Bacta SR Exchange - Bryony Sheldon speech
27 March 2025
This speech was delivered by Director of Policy Bryony Sheldon at the Bacta SR Exchange on Wednesday 26 March 2025.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Hello everybody, thank you for that introduction and thank you everyone for being here today. My name is Bryony Sheldon and I am a Director of Policy at the Gambling Commission. It is great to be here at the Bacta Social Responsibility Exchange to speak to you today. And I think its worth reflecting on what it is this event is here to do for a moment. At the Commission we think its really powerful when trade bodies and operators come together to discuss issues with each other and learn from sharing their best practice, especially in areas as important as keeping gambling safe. And that is all the more important when you can do it not just with senior figures but with staff working in venues and on the front lines too. So thank you to Bacta, Liz and John for organising today and thank you again to all of you for taking the time to attend. I’m sure it will be a really positive day.
But what am I going to add to the day? Well it won’t be news to any of you here that the Commission conducted assessments across the Adult Gaming Centre (AGC) sector in the second half of last year and so I will discuss that, what we learned and what we need all of you to focus on. I want to spend a bit of time reflecting on the recent workshops that our Compliance team ran and which so many of you attended. I’ll then touch on how we can make progress through collaboration more quickly and why we think events like today are so important to that. And as a Policy Director you would of course be surprised if I didn’t say a few words about the ongoing consultation on gaming machines. So I’ll finish with an overview of that and how important it is that you and your businesses get involved.
But first, back to the compliance activity last year.
Our team performed compliance activity across the sector in the latter half of last year. This was a mix of self assessment, venue visits and head office assessments. We saw several areas of good practice including controls to prevent underage gambling, local area risk assessments and attentive staff. As with all sectors though, standards can vary and we saw that some operators are struggling with certain elements of compliance.
Whilst we did see some comprehensive policies and controls, they didn't always capture the key criteria required to identify a customer who may be at risk of, or experiencing, gambling related harm. It is really important, particularly within a face to face gambling environment, that staff have sufficient guidance and training to identify the customer behaviours that may indicate that they are at risk of gambling related harm.
It was clear in most cases that lots of customer interactions were happening but some staff conducting interactions did not always demonstrate awareness of why they were having some of these conversations, particularly those earlier in the customer journey. Staff should be trained in identifying potential indicators of harm, how to conduct a customer interaction, and what to do if the behaviour or concern continues. They should be clear on what the aim of conducting an interaction is, how to record the outcome and how to monitor behaviour in case follow up action is needed.
Evaluation is one area of customer interaction where we have seen consistent challenges and failings. Operators are not always checking whether interactions are working effectively, whether follow up action is required, or whether the interaction was appropriate for the type of harm, or potential harm, identified. Evaluation, or reviewing the effectiveness, of customer interactions is a ‘must do’ as part of the conditions of your licence.
Outside of customer interaction another area we have seen some non-compliance is Money Laundering and Terrorist Financing Risk Assessments. These did not always consider all relevant risks, including those found in guidance we provide to you and in our own money laundering and terrorism financing risk assessment of the British gambling industry. You need to review these documents and ensure you have captured all relevant risks and any additional risks that you think your business may face within your risk assessment.
One of the key takeaways from this should be that providing the right training to staff - both in venue and head office - is essential, so that everyone is aware of both the compliance requirements and your business’s internal policies and controls. It is also key to ensure that customer interactions are conducted, recorded and evaluated.
With that said, we wanted to make sure we were doing everything we can at the Commission to help you and your teams get this right. So since the start of the year we have held four workshops and I want to go over how those went now.
I think it’s fair to say that we saw these workshops as particularly important when we looked at the challenges around customer interaction and anti-money laundering. In February we held four workshops in Leominster, Crawley, Loughborough and Glasgow. And I want to pass on the thanks of my Compliance colleagues to you and to all those who attended and supported the workshops that we hosted.
At each workshop we spent time going through the issues and challenges we observed in the assessments last year, particularly in the areas of customer interaction and Anti-Money Laundering (AML) as I have already mentioned. Table activities allowed operators to discuss these challenges and good practice between themselves and there were lots of great conversations so hopefully everyone took something valuable away from the day. And hopefully today’s event may well provide further opportunities to build on that.
The feedback from the workshops has been really positive and the team have reported back how good it was to engage directly with licensees in this way. Over 170 people attended representing 87 licensees. It was really good to see the opportunities for discussion between different Arcade owners and it was insightful for us to hear some of the challenges and good practice within the sector.
Following on from the workshops, our compliance team will be performing follow up assessments over the next few months. This is to ensure that some of the issues raised during last year’s assessments, and which were discussed in detail at the workshops, have been fully considered and implemented to ensure full compliance with regulatory requirements. We want to make sure you get this right. We want compliance at the earliest opportunity so if you have questions about this, my compliance colleagues are very keen that you reach out to them. Working together, through collaboration, we can get this right which will lead to positives for your customers and your businesses.
And the power of collaboration is something I just want to spend a moment reflecting on. At the Gambling Commission, as many will have heard before, we want a collaborative relationship with the gambling industry because we know that through working together we can achieve far more - and often more quickly - than if we simply rely on our formal powers alone. Now that relationship needs to be based on compliance first, of course, and I don’t mean that there won’t be times when we don’t see eye to eye. That is a natural part of how a regulator and those they regulate will find each other at times. But where we can, we want to work with you in collaboration to make gambling safer, fairer and crime free.
To that end we continue to prioritise getting out and seeing your businesses and how they operate. Whether they be our CEO Andrew Rhodes and his executive team, or colleagues within our contact centre and other operational or policy teams. The visits provide an insight into the day to day activities and challenges of the sector and allows us to meet our licensees and staff face to face. We will definitely continue these site visits and if you would be interested in hosting a visit, please do get in touch. We always welcome any offers.
And hearing from you is something that we have every reason to be focussed on currently given our open gaming machines consultation.
As everyone in this room will already know, we launched our consultation on gaming machines – in terms of LCCP and Technical Standards - on 29 January and it will be open for 16 weeks.
It’s important to say that we are really grateful for the feedback industry provided during pre-consultation. We believe your input and the evidence provided within it, has had a positive impact on our finalised proposals and supporting material. For example:
- We have added a second consultation option for the proposals on ‘limit setting’ and ‘display of sessional information’. This would exempt existing B3A and B4 gaming machines and games when made available for use in clubs.
- We have limited the ‘awards below the stake size’ and ‘prohibiting player-led features that permit a customer to reduce the time until the result is presented’ proposals to new Cat B and Cat C gaming machines and/or games, thus removing existing games from those proposals.
- Where existing gaming machines and/or games are within scope of our proposals we have extended the proposed implementation timeline from 18 months to 24 months.
Our intention was to arrive at a package of proposals that protect the vulnerable and ensures all consumers can make informed decisions about their gambling whilst recognising the need to minimise the impact on consumers who are not experiencing difficulty in managing their gambling safely.
We remain keen to hear workable alternatives to our proposals – but for those of you thinking about that we would challenge you that the starting point for alternatives should aim to achieve the same policy objectives as we have laid out in the consultation and that were envisaged in the Gambling Act Review White Paper.
We know our proposals may create technical challenges and lead to direct costs for licensees. We want to explore those areas further during the formal consultation and via the information and data requests that form part of this process. The information provided by you will inform our assessment of impact and the final decision-making process – which will need to consider the appropriateness and proportionality of our proposals through the lens of consumer benefits and costs to industry. So your input is vital to us getting the balance right here and as with every consultation we conduct, the responses we receive will inform where we finish and may result in amended policy positions.
And with that said, I think I’ll leave it there. It’s been great to be able to join you today. Events like the Bacta SR Exchange are really crucial in making sure all gambling businesses are compliant with the Commission’s rules and in that way playing their part in making gambling safer, fairer and crime free. So thank you again for being here and thank you for listening.
Thank you.
Last updated: 27 March 2025
Show updates to this content
No changes to show.