Report

High Value Customer and VIP Scheme Monitoring

Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring

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Published
17 July 2025

Last updated
17 July 2025 - Changes

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Contents

• High Value Customer and VIP Scheme Monitoring

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• Executive summary
• Introduction
• Theory of change and hypotheses to test
• • Theory of Change
  • Hypothesis 1: The HVC market
  • Hypothesis 2: Controls
  • Hypothesis 3: Unintended consequences
• Methodology and limitations
• • Methodologies
  • Limitations
• Operator survey findings
• • Respondent characteristics
  • Presence and membership of schemes
  • Gross Gambling Yield (GGY) from HVC scheme members
  • Operation of HVC schemes
• Casework analysis
• Other sources of information
• Conclusions and next steps
• Appendix: Industry data request

Hypothesis 2: Controls

Operators are applying robust controls, where schemes are in place. 

The rationale and premise of the policy change, as articulated in the original consultation (opens in new tab), was that there were 4 areas of consistent concern about operators’ use of High Value Customers (HVC) or VIP schemes: 

1. Assessing and mitigating risk (knowing your customer) - Membership of a HVC or VIP scheme is conditional on robust ‘know your customer’ or due diligence checks. This had not been the case in a number of occasions. Common issues emerging from the Gambling Commission’s casework included failures to undertake appropriate initial and ongoing checks, or accepting limited or questionable source of funds evidence. Information on customer accounts had highlighted practices that aimed to increase customer spend to the exclusion of other considerations.  

2. Accountability and/or oversight of HVC teams - Dedicated teams in a number of cases were focusing on operator commercial performance, often through isolation from other functions (for example, safer gambling or anti money laundering (AML)), leading to a lack of appropriate oversight and senior accountability, and breaching of internal policies, among other things. 

3. Relationships within operators - There was evidence of unprofessional relationships between staff and customers, often leading to irresponsible, and on occasion exploitative, behaviour (for example, unsolicited engagement). 

4. Incentivisation - Incentives offered via HVC schemes in several cases exacerbated at-risk behaviour, such as accelerating spend, cross-selling to other products, and placating customers when they were distressed or disgruntled following heavy losses.  

The data exercise in 2021 provided some assurance, through self-reported information and examination of provided operator policies and procedures, that rules on HVC or VIP schemes were being applied (where schemes remained in place). The hypothesis we test therefore is the extent to which robust controls remain in place, where such schemes are offered.  

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Hypothesis 1: The HVC market Next section
Hypothesis 3: Unintended consequences

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Last updated: 17 July 2025

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