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]]>Considering the new statutory levy arrangements, this decision is intended to prevent the emergence of a dual funding structure and to avoid duplicating work already supported by the statutory levy.
As a result, Section 2.39 of the Gambling Commission’s Statement of principles for determining financial penalties has been amended to confirm that payments made in lieu of a financial penalty as part of a regulatory settlement will now be paid into the Consolidated Fund in the same way as financial penalties imposed under section 121 of the Gambling Act 2005.
Next steps
Please get in touch with us if you have any questions about regulatory settlements.
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]]>The post DCMS Launches Consultation on Unlicensed Gambling Advertising and Sponsorship Ban appeared first on Harris Hagan.
]]>The consultation covers unlicensed gambling sponsorship and advertising in Great Britain across all sectors, not only sport. The government’s stated aim is to prevent unlicensed gambling sponsorship moving into other areas, such as cultural events or music venues, although it notes that it is not currently aware of sponsorship or advertising by unlicensed gambling operators at non-sporting events or venues in Great Britain.
Background and Current Position
The consultation follows concerns about overseas gambling brands using sponsorship and advertising arrangements with high-profile sports clubs, particularly Premier League and Championship football clubs, primarily to reach global audiences due to the global nature of the sport. DCMS considers that this exposure is also affecting consumers in Great Britain.
Under the current position, sponsorship or advertising arrangements with unlicensed gambling operators may continue provided that those operators’ services are not accessible to consumers in Great Britain. However, DCMS notes that although geo-blocking is used to restrict access by unlicensed operators, it can be bypassed using VPNs, enabling consumers in Great Britain to access those websites.
Some of these arrangements have also involved white label structures, where a Gambling Commission licensed operator offers gambling services under a third-party brand. The consultation highlights TGP Europe, which held a Gambling Commission licence until May 2025 and acted as a white label provider for a number of overseas brands. After the Gambling Commission identified compliance failings, TGP Europe surrendered its licence and left the British market. This left its overseas partners unlicensed in Great Britain and placed partner football clubs with sponsorship agreements at risk of advertising unlawful gambling.
The consultation notes that DCMS does not currently anticipate extending the proposed ban to gambling operators in white label agreements. However, it will work with the Gambling Commission to consider whether further action is needed to ensure that white label arrangements are properly monitored and enforced where necessary.
Reason for the Proposed Ban
DCMS’ rationale for the proposal is based on three main objectives:
What the Ban Would Cover
DCMS proposes to implement the ban through secondary legislation utilising section 328 of the Gambling Act 2005, which gives the Secretary of State power to make regulations controlling gambling advertising, subject to Parliamentary approval.
The proposed ban would make it a criminal offence to participate in or facilitate the advertising of gambling (including the advertising of gambling by sponsorship) by unlicensed gambling operators across all sectors of the economy and at all levels.
The ban across all sectors, venues and events in Great Britain would cover physical advertising and sponsorship assets, including:
The ban would also extend to any team, club, or individual when competing or performing in Great Britain, regardless of the origin or usual location of those events or individuals.
Online Advertising
The proposed ban would focus on physical advertising and sponsorship, and online gambling advertising is not considered as part of the consultation, noting that primary legislation would be required to extend the ban to online gambling advertising. DCMS may consider this later if there is sufficient evidence to do so.
Proposed Timing
The consultation sets out two possible implementation options:
DCMS’ preferred option is a fixed start date in August 2027, ahead of the 2027/28 football season.
Potential Impact
DCMS recognises that the proposed ban may have a negative financial impact on clubs, sports, leagues, events and venues that currently have sponsorship or advertising arrangements with unlicensed gambling operators.
The consultation states that approximately 40% of Premier League clubs had sponsorship or advertising deals with unlicensed gambling operators for the 2025/26 season. The impact is likely to greater for lower-revenue clubs and sports that rely more heavily on sponsorship income.
Data provided to DCMS through the consultation will allow the government to estimate the potential financial impact when it considers how the ban should be implemented.
Consultation Response
The consultation includes separate questions for individuals and organisations.
The consultation runs for 8 weeks and closes at 11:59pm on 9 September 2026.
Responses can be submitted through DCMS’ online response form. Where the form cannot be accessed, responses may be sent by email to [email protected].
Please get in touch with us if you have any questions about the consultation on the proposed ban of sponsorship by unlicensed operators.
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]]>The post Gambling Commission to implement Financial Risk Assessments in staged approach appeared first on Harris Hagan.
]]>Staged Introduction Following Consultation and Pilot
Following extensive consultation, stakeholder engagement and piloting, the Gambling Commission has decided to introduce Financial Risk Assessments using a staged approach. The introduction of Financial Risk Assessments is one of the more controversial and debated outcomes of the 2023 White Paper. You can read more about the Financial Risk Assessment Pilot in our stage 1, stage 2 and stage 3 blogs.
The Gambling Commission has said that “Financial Risk Assessments will provide operators with a new, more effective and proportionate way of identifying customers in significant financial difficulty, while reducing reliance on the document checks that some operators currently use to seek to identify financial risk and that are unpopular with many customers”. The Gambling Commission further notes that some such customers are not currently being identified or supported, despite being two to four times more likely to have a debt management plan and two to five times more likely to have had a default in the previous 12 months than the wider population. If unidentified, they may continue receiving marketing and promotional offers despite being financially vulnerable.
It is expected that the majority of customers will never require an assessment due to the high spending nature of the relevant thresholds being introduced. However, where an assessment is required, the process is expected to be frictionless, document-free and carried out by Credit Reference Agencies with no impact on the customer’s credit score.
Stage One Implementation
The first stage of implementation will involve assessments being carried out by the largest operators where customers have a high spend of multiple thousands of pounds over a 24-hour period.
For most customers, Stage One will apply at £5,000 net deposit in a rolling 24-hour period. This has been described as an unusually high spend pattern, exceeded by less than 0.5 percent of customers.
The Gambling Commission will continue working with gambling businesses, Credit Reference Agencies and other stakeholders to refine the assessments, develop guidance and support proportionate implementation.
For the small proportion of customers who may need support, the Gambling Commission will support operators in taking appropriate and proportionate action. This may include reducing marketing to vulnerable consumers, helping customers set deposit limits, or taking further action where needed.
The Gambling Commission has also confirmed that, during the early stages of implementation, it will not take enforcement action for a failure to act following a Financial Risk Assessment. However, operators of course remain subject to all other existing licence requirements.
The timetable for Stage One will be confirmed after engagement with industry and other stakeholders through implementation groups being established over the summer.
Financial Risk Assessment Thresholds
Stage 1 implementation
Interim stages of implementation
Final stage of implementation
Comments from the Gambling Commission and Government
Sarah Gardner, Acting Chief Executive of the Gambling Commission commented:
“We are confident that our approach, using high-quality data, will enable support for high-spending customers in financial difficulties, while reducing friction for customers who are not in financial difficulties by removing the need for unnecessary and unpopular document checks to understand financial risk.”
“We have listened to feedback throughout the pilot process which has led to us deciding to carefully proceed. We will work with key partners to make sure that they are implemented in the most effective way for consumers and operators.”
Gambling Minister Baroness Twycross also welcomed the decision to implement Financial Risk Assessments by commenting:
“Attention must now turn to successful implementation, so that financial risk assessments work for consumers, gambling operators and the wider ecosystem.”
“The right balance must be struck so that assessments protect those in financial difficulties from the risk of gambling-related harm but do not create unnecessary burdens for the industry or consumers.”
Summary
Please get in touch with us if you have any questions about the first stage of the Financial Risk Assessments implementation.
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]]>The post Gambling Commission seeking proposals from industry to reduce regulatory burdens appeared first on Harris Hagan.
]]>The Gambling Commission has made clear that any reduction in burden must still maintain strong consumer protections and uphold the licensing objectives under the Gambling Act 2005.
Purpose of the Initiative
The initiative forms part of the Gambling Commission’s 2026/27 Business Plan. It invites industry stakeholders to suggest how regulatory requirements, guidance and operational processes could be streamlined or improved.
The aim is to identify practical changes that make regulation more effective and proportionate, without weakening consumer safeguards.
Areas Proposals May Cover
Industry proposals may relate to:
The Gambling Commission also reiterates that it remains committed to ensuring compliance costs are proportionate to the risks faced by consumers and at the same time, that it continues to focus on the licensing objectives of the Gambling Act 2005, namely:
How and When to Submit Proposals
Stakeholders are asked to submit proposals using an online form before the end of September 2026.
Comment from the Commission
Tim Miller, Executive Director for Research and Policy at the Gambling Commission commented:
“We want to hear from the industry about where regulation can be improved or streamlined without compromising the protections that consumers rightly expect.”
“This is an opportunity to identify tangible changes that support innovation while ensuring regulation remains effective, proportionate and focused on keeping gambling fair and safe.”
Please get in touch with us if you have any questions about the industry proposals.
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]]>The post DCMS confirms increase to Gambling Commission fees from 1 October 2026 appeared first on Harris Hagan.
]]>Since the Gambling Commission’s fees were last reviewed in 2021, the Gambling Commission has increased its investment in areas including disrupting the illegal gambling market, data capabilities, enhancing core operational functions and implementing reforms proposed in the White Paper. Alongside additional pressures, such as inflation, DCMS recognised a need for review of the current fee structure that has been in place since 2017.
What are the changes to Gambling Commission fees?
In its consultation response published on 30 June 2026 (“Consultation Response”), DCMS confirmed that, based on the 47 consultation responses received, it would be diverging from most of its original proposals set out in the Consultation. The government will effect the following changes to Gambling Commission fees through secondary legislation:
For full details of the changes to annual fees by licence type, please see Annex One of the Consultation Response or for details of changes to application fees, please see Annex Two.
For reference, the Consultation originally proposed three different options with increases to licence fees of (a) 30%, (b) 20%, or (c) 20% plus 10% ringfenced for illegal markets, revenue protection and related activities.
Following the Consultation, the Gambling Commission’s view is the DCMS’s findings now provide certainty on the Gambling Commission’s future income for the coming years. It should be noted that the changes to fees are subject to the passage of secondary legislation, which is planned to take effect on 1 October 2026.
What can operators expect?
The Gambling Commission has confirmed that, over the coming weeks, it will be making contact with operators about further details on how the increase in Gambling Commission fees will affect them and will provide information about alignment to any new fee category. The Gambling Commission will use licensee’s submitted regulatory returns data for 2025 to 2026 to determine its new fee category.
Next steps
Please get in touch with us if you have any questions on the increase to Gambling Commission’s fees or would like to discuss regulatory returns reporting or fee category tracking to ensure you are in the correct fee category.
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]]>The post Important updates to the Money Laundering Regulations 2017 for casino licensees appeared first on Harris Hagan.
]]>What are the changes to the MLRs and what does this mean to casino licensees?
Following parliamentary debate, and approval, on 9 June 2026, the following changes to the MRLs came into effect on 30 June 2026.
High risk jurisdictions
Casino licensees are required, pursuant to Regulation 33 of the MLRs to apply enhanced customer due diligence (“ECDD”) where the relevant transactions or customer relationships involve a person established in any high-risk third country, defined as a country named on the list of High-Risk Jurisdictions on the Financial Action Taskforce’s (FATF) ‘Call for Action’ country list only. Prior to 30 June 2026, the definition of a high-risk third country also included referenced to FATF’s ‘Increased Monitoring’ list.
In its bulletin on the changes to the MLRs, the Gambling Commission noted that the refined definition of high-risk third country enables casinos to focus on money laundering and/or terrorist financing threats faced specifically by the UK. The Gambling Commission reminds casino licensees that they are continued to require to apply ECDD measures based on geographic risk in accordance with Regulation 33(6)(c) of the MLRs, including taking into account FATF lists and other FATF assessments.
Unusually complex and unusually large transactions
Regulation 33(1)(f) of the MLRs now requires casino licensees to apply ECDD measures and enhanced ongoing monitoring in any case where a transaction is “unusually complex or unusually large”. This replaces the previous wording where ECDD was required in cases where a transaction was complex or unusually large.
Currency thresholds
The MLRs have now been updated so that any reference to Euros is now to Sterling. This is particularly relevant to Casino licensees in relation to Regulation 27(5) of the MLRs, as the threshold for customer due diligence measures in relation to specific transactions (set out at Regulation 27(6) of the MLRs) is now £2000.
Clarification on business relationships
The Gambling Commission’s bulletin on the changes to the MLRs sets out that the Gambling Commission’s The prevention of money laundering and combating the financing of terrorism guidance (“Casino Guidance”) will soon be updated to provide further details on the establishment of business relationships.
What should casino licensees do?
The Gambling Commission expects casino licensees to update their MLRA as a result of the changes to MLRs, which in turn, will prompt a review of their policies, procedures and controls.
The Gambling Commission has also announced changes to the Casino Guidance in due course. We remind licensees that licence condition 12.1.1 requires licensees to update their MLRA, as necessary, in light of any changes of circumstances and ensure policies, procedures and controls are implemented effectively, taking into account any applicable learning or guidelines published by the Gambling Commission from time to time. In any case, licensees must update their MLRA at least annually.
Next steps
Please get in touch with us if you have any questions about updating your MLRA or policies, procedures and controls.
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]]>The post Jessica Wilson on Statutory Gambling Levy Panel for iGB L!ve 2026 appeared first on Harris Hagan.
]]>Following first funding allocations of the statutory gambling levy, the session will explore what is working, what remains unresolved, and whether the new levy system can balance independence, collaboration and long-term sustainability. Key questions that will be considered include:
Jessica Wilson will be speaking alongside:
Anna Davies, Compliance Director – Better Change
Dan Spencer, Principal Consultant – EPIC Global Solutions
Lee Willows, Founder & Executive Chair – Community Care Gaming
Session details are as follows:
Date: 1 July 2026
Time: 12:20-13:00
Location: Excel London, Royal Victoria Dock, 1 Western Gateway, London E16 1XL
Free registration is open and do let us know if you have any questions or would like to meet with Jessica Wilson.
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]]>The post AI-powered content marketing sweep to protect children appeared first on Harris Hagan.
]]>The update follows publication of an enforcement notice by CAP setting out its expectations that content marketing should not be of strong appeal to under 18s. The sweep will proactively search for online ads that break the rules.
CAP begins actively monitoring from 11 June “followed by targeted enforcement action where needed”.
Background
The Advertising Standards Authority (“ASA”) is the UK’s independent regulator of advertising across all media. It administers and enforces the UK advertising codes, investigates complaints regarding advertising, and may require advertisers to amend or withdraw advertisements that do not comply with the applicable rules.
The Gambling Commission’s update reminds operators that all advertising, including consumer-facing social media posts, must be socially responsible and must comply with the relevant advertising codes, including the CAP code and the Broadcast Committee of Advertising Practice (“BCAP”) code which are enforced by the ASA.
The rules are intended to ensure that gambling marketing communications are socially responsible, with particular regard to protecting children, young persons under 18 and other vulnerable persons from being harmed or exploited by advertising that features or promotes gambling.
The CAP enforcement notice
The enforcement notice focuses on content marketing and CAP’s expectation that no content marketing should be of strong appeal to those under 18 years old.
The Gambling Commission refers operators to the ASA’s guidance within the enforcement notice, together with the ASA’s content marketing remit statement and its latest post on keeping gambling advertising responsible and protecting young people.
AI-based compliance sweep
The AI-based Active Ad Monitoring System is made up of three components:
The sweep will also involve partnerships with social media platforms.
The CAP enforcement notice states:
“If we identify ads that break the rules, we will require you to amend or remove the ad immediately and, if you fail to comply, we will impose sanctions, which may include referral to the platform hosting the ad and/or the Gambling Commission.”
The Gambling Commission’s role
The Gambling Commission emphasises that it works closely with the ASA and where a gambling firm is found to be in serious or repeated breach of the rules, the Commission can take significant action, including issuing fines.
Please get in touch with us if you have any questions about your compliance with CAP and BCAP codes and the AI-powered content marketing sweep.
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]]>The post IAGA Gaming Summit 2026 – join us for the responsible gambling panel moderated by David Whyte appeared first on Harris Hagan.
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The 43rd annual International Association of Gaming Advisors (IAGA) Summit will be held at the Ritz-Carlton in Sarasota, Florida from 2 – 4 June 2026.
As part of the 2026 Summit Agenda, Partner, David Whyte, who also sits on IAGA’S EMEA Engagement & Steering Committee will moderate the panel Innovations and Global Perspectives in Responsible Gambling on Thursday 4 June 2026. The session will explore:
The session’s panellists are:
Stephen Martino, Chief Compliance Officer
Sarah McCarthy, CEO, Responsible Gambling Council
Jamie McKelvey, Deputy Attorney General and Responsible Gaming Coordinator, New Jersey Division of Gaming Enforcement
Kane Purdy, Managing Director, Gamesys Operations Limited, and Chair, GamProtect, UK
Sarah Taylor, Executive Director, Hoosier Lottery
Date: Thursday 4 June 2026
Time: 1-2pm
Location: Ritz-Carlton, Sarasota
Register for the 2026 Gaming Summit. All Harris Hagan Partners will be in attendance – if you would like to arrange a meeting, please do not hesitate to get in touch.
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]]>The post Gambling Commission provides post-Pilot update on financial risk assessments appeared first on Harris Hagan.
]]>Background
The Gambling Commission has been reviewing the results of last year’s financial risk assessments Pilot, and assessing whether the model could meet the aims set out in the 2023 Gambling Act Review White Paper and operate as a practical way of identifying high-spending customers who are in current financial difficulty.
Currently, operators take different approaches to identifying financial difficulties and the information they use to do so. Some operators request documents where this may not be necessary, while others fail to identify and support customers showing signs of financial risk. Financial risk assessments were therefore identified as a more consistent and frictionless means of identifying financial difficulty.
The Gambling Commission says that some commentary on the proposal has been “ill-informed or inaccurate”, including suggestions that consumers are currently being driven to illegal operators as a result of financial risk assessments. The Gambling Commission notes that these checks are not yet in force and no customer has had action taken on the basis of one. Further, they confirm that the proposal does not involve introducing spending caps or limits, and instead, the proposed threshold would act as trigger to check on whether that customer is in financial difficulties.
Financial Risk Assessments and the Pilot
The Gambling Commission summarised financial risk assessments as:
The purpose of the Pilot was to test whether, and how, financial risk assessments could be introduced to support customers in financial difficulties without adding unnecessary friction to the customer journey. You can read more about the background of the Pilot in our stage 1 and stage 2 blogs.
Current Position and Findings
The Gambling Commission states that the Pilot produced encouraging results in terms of speed and frictionless assessments, and it has been investigating into the practical issues that were raised by businesses during the Pilot.
The Gambling Commission is collating its findings to inform decisions on whether and how to introduce financial risk assessments, and set out the following outcomes and commentary:
The findings from the Pilot will be presented to the Gambling Commission Board for consideration of next steps, although it is stressed that no final decision has yet been taken.
“Despite the success of the pilot in informing those considerations, no one should pre-judge what comes next”
If the proposal is taken forward, it will work with operators and credit reference agencies on a sensible implementation plan, while being mindful of the risk of over-implementation or unnecessarily rapid implementation creating friction for consumers. Guidance will also be developed to help operators take a proportionate approach when offering support to consumers where financial risk is present and high customer spending continues.
The Gambling Commission further emphasises the importance of ongoing evaluation. NatCen has acted as the evaluation partner for the Pilot, and its reports are expected to be published alongside the Commission’s next steps.
Next steps
Please get in touch with us if you have any questions about the financial risk assessments post-Pilot update.
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