Checklist of considerations
We welcome sight of novel product or concept developments before they are deployed in the market. We do not approve individual products, and the responsibility rests with operators to ensure that their developments are compliant and will help to deliver the licensing objectives of the Gambling Act. It is recommended that businesses obtain their own legal advice in this regard.
To assist developers we have provided a broad checklist of items that we expect them to have considered before contacting us. The list is not exhaustive and must not be considered in isolation from the previous advice. It provides a basic list of key issues.
In respect of the cashless technology product or system you are developing, you should be able to fully explain:
- How you will make sure that consumers are required to have a break from gambling before they are able to access and use new funds.
- How you have satisfied yourself that you will be compliant with the Gaming Machine (Circumstances of Use) Regulations in respect of the use of debit or credit cards, payment limits and committed payment limits.
- What anti-money laundering controls you have considered in designing your solution. For example, would a player be able to fund a gambling product via cash and then withdraw funds via an app or digital wallet?
There are also a variety of harm mitigation and consumer empowerment measures that you should consider. You should ask yourself:
- What information can your product provide to the consumer about their own gambling? For example, will consumers be able to access information on their transactional gambling history over certain periods of time?
- Are you able to provide tools that enable the user to manage their gambling? For example, can the consumer use the product to set limits on the amount of money they are able to deposit or spend over a certain period of time?
- What alerts would be triggered when a limit is reached? How will the limit-setting be made effective in terms of reducing the risk of gambling-related harm?
- Does the product allow for users to voluntarily stop themselves from using the product for gambling purposes for a period of time? Or provide a cooling off period period whereby the product cannot be used for gambling for a certain period of time?
- If the product or system is to be made available for use with different gambling products (including different categories of gaming machine), how will you ensure that your solution is adaptable and able to respond to the different nature of each gambling product and the associated risks or legal requirements?
- Does your solution enable you or a gambling operator to monitor customer behaviour (for example, the gambling spend or intensity of an individual customer) over a period of time?
- How can you prevent, or assist in the prevention of, underage gambling?
Licence Conditions and Codes of Practice: cashless payment
Last updated: 23 November 2023
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