Industry Forum minutes for 4 March 2025

Minutes of the meeting of the Industry Forum, 4 March 2025.

Location: The Studio, Birmingham and on Microsoft Teams.

Members:

• Nick Rust (Chair)
• Kirsty Caldwell
• Charles Cohen
• Ashley Padgett
• Mark Pearson (joined remotely)
• Nigel Roddis
• Leo Walker (joined remotely)
• Helen Walton
• David Williams.

In attendance:

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Apologies:

• Tony Boulton

1. Item 1: Welcome and Introductions

The Chair welcomed attendees to the meeting and noted apologies.

There were no new declarations of interest.

2. Item 2: Minutes of last meeting for approval

The minutes for the meeting held on 27 January 2025 were approved.

The amendment to the meeting minutes held on 25 October 2024 was approved.

3. Item 3: Actions update

The actions from the IF meeting held on 27 January 2025 were reviewed.

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All other actions had been completed prior to the start of the meeting.

4. Item 4: AML review

An introduction to the planned review of the anti-money laundering process was provided to forum members

An initial internal review including case work data has been undertaken to better understand the themes around AML and what operators are doing.

Through this initial process some gaps have been identified. The end goal is to drive up standards and keep crime out of gambling.

Now looking to increase engagement with operators and others, including the National Crime Agency and would like to have more engagement with Money Laundering Reporting Officers. More generally, the team would like to give more support to industry than has been available historically.

GC officials noted that they were keen to hear and understand the views of Industry Forum members on the issue and the areas that can be focused on to help both industry and the Commission.

A discussion took place with Forum members sharing their feedback and thoughts.

Members queried whether the GC had a view on how big money laundering is in the UK.

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GC officials were asked whether they were seeing common themes.

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GC officials were asked what their view was on the Commission and industry being close to agreeing an AML code.

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5. Item 5: Fair and open

An overview of the fair and open paper was provided to IF members. The GC is interested in getting a better understanding of issues around fairness and transparency for customers and will start by looking at delays to account withdrawals in this context. GC officials asked IF members to share any feedback or thoughts they had on the paper.

Members queried what was meant by ‘RTP errors’. GC officials clarified that it means where a games actual Return to Player (RTP) has not performed in accordance with its tested and certified performance. Some members commented that they would expect that to be an extremely small number.

GC officials reported that although this is not reported as often as it used to be, it is something that the GC continues to get reports on as it is classed as a reportable key event (LCCP Condition 15.2.1 - Reporting key events). GC officials reported that 344 gaming faults were reported in 2024 and 194 in 2023 (Reported incidence of gaming system faults). It was noted that these reports include RTP errors, but not exclusively.

Members commented that operators and suppliers are responsible for flagging these events. Mostly the manufacturer and/or supplier informs the operator – but the operator still has to report it to the GC as a key event.

IF members commented that personal documentation requests are an area with inconsistencies across operators. For some operators the previous 90 days bank statements is sufficient, whereas others ask for the previous 12 months of documentation. It would be helpful if there was guidance on what customers should expect from operators. For example, what kind of evidence is acceptable? How much information is it fair and reasonable to expect operators to ask from their customers?

Members reported that the level of information requested by operators can be because they are concerned about not applying the right procedures expected by the Commission.

Queries were raised on what customers should expect in terms of response times from operators. For example, if they have asked to withdraw funds, how soon should they expect to receive it? It is important to understand whether decisions are based on necessary AML checks or if it is for commercial reasons. The latter could suggest the decision is based outside of reasonable requirements. It was noted that some operators have a very risk averse AML policy which can lead to long delays in releasing funds. Members also noted that it will depend on the reason for withholding a payment. For example, where there is a suggestion of match fixing, an operator will withhold funds which can affect people who were making legitimate bets. This issue will mean contacting the appropriate sport's governing body, so the whole process can take months.

Members queried how big the withdrawals issue is. GC Contact Centre stats say that there are just over 2000 complaints about withdrawals from consumers per annum. Members were interested to know how many of these complaints were as a result of operators not complying with regulations and how many were as a result of operator own terms and conditions?

GC officials reported that the compliance team have initiated a data request amongst 18 operators (mainly large, but some medium sized) to get statistics on the pace of withdrawals.

One member said in their organisation, 99.8 percent of withdrawals are paid within 24 hours and queried whether the GC is seeing anything in the data they are getting that surprises them. GC officials reported that the research and statistics team have only just started to work on the data, so it is too early to report with confidence. However, the data is suggesting a lot of different patterns when it was expected to see something more homogeneous. Some operators release funds instantly, some take 24-48 hours and others longer. It was noted that the release of funds can often be affected by banks who are not able to support instant payments. Additionally, where there are delays, the most common reason given is the bank card does not match the details or has expired, meaning that the issue can often be at the banking end rather than with the operator.

IF members commented that it would be good for the GC to get a perspective from gambling consumers on their experiences with withdrawals and queried whether the Gambling Survey of Great Britain would be able to give a good enough picture of this.

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Members commented that how the GC responds to the issue of pool betting and operators seeding their own markets to generate the prize pot could unnecessarily and negatively impact progressive jackpots, poker games, etc, if it is written too loosely (as suggested it could be in the paper). It was suggested that the GC should be as direct as possible within the wording of terms and conditions to ensure that it targets the actual issue. It was recommended that the GC does not lead to an interpretation that restricts a pool to within one operator jurisdiction – thus enabling players outside the UK to win too.

IF members asked what the next steps were in terms of the fair and open paper and GC officials responded to confirm that the bulk of the primary recommendations within the paper will be taken forward in the GC 2025 to 2026 business plan along with some, but not all, of the other recommendations.

6. Item 6: Forum member contributions

Members commented that they don’t often hear back after providing feedback to GC officials, noting the recent GSGB question that the group responded to.

GC officials confirmed that feedback on the impact of the input from IF is due imminently. It has been delayed due to the research team being heavily involved in the planning and delivery of the Spring Conference.

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It is clear that the terminology around gross and net limits needs to be properly understood as there is still confusion around what a net deposit is. GC officials reported that this is imminent.

IF members highlighted that with consultations such as this, the Forum would be very keen to feed into them during the planning stages, so that they have an opportunity to help improve how they are received by industry.

Members highlighted the FRA pilot. They are aware that there is currently a small number of operators involved in that and noted that the IF could provide guidance on this before it goes out more widely and/or publicly to ensure that the GC has a wider set of perspectives.

7. Item 7: Any other business

The Chair thanked everyone for attending and closed the meeting.