Global Gaming Expo - Tim Miller speech
11 October 2023Speech by Tim Miller
This speech was delivered by executive director Tim Miller at the Global Gaming Expo (G2E) on 10 October 2023.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Thank you everyone, and thank you Wes for your presentation. You’ve all now heard the perspective from a representative of the British Gambling Industry. Now let me tell you about how the world looks according to the regulator of that industry - the Gambling Commission. I’m Tim Miller, and I’ve been at the Gambling Commission now for over seven years, serving on the Executive Team with responsibility for Research and Policy and I’m also the Senior Responsible Owner for our work in implementing the British Government’s review of gambling legislation and regulation.
So recognising that we have a very international audience today, I want start with a brief overview of the British Market, why it looks as it does, our approach to its regulation and what impact that has had. Of course it doesn’t matter what size your jurisdiction is or how well established it is, you’re always going to be affected by the trade winds from other parts of the world. So, I will also talk about the growing importance we put on international collaboration with our fellow gambling regulators and, in particular, how we’re tackling illegal online gambling. Finally, I’ll give a short update on how the Government review of our gambling laws and regulations is progressing and why that should be of interest to you, wherever you are in the world.
But first, what does gambling look like in Britain.
When we look at the British gambling market, even when you account for impacts of the Covid-19 pandemic, it continues to show all the characteristics of the mature licensed market that it is. When we look at our statistics on participation in gambling in Great Britain we see:
- the year to end of March 2022 saw Gross Gambling Yield at £14.1 billion
- even excluding lotteries that number is £10 billion a year, making the British jurisdiction the largest licenced online market in the world
- when we look at participation, the year to end of March 2023 saw 44 percent of adults taking part in a gambling activity during the previous 4 weeks.
Many things have changed in the world since Covid-19 first hit and gambling hasn’t been immune but the fact that these numbers are similar to where we were in early 2020 does tell a story in and of itself.
And the story is the same when we drill a bit more into participation too, with the land-based gambling participation rate for the last year remaining statistically stable at 27 percent and online also remaining statistically stable at 26 percent.
So we have a mature, fairly resilient and stable market in Great Britain and by international standards a liberal approach to products with high rates of channelisation.
Now all businesses want to grow, we get that. And in an ultra competitive market innovation will be an essential part of that growth strategy. And some of the changes we are seeing are to the benefit of consumers and to player safety. But what I want to remind everyone here today is whilst the Commission understands operators are experiencing competitive times, we make no apology for expecting – and demanding - the interests of customers be their first priority. We demand that there is compliance with our standards, and we will not tolerate business practices that put consumers at risk.
Now although we’re currently implementing with Government changes to the Gambling Act 2005 - the legislation that set up the Commission and our regulatory model - we already have broad and uncompromising powers to enforce our rules and regulations against those operators in the British market.
- the last year has seen the Gambling Commission conclude the largest enforcement cases in our history
- in terms of scale we broke our own record for the largest ever settlement twice in the last financial year
- and again, in the last financial year of 2022/23 the Commission concluded 24 enforcement cases with operators paying over £60 million because of regulatory failures
- this compares with just three operators paying out £1.7 million because of failures in the 2016/17 financial year.
And operators are taking note. One leading operator recently told us from their own research that 9 out of 10 of the largest enforcement penalties worldwide and 85 percent of all enforcement action in gambling worldwide has been carried out by the British Gambling Commission. I don’t tell you these statistics as some sort of brag. From one perspective, having to take enforcement action at all shows that something has gone wrong. But our willingness to use the weight of the powers granted to us by Parliament is leading to operators reassessing how they behave and perform in our jurisdiction and how seriously they take compliance with our rules.
However, whilst we are having results domestically, gambling is a global business. Leading operators are now multi-nationals. As more North American jurisdictions open up to online gambling or sports betting, we see more and more large British or European operators looking to establish themselves here, in your markets. And that’s why we think international collaboration is so vital between gambling regulators. Increasingly we regulate the same companies; we address the same risks; we face the same challenges.
The Commission regularly talks about the importance of international collaboration between regulators, and we work hard to strengthen our relationships with other regulators abroad. But sometimes people wonder what it actually means, what it can achieve.
So let me illustrate what we are doing by taking one issue as an example: illegal online gambling. What might be illegal in one jurisdiction might not be in another. Similarly, some jurisdictions don’t yet regulate online gambling at all, and most regulators are largely focussed on what operators are doing in their own jurisdictions. But let’s also remember that legitimate, licensed operators from one jurisdiction can actually be the illegal or black market in another.
The more gambling regulators know of each others rules, standards and markets, the more we are sharing information and best practice, the more we support each other then the more effective we will be. This in turn makes it harder for uncooperative operators to circumvent a regulator’s regime or means they are more likely to face difficult questions in their home jurisdiction if they act poorly elsewhere. In short, if you are noncompliant in one jurisdiction don’t be surprised if you are the subject of regulatory conversation in other jurisdictions.
As more and more countries look to regulate online gambling, we at the Commission are only too ready to work with them, to support them in establishing their regimes and indeed to learn from them. Yesterday I was delighted, alongside our Chair, Marcus Boyle, to host a roundtable for regulators across North America to discuss the practical steps we will take to enhance regulatory collaboration. We are also close to concluding a number of Memoranda of Understanding with US regulators, in order to establish clear working relationships that will support all of us to be more effective.
I’m also pleased that we have been helping to broker stronger links between the North American Gaming Regulators Association (NAGRA) and the Gambling Regulators European Forum (GREF). We expect this to lead to much more sharing of knowledge and experiences at a cross-continental level, especially in those subjects areas like safer gambling, where our regulatory approaches and philosophies are increasingly aligned.
Now I’ve already touched on illegal online gambling and this is a particular focus for the Commission at the moment and an area that proves that collaboration can deliver greater results than working alone.
Whilst relying on our own powers, including soft power, we have had some level of success. Over the last year we have focussed on working upstream to shut down the access that illegal sites targeting the British market have to our consumers. And through engagement and collaboration with payment providers, internet search providers and product and games developers, we have been able to deliver some dramatic results, with a 46 percent reduction in traffic to the largest illegal sites coming into our market. Our CEO, Andrew Rhodes, will be talking more about this at the International Association of Gambling Regulators (IAGR) Conference next week and I would encourage those of you grappling with similar issues to follow that speech because our experience is that you can make a sizeable impact in this space.
But it also proves collaboration is vital. And again, that goes for collaboration between gambling regulators. Just last month we discussed how we can collectively better tackle illegal online gambling with fellow European regulators and we have been engaging with many other regulators, including jurisdictions from Australia on one side of the world to Curaçao on this side.
Only through working together can we ensure we all have safe, fair and crime free gambling. If as regulators we are able to speak, more often, with one voice then it will enhance our ability to influence those outside the industry - who need to play a more positive and direct role in tackling issues like illegal gambling. The collective voice of gambling regulators across the globe pressuring big tech companies, banks and even some other jurisdictions to address the role they play in facilitating illegal gambling, will be much harder to ignore.
And making gambling safer, fairer and crime free was a driving force behind the British Government’s Gambling Act Review White Paper as well. Published in April this year, it made over 60 recommendations, outlining action to take. I’m pleased to say the Gambling Commission for its part has already begun implementation and the first round of consultations were opened in the Summer on the topics of:
- age verification in premises
- remote games design - building on our earlier work on online slots, we plan to consult on similar protections for other online casino games
- direct marketing and cross-selling - we want consumers to have more control over the direct marketing they receive
- and financial risk and vulnerability checks for remote operators.
The closing date for these is 18 October and I’m pleased to say we’ve already had thousands of responses. Alongside these, we are making great strides on Gambling Act Review work that isn’t consultation reliant. For example, the GamProtect project that has grown out of the Commission’s industry challenge to deliver a holistic view of risk of harm, known as Single Customer View (SCV), is one such initiative. We have worked with Wes and his colleagues at the Betting and Gaming Council as they set up a pilot, setting the parameters for what it needs to deliver, and working with the Information Commissioner, our data protection regulator, to make sure that it was legal, data would be secure and only used to protect people from harm.
We’re now expecting a further update on the progress of this project before it is expanded to cover more operators and more consumers as a result. And we’re also finalising our new methodology for collecting Participation and Prevalence data. The Gambling Survey of Great Britain will be the largest of its kind in the world when up and running, with 20,000 respondents a year. We expect it to become the new gold standard for this type of data in Great Britain and whilst many may look to argue about the new data – in particular for problem gambling rates, we are clear that better data will lead to better regulation and better outcomes for both consumers and operators as a result.
So what is clear is that, despite being a well established and mature market, gambling regulation in Britain will not be standing still over the next few years. Our commitment to making gambling safer, fairer and crime free will continue but our regulatory approach will continue to adapt and evolve to respond to new challenges; to new innovations; to new opportunities.
Thank you for your time today. I’m looking forward to your questions. But let me finish with this point. Gambling is a global industry with global operators. No regulator – regardless of their experience or scale can be the world police for this industry. But by working together and committing to collaboration, we can make sure we each achieve the safer, fairer and crime free gambling that we want for our jurisdictions and for our consumers.
Last updated: 11 October 2023
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