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European Gaming Congress 2024

Compliance Updates

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:

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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.

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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

Stakelogic Secures License to the newly regulated Danish market

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Industry-leading provider secures license to provide slots and live content in Denmark

Award-winning casino content provider Stakelogic has obtained a license from the Danish Gambling Authority, Spillemyndigheden, to provide its gaming content in Denmark.

The license will allow Stakelogic to bring its premium portfolio of online casino slots and live dealer content to the Danish market, including recent releases like Fire and Gold Cluster Breaker, Super Wheel Game Show, Trident of Legends, and The Watcher.

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Stakelogic is able to partner up with leading Danish operators, establishing itself as a must-have provider in the country. The move further highlights Stakelogic’s commitment to strengthening its position in the European market and exploring new and exciting regulated markets.

The license also further cements the company’s presence in the Scandinavian markets, having secured a license from the Swedish authority, Spelinspektionen, in 2023 and establishing itself as a popular provider among Swedish players.

Denmark is one of Europe’s fastest-growing markets, with a strong focus on customer care and responsible gambling. Stakelogic is proud to have met all the requirements needed to obtain the license, highlighting its commitment to providing players with the best and safest gaming experiences.

Stephan van den Oetelaar, CEO at Stakelogic, said: “Denmark is one of the fastest growing markets in Europe, and we are proud to have achieved a license to the newly regulated market.

We are grateful to Spillemyndigheden for their support in us and we are excited to take our next steps into the market.”

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Compliance Updates

UKGC Appoints Charles Counsell OBE as Interim Chair

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Charles Counsell OBE has been appointed as Interim Chair of the UK Gambling Commission (UKGC) for a nine month term which will commence on 1 February 2025.

Charles was Chief Executive Officer of The Pensions Regulator from April 2019 to March 2023. Prior to this he was CEO of the Money Advice Service, and Executive Director of Automatic Enrolment at The Pensions Regulator.

As CEO of The Pensions Regulator, Charles developed the new corporate strategy to put the pension saver at the heart of the Regulator. He delivered their first Equality, Diversity and Inclusion Strategy and Climate Change strategies – both focused on driving change in the regulator and across the Pensions Sector.

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Throughout his career, his roles have focused on setting up and delivering large change programmes requiring significant stakeholder relationship engagement: initially in the private sector and latterly in senior public sector appointments.

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Compliance Updates

SYNOT Games Secures Danish License

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SYNOT Games has obtained a B2B online slot games supplier license in Denmark, authorising the company to supply its gaming content within Denmark’s regulated market. This B2B license, issued by the Danish Gambling Authority (Spillemyndigheden), becomes effective on January 1, 2025, aligning with new regulatory requirements mandating that all game suppliers hold such a license from that date forward.

This development enables SYNOT Games to offer its portfolio of slot games to Danish operators, reinforcing its commitment to compliance and responsible gaming practices.

“Obtaining the B2B license from the Danish Gambling Authority marks a significant milestone for us in the Danish market. This license not only aligns with new regulatory requirements but also reinforces our commitment to adhering to the highest industry standards. We are thrilled to continue offering Danish players the immersive gaming experience our portfolio provides,” said Martina Krajčí, CCO of SYNOT Games.

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