Consultation response
Licensing, Compliance and Enforcement Policy: Consultation Response
This response sets out our position in relation to the consultation around proposed changes to our Licensing, Compliance and Enforcement Policy.
Contents
- Executive summary
- Introduction
- Summary of responses - Licensing changes
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- Proposal 1: Policy position in relation to dual regulation products
- Proposal 2: Changes to complete applications
- Proposal 3: Clarification of relevant persons
- Proposal 4: Timescale for using licence
- Proposal 5: Clarification of suitability criteria
- Proposal 6: Clarification of financing arrangements
- Proposal 7: Addition of new examples to update the Commission about
- Proposal 8: Minor updates to reflect minor changes to processes in the policy
- Summary of responses - Compliance changes
- Summary of responses - Enforcement changes
2 - Street collectors selling game cards
35.5. Licensing authorities may also be aware of street sellers in their areas approaching the public to sell them game cards, often saying that the cards are being sold to raise money for good causes. If such cards require an element of skill on the part of the player, such as completing a tie-break question, they may be genuinely distinguishable from a lottery.
35.6. It will be unlikely that the product being sold is a legal lottery. This is because societies running large lotteries are not permitted to sell lottery tickets in the street by virtue of a condition on their operating licence, and the Commission recommends in this guidance that those running small lotteries have a similar restriction imposed upon them by the local authority that registers them.
35.7. The Commission has no comment on products that are not classed as gambling under the Act, but would advise authorities with concerns over street sales of such products to contact the trading standards department. They will be able to advise on whether the product being sold amounts to a gambling product and agree on the best course of action, which may include relying on relevant legislation such as street trading regulations.
Last updated: 14 September 2023
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