Compliance Updates
Our UKGC consultation response: Failing to protect the vulnerable should not be the White Paper’s legacy
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
DCMS Concludes Consultation on Gambling Regulation Funding
The Department for Culture, Media and Sport (DCMS) has published its consultation response on the funding of the Gambling Commission which took place between January and March this year.
The 2023 White Paper committed to a review of the Commission’s fees to ensure sufficient resources to deliver its core responsibilities and the commitments outlined in the Gambling Act Review.
The consultation findings now provide certainty on the Commission’s future income for the coming years.
Licence fees will increase by 25% overall, but the specific changes to fees will be different for each type of operating licence. New fee categories will also be introduced for most licences. Operators are strongly encouraged to review the annexes to the Government’s consultation response to understand how these changes affect their business.
Fees for society lotteries will be held at their current levels, and a new system of fees calculation will be implemented for non-remote general betting limited licence holders. Fees for personal licences will increase by a flat 25%.
Changes to the fees are subject to the passage of secondary legislation and will take effect on 1 October 2026.
Over the coming weeks, operators will be contacted by the Commission with further details about how this affects them and information about alignment to any new category. The criteria for the revised fee categories are set out in the DCMS consultation response. An operator’s submitted regulatory return data for 2025 to 2026 will be used to determine its new fee category.
For further information about the findings of the consultation you can visit the DCMS consultation response webpage.
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Compliance Updates
Tim Miller Announces Departure from UK Gambling Commission
The UK Gambling Commission has announced that Tim Miller, Executive Director of Policy & Research, has decided to leave the Commission in September 2026 after 10 years of service.
Following his departure, Tim will take up a new role outside of the British regulated gambling industry, supporting governments, regulators and other organisations that are developing and overseeing gambling regulatory systems around the world.
During his time at the Commission, Tim has played a leading role in strengthening the Commission’s research and evidence base, bringing greater rigour and robustness to its research framework. He has overseen the development and launch of the Gambling Survey for Great Britain – the largest survey of its kind anywhere in the world – helping to transform the evidence available to inform gambling regulation and policy.
Tim has also led the Commission’s work to implement the Government’s Gambling Act Review White Paper, overseeing the introduction of a wide range of new protections and regulatory measures. These include reforms to age verification, financial vulnerability checks, remote game design, direct marketing controls and wider measures to make gambling safer, fairer and free from crime.
Tim Miller said: “I have worked at the Commission longer than anywhere else during my career and have found it the most rewarding and fulfilling role. In large part this has been due to the amazing and dedicated colleagues that I’ve had the pleasure to work alongside. That’s what made it a hard decision to leave but after ten years I felt ready for the next challenge.”
Sarah Gardner, Acting Chief Executive of the Gambling Commission, said: “Tim has provided outstanding service to the Commission for ten years. I would like to thank Tim for his significant contribution to gambling regulation and wish him every success in the future.”
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AGCO
AGCO Fines Great Canadian Entertainment $120,000 for Using Unauthorised Gaming System Software at Four Casinos
The Alcohol and Gaming Commission of Ontario (AGCO) has ordered monetary penalties totalling $120,000 against Great Canadian Entertainment (GCE) for using unauthorided gaming system software at multiple Ontario casino sites, a serious compliance failure that bypassed requirements designed to protect the integrity of casino gaming.
Gaming equipment and systems are central to casino operations. They process payments and wagers, support slot-game play and help maintain controls that protect the integrity, safety and security of the gaming environment. When these systems are used or operated without required testing, monitoring and approval, it weakens safeguards designed to detect and prevent unlawful conduct, including money laundering, and can undermine public confidence in Ontario’s regulated casino sector.
The AGCO reviewed 40 instances in which revoked or unapproved bill validator software had been installed across four casino sites between February 20 and March 15, 2025. Bill validators are components within gaming machines that accept and process cash and help support anti-money laundering controls.
The AGCO’s Standards for Gaming require gaming equipment and software to be tested and approved before being deployed in casinos. Bill validators verify the authenticity and value of cash inserted into electronic gaming machines and are an important safeguard. That is why these systems must undergo rigorous testing and approval to confirm they operate as intended, perform critical functions reliably and are authorised before being introduced into a live casino environment.
Casino operators are responsible for ensuring that changes to gaming systems are properly reviewed, tested and authorised before implementation. Using unapproved software in a live casino environment is a serious compliance failure.
A casino operator served with an Order of Monetary Penalty has the right to appeal the Registrar’s action within 15 days to the Licence Appeal Tribunal (LAT), an adjudicative body that is part of Tribunals Ontario and independent of the AGCO.
“The AGCO requires casino operators to protect the integrity of their gaming systems by making sure they are independently tested, approved and operating as intended. When unauthorised software is used in a live casino environment, it bypasses critical safeguards that are meant to uphold the integrity of gaming and the public’s confidence in the system. The AGCO will continue to hold all casino operators accountable for meeting Ontario’s high standards of gaming system integrity,” said Dr. Karin Schnarr, Registrar and Chief Executive Officer at AGCO.
The post AGCO Fines Great Canadian Entertainment $120,000 for Using Unauthorised Gaming System Software at Four Casinos appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
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