Prize draws in the digital age

Anti-money laundering responsibilities for casino businesses

There are various license types, including remote casino, remote betting, and land-based licenses. The Gambling Commission’s Notice essentially makes clear that those B2B operators have a role in assisting the Gambling Commission in tackling unlicensed gambling in the British market and that such B2Bs place their own licence at risk by not taking sufficient steps to ensure that its content is only made available to British consumers via licensed B2C websites. Similarly, a centrally co-ordinated self-exclusion database (“GAMSTOP”) also allows customers to self-exclude from remote gambling offered by operators licensed by the Gambling Commission. In contrast with some jurisdictions, only casinos form part of the “regulated sector” for AML purposes, though all operators are required to conduct detailed risk assessments and implement AML policies, procedures and controls.

The Act initially covered gambling offered in premises based in Great Britain and also remote gambling offered by GB-based operators. To increase their confidence in using these powers, we will align the regimes for alcohol and gambling licensing by introducing cumulative impact assessments when Parliamentary time allows and will consult on increasing the maximum fees they can charge for premises licences and permits. While most age-restricted products including gambling are permitted from age 18 in this country, there is evidence that young adults (such as those age 18 to 24) may be particularly susceptible to gambling-related harm. The Commission will become a more proactive regulator and it will now start building the capacity to require and analyse more data from online operators to identify non-compliance with licence conditions.

As outlined, the Gambling Commission has expressed concern regarding the adherence of operators to ‘available for use’ guidance. The increased flexibility will provide operators with more scope to make commercial decisions relating to energy consumption and customer demand. Under the scenario outlined in Option 1, it is expected that there will be a significant increase in commercial flexibility for operators across both bingo halls and AGCs. Similarly to bingo halls, this would likely result in both energy savings and increased GGY for operators. The removal of energy intensive legacy Category C cabinets will likely reduce the overall energy consumption of these operators.

This section of the consultation received 46 responses, primarily from licensing authorities and gambling operators. In contrast, most industry responses were concerned that customers may use this information to incorrectly determine that a machine is due a pay-out and therefore could lead to people spending more on a machine. Most responses in favour of implementing these features on machines were in agreement with the rationale outlined in the consultation that it would help customers to make more informed decisions and keep track of their spending.

Working with the Gambling Commission and others, we will now make online gambling safer with an overhaul of game design rules to remove the features known to exacerbate risks, and put new obligations on operators to prevent unchecked and unaffordable spending. By the second quarter of 2025, five online casinos based in Britain shut their virtual doors, listing compliance headaches and higher bills as key reasons. A fresh batch of rules is reshaping the day-to-day running of online casinos in the United Kingdom, bringing big changes for operators and players alike. The proposals were opposed by the gambling industry, including the Gibraltar Betting and Gaming Association.They also regulate crypto gambling websites and mitigate the risk of money laundering through such sites.

Prize draws in the digital age

Apart from reviewing the activities of the licensed operators, the Commission is authorised to take regulatory actions against those licencees who breach the rules in some way. Previously, an operator in one of the whitelisted gambling jurisdictions could advertise their services in Great Britain without requiring a separate licence from the Commission. The Gambling Commission is an executive, non-departmental public body of the Government of the United Kingdom responsible for regulating gambling and supervising gaming law in Great Britain. The industry supports thousands of jobs across the country and the Government has been clear it does not want to harm its success.

In spite of this action and the Commission’s stated expectations, some respondents complained that operators made withdrawing money from accounts unnecessarily difficult and subject to artificial delays (especially prior to the Commission’s ban on reverse withdrawals) which do not apply for deposits. Further concerns were raised in areas where the Gambling Commission has previously taken action, including rules around the timeliness of requests for identity documentation. For example, while operators are required to disclose key information on their products, a recent study examining 350 roulette games offered by 26 major operators suggests this can be very onerous for users to access in practice. A reasonably widespread concern in call for evidence responses from consumer groups and private individuals was that friction is unequally distributed across the customer journey in a way that can disadvantage consumers. Such transparency supports consumer confidence in a fair and open market, and should not bring new costs to the industry or consumers. We are reinforcing existing expectations concerning the need for operators to provide clear and transparent terms of service to consumers.

While a wide array of evidence submitted to the Commission and this Review has shaped our proposals, three key information points have been important in helping to make sure our proposals are proportionate and properly address the identified risks. The Commission’s requirements will specify that these checks should only be undertaken at the appropriate time and for legitimate purposes like harm prevention rather than to inform marketing tactics or disadvantage successful customers. The consultation will also consider how operators should respond to any findings from these checks in concert with their wider assessments of customer risk.

These responses also argued that ‘self-regulation’ is too prevalent in gambling advertising and could not be relied upon to reduce harm, particularly with regards to online formats such as social media advertising, affiliates and direct marketing. Recent reforms such as the Gambling Commission’s toughened regulations for VIP schemes or the voluntary suspension of broadcast advertising during the initial COVID-19 lockdown were cited as evidence that the current system is able to respond quickly where new risks emerge or evidence of harm is found. The shift towards online data-driven marketing outlined above is not unique to the gambling sector, and should be considered in the context of the broader digital ecosystem. We welcome industry’s expansion of its commitment to safer gambling messaging to constitute 20% of all advertising across both online and broadcast channels.

• The Gambling Commission’s statistics from May 2020 show that they represented 47% of total employment in the gambling sector.
• By contrast, Option 2(a) would likely increase the numbers of Category B cabinets in a similar proportion to Option 1, while safeguarding against the possible scenario in which Category B machines become the only cabinet gaming machines offered.
• Today, casino online sites must make an application to the UKGC if they want to operate and advertise legally in the UK.
• By employing decentralized systems, casinos can increase player trust and reduce fraud scenarios.
• We will legislate to increase the minimum age to play cash-payout Category D slot machines to 18 years, reinforcing The British Amusement Catering Trade Association’s (Bacta) voluntary commitment.
• Because one of the main objectives of the Gambling Act 2005 is to protect children from gambling, the Commission has implemented a range of measures to prevent underage play.

The current process to assess these changes of control is taking up a considerable amount of the Commission’s time as it often has to pause applications to consider significant suitability concerns or open a licence review. The Commission has found that carrying out due diligence on a new owner to ensure that the licensing objectives are being met can often be complex and challenging. This has been demonstrated over the last few years, including through the implementation of the ban on credit cards and making membership of GAMSTOP compulsory through the LCCP. Such an approach would allow for dedicated team members to develop in-depth knowledge and understanding of these operators, which will also enable earlier intervention.

Some operators were keen to highlight the increasing cost burden for land-based casinos in other areas, but acknowledged the logic of applying consistency across regimes. Currently, 1968 Act casinos are not required to have a table gaming area so the premises plan will need to be updated accordingly. In order to include SSBTs as part of a sportsbook offering, casinos would be required to apply for a remote general betting standard real events licence. It was also suggested that customers who do not normally engage in sports betting online may be encouraged to do so via availability in a casino. Those opposed to sports betting in casinos suggested that a broader range of products makes it easier for gamblers to move from activity to activity, upscaling losses and potential harms.

We will also consult on slot-specific measures to give greater protections for 18 to 24-year-olds who the evidence suggests may be a particularly vulnerable cohort. The Review launched with a call for evidence which ran from December 2020 to March 2021 and received 16,000 submissions. The package of measures outlined in this white paper will significantly increase protections with the aim of preventing harm.

Option 3: Remove the 80/20 rule completely, applying no requirements on set gaming machine ratios

For instance, one operator found that the rates of harm detected among customers who had created their account with a sign up bonus was no different than among those who had no such offer, while another analysis found no correlation between receiving cashback bonuses and self-exclusion. Industry offered some insight based on its own data in relation to these promotions and their impact on customer behaviour. In the Gambling Commission’s online tracker survey, 65% of respondents who had seen promotional offers reported that they had an impact on their gambling behaviour, whether that was gambling for the first time or restarting after a break, the amount gambled, or the product gambled on. Submissions from people with personal experience of gambling harms elaborated on the negative effects which can come from such direct marketing and inducements. This is likely due to a combination of operators deliberately targeting more engaged customers, and engaged gamblers being on a greater number of mailing lists.

The government will consider the need for bespoke dedicated safe play messaging as part of cashless gambling on gaming machines. Should there be voluntary limits (the ability for customers to set time and monetary thresholds) on gaming machines accepting direct cashless payments? The authorisation required by the account holder in these systems mitigates against the risk of cashless payments facilitating crime through stolen cards being used on gaming machines. The risk would be that some forms of direct cashless payment (such as contactless) lack account verification and could allow stolen cards to be used on gaming machines. While it is important to future-proof gaming machine payment methods, there must be a balance between this and any elevated risk of harm that could emerge from allowing direct cashless payment methods to be used for gambling. As such, any change in the composition of gaming machines which results in a higher share of Category B machines will represent an uplift in GGY for operators.

Introduction of an age limit on ‘cash-out’ slot-style Category D machines

Verification typically involves submitting identification documents (passport, driving licence), proof of address (utility bill, bank statement), and in some cases a selfie or video verification. The casino must clearly state which ADR provider it uses in its terms and conditions. If you have a complaint that the casino cannot resolve internally, you can escalate it to the ADR provider for an independent, impartial review. The RTP published for a slot, for example, has been confirmed by third-party testing — the casino cannot quietly alter the odds. When you see logos from these organisations on a casino’s website, it means the games have been independently verified to operate as advertised.

The review found mostly cross-sectional studies linking gambling to harm, with more longitudinal research needed to isolate the causative role of gambling in the harms people experience in order to estimate a more accurate cost. Conversely, industry argued that calculating the social costs of gambling in order to recoup these costs is inherently complex. Canadian provinces tend to have high levels of expenditure addressing gambling harm paid for out of general taxation; but all have specific proportions of their total revenue derived from specific taxes on gambling. GambleAware also produces national safer gambling campaigns to raise awareness and encourage behaviour change in relation to gambling-related harms.

The legislation covering the gambling sector was written in 2005. It has made gambling easier, quicker and often more fun, but when things go wrong it can see people lose thousands of pounds in a few swipes of the screen. We live in an age where people have a virtual mobile casino in their pockets. These are the most comprehensive reforms to the gambling sector since the Gambling Act was introduced in 2005, and delivers on the 2019 manifesto commitment to review this act. Betting companies are already required to prevent harm, but there have been repeated instances where they have allowed losses which the majority of the population could never afford.

Similarly, PHE’s evidence review found no substantial evidence to establish that exposure to advertising is a risk factor for harmful gambling, although this may only indicate a lack of evidence rather than a lack of relationship as PHE only examined systematic review level evidence. We are calling on operators to take existing commitments in the industry code further, and use the full potential of available advertising technology to target all online advertising away from children and vulnerable people and those showing indicators of harm. The Commission will also take forward work to strengthen consent for direct marketing for online gambling, with both new and existing customers given more choice on what offers they want (including requiring consent to ‘cross-selling’ new products) and how marketing is sent to them. Although there are no specific laws preventing customers’ use of cryptoassets to fund gambling, operators may only accept them as payment if they can comply with all Gambling Commission requirements, including anti-money laundering, ‘know your customer,’ and safer gambling measures. Not only is self-exclusion an unsuitable substitute for account closure in most casino not on gamestop circumstances, but it is also a key proxy for harm used by operators to learn how to identify potentially harmful gambling within play data.

We currently estimate that the key proposals we can quantify will lead to between a 3% and 8% reduction in Gross Gambling Yield (GGY) across the gambling sector, with the main decrease being in online gambling (where we estimate a reduction of between 8% and 14% of GGY). It is likely that the proposals will come with costs to the gambling industry, both in terms of upfront delivery cost but also in reduced revenue compared to current levels. Measures in this white paper are designed to increase existing protections against gambling-related harm in a proportionate and targeted way.

The committed payment limits are £10 for Category B1, B2, B3 and B3A machines, and £5 for Category B4 and C machines. The deposit limits are currently set at £20 for Category B and C machines, and £2 for Category D machines. Vii) Category D machines (Optional response) We also strongly disagree with the assertion that Category D crane grab machines should not have a maximum transaction limit. It will also help mitigate against the risk of someone putting a significant sum of money onto a machine in one go. However, customers can continue to deposit money onto the machine without needing to pause or undertake an action.