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Our UKGC consultation response: Failing to protect the vulnerable should not be the White Paper’s legacy

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The dust has settled and the process is complete. The consultation on the proposed changes outlined in the UK Gambling White Paper is closed so now we just have to wait and see. Whilst we do so, we thought that in the spirit of transparency, we would share our own thoughts, more or less as they were communicated in our consultation response to the UK Gambling Commision.

Offering a real-time customer risk profiling tool, ClearStake’s focus was obviously on affordability checks. But then, much of the industry’s attention has been on this topic over the last few months. This is, to our mind, the single most important challenge facing the sector. Addressing it in the right way, a way that protects both punters and operators, will be the key to a sustainable, profitable future.

And with that goal uppermost in our mind, here is what we said:

1. Affordability checks must use real financial data

Certainly at the levels of spend proposed as meriting more thorough checks (£1,000 in a day or £2,000 over the space of three months), we don’t believe there is any real substitute for real financial data, by which we mean bank data. There is simply no other way of establishing whether a player can afford to lose this amount of money or not. Everything else – including data from credit reference agencies – is guesswork. We believe that the single greatest mistake that could be made during this process is not solving the problem of financial harm caused by gambling. That won’t be an issue if the government requires decisions to be made by operators in possession of a proper financial picture of their customers.

2. We can solve two problems at once

The consultation focused on affordability checks, but it would be almost perverse to ignore the wider reality at play here. Operators also have to perform anti money-laundering and source-of-funds (SOF) checks on their customers, and they do so by looking at bank statements. Given this is the case, it makes a lot of sense to us to effectively combine both these requirements within a single check.

3. At higher spend levels, it makes sense to keep customers connected

There has been a lot of talk about how frequently checks should take place, or to put that another way, whether it should be necessary to go back to a customer within six months or a year if they have already passed a check. To us, this rather misses the opportunity presented by Open Banking in particular. After the first check, assuming the player allows it, any checks in future can be entirely frictionless. The connection can remain in place and used when necessary (and only when necessary!) in order to make the ongoing compliance relationship as smooth as possible. We don’t expect ongoing connection to be mandated, but it should certainly be held up as best practice for all concerned.

4. Some of the proposed data points make little sense

When a solution that takes guesswork out of the equation is available, does it really make sense to suggest that postcodes and job titles are meaningful ways to determine an individual’s financial situation? We don’t think so. We believe that continuing to ‘lean in’ to data like this gives a misleading impression that it is good enough. It isn’t. Even as part of a broader decision-making process, it is very difficult to see where some of these data points fit in. You could say the same, of course, about missed loan repayments from three years ago.

5. The solution exists – why cobble together a new one?

Hovering behind the entire consultation process appears to be a not-quite-defined ‘solution’ to the affordability challenge. This is apparent in the various hints towards the use of CATO data (let’s just say it, even if the Commission aren’t willing to) and a hodge-podge of random data points in order to make affordability decisions, as part of a system that would have to be piloted in order to ensure a) it works and b) it doesn’t create data security issues.

Leaving aside the absurdity of asking us to judge the merits of an approach that hasn’t actually been defined, we would simply point out that in Open Banking, a solution to this challenge already exists. One that is already used by over 7 million people in the UK, by most UK operators to handle payments, and already used to handle affordability and SOF checks by forward-thinking operators. Why on earth are we re-inventing the wheel?

So there you have it. That’s what we told the consultation, albeit in language a little less colourful. I hope they listen.

Compliance Updates

KSA Issues Warning to 711 BV

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The Netherlands Gambling Authority (KSA) has issued a warning to 711 BV, an online gambling provider, for using an influencer to advertise online gambling. This violates the ban on using role models to advertise online gambling. The purpose of these rules is to protect vulnerable groups, such as young people and at-risk and problem gamblers, from gambling advertising.

Role model ban

Online gambling providers are prohibited from using role models, such as professional athletes, actors, models and influencers. The Royal Netherlands Gambling Authority (KSA) has informed 711 that all expressions in which the influencer promotes the gambling provider must be removed. This means, among other things, that the expressions may no longer be seen in the videos. 711 has confirmed that the collaboration has ended and has initiated the removal of the content in question.

The KSA emphasized that gambling providers must be careful about who they use for promotion.

In addition, the KSA addressed 711 about offering tournaments in which players were automatically entered, without having to register or agree to the bonus terms. This can lead to inappropriate gaming behaviour. 711 has confirmed that it has stopped this practice.

The post KSA Issues Warning to 711 BV appeared first on European Gaming Industry News.

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Compliance Updates

eGaming Integrity Celebrates Two Years of Independent Compliance and Audit Expertise

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eGaming Integrity Ltd marks its two-year anniversary, celebrating a period of growth, trust, and continued delivery of independent regulatory, compliance, and audit expertise to eGaming operators, suppliers, and Corporate Service Providers.

Founded by former regulators and senior compliance leaders, eGaming Integrity was established with a clear mission: to help protect licences and reputations through practical, regulator-ready assurance. Two years on, the firm continues to provide objective, expert support designed to strengthen governance and reduce regulatory risk.

A Trusted Partner for Assurance

In just 24 months, eGaming Integrity has become a trusted partner for organisations seeking confidence in their control environments. The team delivers:

  • mock regulatory audits and inspection readiness;
  • independent internal audit programmes;
  • targeted remediation and advisory support.

Emma Shilling, Director, highlighted the firm’s commitment to meaningful, independent assurance: “Reaching our second anniversary is a proud moment. From day one, our focus has been to provide independent assurance that adds real value. We help embed governance and compliance into everyday operations to protect licences and reputations for the long term.”

Robert Penfold, Head of Internal Audit, highlighted the importance of objective insight in strengthening client operations: “Over the past two years, eGI has shown how truly independent audit and compliance support can reduce risk and give boards confidence that controls are working as they should. Our role is to provide clear, workable solutions that prepare businesses for scrutiny and support their ongoing success.”

Looking Forward

As it enters its third year, eGaming Integrity remains committed to delivering expert,

impartial, and commercially practical assurance. Whether preparing businesses for regulatory engagement, providing independent internal audit services, or supporting targeted remediation, the firm’s goal remains simple: to be the trusted partner that helps protect licenses and reputations.

The post eGaming Integrity Celebrates Two Years of Independent Compliance and Audit Expertise appeared first on European Gaming Industry News.

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Compliance Updates

Regulators Call for Stronger Measures Against Illegal Online Gambling

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Regulators of Austria, France, Germany, Great Britain, Italy, Portugal and Spain issued a joint institutional statement.

The fight against illegal online gambling is one of the paramount tasks facing regulated jurisdictions. Its borderless nature and the speed of technological innovation make it easier for illegal operators to evade regulatory oversight. This creates significant risks for consumer and public health protection, endanger public order and harms the activity of legitimate operators. In short, illegal online gambling undermines the entire regulatory framework designed to protect the public interest.

The statement reads: “We express our common concern regarding the increasing proliferation of advertising targeting our jurisdictions by unauthorised operators, particularly through digital channels such as social media, video platforms, and affiliate networks. These activities not only violate our national laws but also expose citizens — including minors and vulnerable individuals — to significant risks associated with illegal gambling.

“We wish to express our strong commitment to consumer protection, market integrity, and compliance with national and international regulations within the respective legal framework by:

• sharing information on illegal operators among us

• calling on digital platforms and social media networks to strengthen their control mechanisms to prevent the dissemination of advertising content from unauthorised operators

• reaffirming our commitment to share knowledge and better practices in identifying, investigating, and sanctioning operators acting outside the law.

This statement marks a renewed and united commitment by our jurisdictions to strengthen the integrity of the regulated gambling sector and to protect citizens from the risks posed by illegal gambling activities.”

The post Regulators Call for Stronger Measures Against Illegal Online Gambling appeared first on European Gaming Industry News.

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