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Consultation response

Changes to information requirements in the LCCP, regulatory returns, official statistics, and related matters

Parts I and II of the consultation response that sets out our position in relation to the information the Gambling Commission requires licensees to provide us.

Published
30 July 2020

Last updated
15 May 2023 - Changes

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Contents

Proposal 5: Additional licence condition 15.1.3 (reporting of systematic or organised money lending)

Proposal

We proposed to introduce a new licence condition (15.1.3) relating to the reporting of systematic or organised money lending. Ordinary code provisions 3.8.1 and 3.8.2 currently provide for licensees to report to us instances of systematic or organised money lending between customers on their premises. We proposed to formalise this reporting requirement via a new licence condition which requires all non-remote casino, non-remote bingo, general betting, adult gaming centre, family entertainment centre and remote betting intermediary (trading rooms only) licensees to report to us any systematic or organised money lending, in accordance with the ordinary code provisions.

Consultation question

Question 1.5. Do you agree with the proposals for the new licence condition?

Respondents' views

Overall, respondents welcomed the introduction of this new licence condition and stated that improved reporting of known or suspected systematic or organised money laundering would give us more visibility of this issue and allow us to better protect consumers. A standardised format and common submission arrangements were also appreciated by licensees.

Some respondents commented that detailed guidance would be required for them to interpret this licence condition. Specific points related to the need for clarity over the terms 'reasonably practical', 'suspect may relate to' and a request for definitions of 'systematic or organised money lending'. Others added that the new licence condition duplicated ordinary code provision 3.8.1, which requires non-remote casino licensees to report systematic or organised money lending to us.

Another respondent stated that there is no evidence that systematic or organised money lending is currently an issue within gambling premises and therefore this new licence condition is unnecessary. Moreover, that if any such activity were identified, it would be reported to the police and the resultant criminal investigation reported to us as a key event. This comment was supported by the observation that the current ordinary code provision requiring non-remote casino licensees to report systematic or organised money (3.8.1) was not mirrored in the linked provision (3.8.2) for premises types other than casinos. Another queried why the licence condition would not also apply to remote gambling.

Our position

Ordinary code provision 3.8.1 provides that non-remote casino licensees should take steps to prevent systematic or organised money lending between customers on their premises, and have appropriate arrangements in place to cover any cases where it appears that the lending may be commercial in nature or may involve money laundering. The ordinary code also provides that a report should be made to us of all cases where the licensee encounters systematic or organised money lending.

Additionally, it provides that a licensee should follow the reporting requirements where any lending may involve money laundering.

Ordinary code provision 3.8.2 provides that licensees other than casinos should seek to prevent systematic or organised money lending between customers on their premises, including arrangements for staff to report any instances of substantial money lending when they become aware of them.

Ordinary code 3.8.1 includes a provision to report instances to us and ordinary code 3.8.2 provides for the reporting of instances of substantial money lending by staff. In the latter case, such information is of interest to us as the regulator of gambling and to meet our obligations to prevent gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime.

Currently, there is no formal mechanism to report instances of money lending to us and we proposed to add this licence condition to make provision for such reporting. The new licence condition had no other purpose and does not supersede ordinary code provisions 3.8.1 and 3.8.2. We have, however, amended the proposed licence condition so that it better reflects that position.

The term 'as soon as reasonably practical' is used elsewhere in the Licence Conditions and Codes of Practice (LCCP) and we do not intend to define it separately here. The need to report money lending has not been extended to remote gambling as structural differences limit the risk of money lending between customers in that environment.

As with all other reportable events, reports should be submitted via the eServices digital service for operators on our website. We intend to provide further guidance on how to meet this requirement. However, the information provided should include details of the incident in sanitised form, for example, the financial volume involved and the actions taken by the licensee (such as whether it was reported to law enforcement and whether the customers involved were barred by the licensee). Where a suspicious activity report is submitted to the United Kingdom Financial Intelligence Unit (UKFIU), the licensee should also provide the unique reference number of the report.

It is our intention to review ordinary code provisions 3.8.1 and 3.8.2 later in 2020, to ensure that they correctly align.

The following changes will take effect from 31 October 2020.

Final wording of new licence condition 15.1.3

Licence condition 15.1.3
Reporting of systematic or organised money lending
All non-remote casino, non-remote bingo, general betting, adult gaming centre, family entertainment centre and remote betting intermediary (trading rooms only) licences

1 Licensees must as soon as reasonably practicable, in such form or manner as the Commission may from time to time specify, provide the Commission with any information relating to cases where they encounter systematic, organised or substantial money lending between customers on their premises, in accordance with the ordinary code provisions on money lending between customers.

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Proposal 4: Changes to licence condition 15.1.2 (reporting suspicion of offences) Next section
Proposal 6: Changes to licence condition 15.2.1 (reporting key events – operator status)
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