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A Day in the Life of Rachel Wagstaff - Compliance Manager

As part of our work to make gambling safer and fairer, our Compliance team ensure that all licence holders comply with the law, our licence conditions and codes of practice. Our compliance activity concentrates on a variety of areas including carrying out assessments, raising standards of work. They also recommend enforcement action where licensees are not upholding the licence conditions and consumers are at risk of harm.

A key member of the Compliance department is Rachel Wagstaff, who has over a decade of experience in compliance having worked for firms regulated by the Financial Conduct Authority. Rachel has worked as a Compliance Manager at the Commission for over six years and has recently stepped into a new role overseeing a team of compliance colleagues.

This key role ensures that we adopt a risk-based approach to compliance work, and licensees are assessed in a consistent way. Rachel will also ensure any serious failings that are identified are escalated quickly to reduce the risk of consumer harm.

What does a typical day look like for you and the team?

Like most people in the Commission no two days are ever the same, but overall, I am here to reduce risk to the licensing objectives by making sure we carry out robust compliance assessments in a fair and proportionate manner. These assessments focus on key areas of risk, such as:

  • Governance and oversight
  • Anti-money laundering
  • Safer gambling
  • Marketing and advertising
  • Affiliate oversight

We offer support to colleagues in the enforcement team where compliance activity has been escalated to casework. We also review, assess and conduct enquiries from reactive work which is referred to us via other teams within the Commission. Referrals include information gathered by intel, contact centre and licensing colleagues. With all of the work that we carryout it is important that we identify breaches of our requirements and recognise and secure evidence to prove a breach of our conditions or offences under the Gambling Act. Where we identify serious failings, we ensure that these matters are escalated for enforcement action to be considered.

Before my new role, I was mainly involved in leading and assisting on online compliance assessments, as well as reactive work and assisting on enforcement cases. My role now is just as busy! I oversee compliance assessments, review the findings, and assist in the decision making on next steps. As well as this, I deal with any emerging issues we become aware of.

What work are you most proud of during your time at the Commission?

I am most proud of working with a team of people who are dedicated to raising standards across the gambling industry, and who put the protection of consumers and licensing objectives at the heart of what they do.

What are the biggest challenges the team faces in the future?

The biggest challenges we face in Compliance and across the Commission is being able to keep up with an industry that is constantly evolving, growing, and presenting new risks.

We are a small team in comparison to the industry – so we must work at pace to identify and tackle non-compliance.

How do you plan to overcome these challenges?

Our approach to Compliance is evolving all the time as we work to make gambling safer here in Great Britain.

We ensure that our resources are focused on the key areas of risk, the Licensing Objectives, and operators that are the greatest risk and could have the biggest impact on consumers. We have continued with this approach throughout lockdown and will continue to do so.

Moving forward, the focus of our work will be full compliance assessments. We conduct both full assessments, which assess all the key requirements of the LCCP, and targeted assessments that assess a specific aspect of the LCCP requirements. In addition to Thematic reviews to assess current or emerging risks. This activity enables us to take a close look at an operator and assess any risks to the Licensing Objectives.

A big part of our assessment work involves looking closely at customer accounts. By looking at customer spend, operator triggers, checks and interactions, we can identify where policies and procedures are not adequate or not being followed. We can also see the direct impact this has on a customer’s betting activity and identify where they may be at risk of harm.

Where serious concerns are identified, we can intervene and stop further risk of harm. Intervention by us could include encouraging the operator to implement new safeguards immediately, encouraging them to cease certain activities immediately and referring matters for enforcement action, which can include recommending immediate suspension of an operating licence.

What steps will you take in the coming months to make gambling safer?

Safer gambling has, and always will be at the heart of the compliance work we do. I will be overseeing assessments, where we will focus on the safer gambling controls that licenses have in place. I will also oversee a number of assessments, ensuring that we have assessed the key areas of the business and the assessment report and operator findings letter is an accurate and fair reflection of the assessment. I will also ensure that where failings are identified our approach is consistent and robust where it needs to be.

I will also ensure that where safer gambling issues are identified during our reactive compliance work, that these are investigated for breaches of our licence conditions and codes of practice and appropriate action taken.