Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Operation of HVC schemes
The data request included questions on operators’ self-reported compliance with High Value Customer (HVC) or VIP scheme rules and guidance. These questions were repeated from the data request in 2021. A summary of the responses follows. The Gambling Commission compliance team have reviewed the data returned by operators and have not identified any significant concerns regarding compliance that require further action.
Policies and Procedures
Where operators had an HVC or VIP scheme currently in place (n=18), every operator reported they had a policy or procedures document governing the operation of their schemes. Similarly, all 18 operators reported their business had a Senior Executive (Personal Management Licence (PML) Holder) appointed to oversee and be held accountable for the operation of HVC schemes.
Financial risk
Operators were asked to outline how they can have confidence that customers are not subject to significantly higher levels of financial risk due to their membership of the scheme. All but 2 respondents reported conducting an enhanced application or onboarding process. Many noted that this included a financial vulnerability check, or assessment of a customer’s personal financial information. Many noted that ‘Know Your Customer’ checks were completed more periodically for HVC customers.
In addition, further measures were put in place by some operators to mitigate the risk, including operator-imposed deposit limits, loss limits, and daily and weekly financial 'backstop' limits. One operator noted benchmarking financial data against national statistics to generate and apply personalised thresholds while 2 operators reported the use of algorithms to detect changes in play intensity.
Assessment of gambling-harm
Around three-fifths of respondents said they monitored additional markers of harm over and above those established for all of their customers. Typically, a customer triggering markers of harm is managed by manual review by Safer Gambling or Due Diligence teams and in some cases the PML holder or steering committee. One operator assesses activity against imposed account limits.
Previously self-excluded customers
Operators noted historic data is available to check for previous self-exclusions and this is usually done as part of the onboarding processes. This is often done alongside checks against GamStop and SENSE. A number of operators noted the level of sign off (by the PML, or other executive) needed to admit a customer with a previous self-exclusion including comprehensive record keeping, though not all operators reported having this process.
Ensuring up to date information is kept
The majority of operators reported quarterly reviews of ‘Know Your Customer’ checks, with others reporting an annual frequency. Other triggers and manual review processes were in place for some operators which meant information could be more regularly updated.
Record keeping
Operators explained their data retention processes, which often included detailed HVC profiles and systems recording aggregated data. More detailed responses outlined the types of data held about their scheme members, which included details of the assessment process, the outcomes of regular reviews, incentives offered, and decision-making records.
Managing commercial conflicts of interest
In many cases, operators told us that safer gambling teams often held responsibilities or relationships with HVCs. There were also governance structures designed to ensure wider non-commercial interests were represented in decision-making. Some mentioned that staff were not incentivised in terms of HVC schemes. Not all operators provided a response about managing commercial conflicts of interest.
Use of affiliates
The majority of operators told us they didn’t use affiliates or ‘introducers’ in promoting their HVC scheme. Where this arrangement was in place, controls included internal compliance reviews, third party monitoring, and strict adherence to affiliate terms and conditions. Where introducers are used, in one operator, this is subject to senior vetting and approval. Another notes that files are maintained for introducers and regularly monitored.
Incentivisation of staff
While some operators have targets and incentives for staff in relation to growth of customers, these are not linked to HVC or VIP scheme expenditure; the majority report no incentivisation of staff. Of the 2 operators that directly incentivise staff in relation to HVC or VIP schemes, one qualified this by stating incentivisation is done on a growth per quarter basis, and the other stated that incentivisation is on the basis of membership only and not related to spend.
Unintended consequences
The majority of respondents were not aware of any unintended consequences as a result of the change in policy. 4 operators noted some displacement away from their business, including a potential shift to the illegal market. Reportedly, this was not solely attributable to the policy change around HVC or VIP schemes. One operator mentioned the potential for gambling affiliates targeting high value customers to shift their focus to begin promoting the illegal market as a result of the new regulations.
Previous sectionGross Gambling Yield (GGY) from HVC scheme members
Last updated: 17 July 2025
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