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Guidance

Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.

Published
1 April 2021

Last updated
17 July 2023 - Changes

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Contents

RTS 11 – Limiting collusion and cheating

Applies to:

Peer-to-peer gaming

RTS aim 11

To reduce the risk that cheating or collusion by players unfairly disadvantages another player and to inform customers about the risks posed.

RTS requirement 11A

Measures intended to deter, prevent, and detect collusion and cheating must be implemented. Gambling systems must retain a record of relevant activities to facilitate investigation and be capable of suspending or disabling player accounts or player sessions. Operators must monitor the effectiveness of their policies and procedures.

RTS implementation guidance 11A

  1. Relevant activities to be recorded will vary by game but may include:
    1. which players played at which tables
    2. the amounts won from and lost to accounts
    3. game activities to an individual bet/action level.
  2. Where appropriate, prevention measures may include:
    1. taking steps to prevent a player from occupying more than one seat at any individual table.
  3. Detection measures may include, detecting and investigating the following, where appropriate:
    1. players who frequently share the same tables
    2. players from same address who share the same table
    3. suspicious patterns of play (such as chip dumping)
    4. unusual gameplay statistics.
  4. Customer complaints about cheating should be investigated.
  5. Records should be kept of investigations which result in an account being closed including:
    1. player details (name, location, which licence the activity was in reliance on), scale of the offences (financial and number of players), time and date etc
    2. the reason for investigation (including whether it was initiated by customer contact) and the outcome
    3. any relevant evidence such as reports, screenshots, chat history etc. This information should be considered when updating the risks identified in relevant policies and procedures.

RTS requirement 11B

Information must be made available about the operator’s policies and procedures with regard to cheating, recovered player funds and about how to complain if a customer suspects other participants are cheating.

RTS implementation guidance 11B

  1. As a minimum deterrent, customers should be informed that accounts will be closed if the customer is found to have cheated.
  2. Information regarding funds that are recovered from accounts during integrity investigations is not expected to cover every scenario but should highlight the main aims of the policy.
  3. Relevant information should be included in terms and conditions or rules.
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