it published its concerns regarding delays customers were experiencing when attempting to withdraw funds.

Whilst the Gambling Commission has seen a reduction in customer complaints regarding withdrawals, they remain the number one subject of complaints the Gambling Commission receives across all operator sizes. As stated in its previous blog, the Gambling Commission reminds operators that it is not acceptable to introduce friction when a customer tries to withdraw from their account, rather than when they deposit into the account, nor should they place their commercial interests over those of their consumers. The Gambling Commission’s blog details several issues it has encountered as part of its compliance work.

Issue 1: Explaining the reason for requesting additional information from the customer or the reason for not paying out

The Gambling Commission has seen operators requesting additional information from customers, as part of the withdrawal process without explaining to the customer the reason for requiring such information.

Under licence condition (“LC”) 17.1.1, operators must obtain and verify a customer’s identity before the customer is permitted to gamble. A customer request to withdraw funds must not result in a requirement for additional information to be supplied as a condition of withdrawal, if the operator could have reasonably requested that information earlier.

The Gambling Commission has reminded operators that it wants transparency for consumers on withdrawals, meaning operators “should make proper efforts to explain to customers what the checks and restrictions are” and that “customers should be informed of the reasons why their withdrawal has been delayed”.

The Gambling Commission has issued a warning that “where we find evidence that an operator has deliberately misled a customer in its communications with them, we will consider the need for regulatory action”.

However, the Gambling Commission does acknowledge that, where there is a knowledge or suspicion of money laundering offences being committed, operators must ensure customers are not tipped-off, which could result in committing an offence under the Proceeds of Crime Act 2002 (“POCA”).

Issue 2: Timing of requests for additional information

The Gambling Commission has seen cases where operators have asked a customer to provide source of funding information after a withdrawal request has been made, with the operator withholding the account balance until the source of funding requests have been satisfied.

Operators are expected to monitor customers’ accounts on an on-going and risk-sensitive basis. The lack of source of funding evidence, in this case, did not prevent the customer from being allowed to make deposits and gamble their funds.

The Gambling Commission has reminded operators that that if they do not have any regulatory concerns about a customer (such as suspicions of money laundering), then there is no valid reason to delay the payout of the withdrawal. Operators “should not…continue to accept deposits indefinitely and then seek to rely on their anti-money laundering procedure to frustrate a withdrawal request”.

Issue 3: Third-party payment methods

The Gambling Commission is aware of instances where an operator has suspected customers funding their accounts through third party payment methods, but only verifying that payment method after a withdrawal request has been made.

The use of third-party payment methods is classified as high risk in the Gambling Commission’s money laundering and terrorist financing risk assessment for the British gambling industry. It is therefore usual for operators to have terms and conditions in place to prevent customers using such payment methods. Where there is suspicion that an account may be funded by a third party, operators should ensure that any investigation is conducted promptly. The Gambling Commission considers it unfair to customers if operators accept deposits from third-party payment methods, but only makes enquiries when a withdrawal request is made.

Issue 4: Confiscation of customer deposits

The Gambling Commission has been made aware that operators sometimes seek to confiscate a customer’s deposit balance, either due to money laundering suspicions or because of a suspected breach of terms and conditions.

The Gambling Commission reminds operators of the offences and statutory requirements under POCA and the Terrorism Act 2000, and that confiscating or returning account funds where there is knowledge or suspicion of money laundering or terrorist financing could result in committing an offence, unless a defence has been sought.

The Gambling Commission further reminds operators of LC 7, which requires operators to ensure that the terms on which gambling is offered are not unfair. The Competitions and Markets Authority has published guidance on unfair terms, with one principle being that consumers should be allowed to withdraw their deposit balance at any time without restriction (except to comply with general regulatory obligations, including anti-money laundering and fraud prevention).

Other reminders

The Gambling Commission’s blog ends with some other useful reminders for operators:

  • Operators should not have terms that give them undue discretion as to when and how those terms are applied, as such terms could be unfair, as set out in the Gambling Commission’s guidance. For example, they should not have terms that say the operator “may” or “reserves the right” to void or withhold winnings in situations.
  • Operators must comply with consumer protection laws and treat customers in a fair, open and transparent way.
  • There may be reasons for an operator to seek further information from a customer for safer gambling purposes as part of a customer interaction, but operators should be transparent with their customers that the reason for requesting more information is for safer gambling purposes. However, the Gambling Commission confirms that it would not be “fair, transparent or necessary to delay or prevent withdrawals purely for customer interaction purposes”.

The Gambling Commission lastly states, “it is imperative that operators review their terms and practices on withdrawals on an ongoing basis, to ensure they are acting compliantly and are treating their customers fairly.”

The Gambling Commission’s blog makes it clear that a delay in processing a customer withdrawal could unmask other areas of non-compliance, including failing to conduct customer due diligence correctly, allowing a customer to gamble without sufficient identity or source of funding checks taking place or failing to verify third-party payment methods before being allowed to gamble

Attempting to correct these mistakes at the point a customer withdraws funds is a mask operators cannot hide behind, as the Gambling Commission has shown that it can see through these actions. Operators should review the Gambling Commission’s guidance in its blog and review their practices to ensure they do not make similar errors. The Gambling Commission’s confirmation that it is not afraid to take regulatory action is a clear warning to operators.

However, operators should not lose sight of their anti-money laundering responsibilities and obligations under POCA, the Terrorism Act 2000, the Licence Conditions and Codes of Practice, the Gambling Commission’s anti-money laundering guidance for casino businesses and for non-casino businesses, and the Money Laundering and Counter-Terrorist Financing (Information on the Payer) Regulations 2017.

If you have any questions or concerns regarding account withdrawals, your policies and processes, your terms and conditions, or your anti-money laundering and counter-terrorism financing responsibilities and obligations, please do reach out to your usual Harris Hagan contact, or get in touch with us here.

Please sign up to our blog to receive further news, insight and commentary.

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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 135

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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27Mar

Harris Hagan promotes David Whyte to Partner

27th March 2024 John Hagan Event, Harris Hagan, Uncategorised 150

Harris Hagan is delighted to announce that David Whyte will be promoted to Partner with effect from 1 April 2024.

David has been an enormous asset to the firm since joining in 2019, having previously worked in-house within the online and land-based sectors and for nine years at the Gambling Commission in both the enforcement and legal departments. His practical operational experience and unique insight into the gambling regulatory framework, aligned with his legal expertise and highly personable approach, has been invaluable to the firm and our clients, particularly on high-profile compliance and enforcement mandates, including some of the most significant cases in the recent history of the UK gambling industry.

David is recognised in the legal directories as “not only technical excellence to the firm but, importantly, an excellent understanding of the regulatory environment. His wider experience provides an invaluable contribution to strategic discussions.”

Bahar and I look forward to working in partnership with David as the firm continues to go from strength to strength in its 20th year and enters a post-White Paper era for our clients.

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