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Raising Standards for consumers - Compliance and Enforcement report 2020 to 2021

The Gambling Commission's report on Compliance and Enforcement action 2020 to 2021

Guidance and lessons learned

The Commission publishes formal guidance and advice which operators are required to take into account when ensuring they are compliant with the LCCP requirements. During the first lockdown, we issued additional guidance to remote operators on how to meet Social responsibility code 3.4.1 on customer interaction: Gambling Commission instructs tighter measures to protect consumers.

We then conducted a consultation on further amendments to Social responsibility code 3.4.1 and associated guidance: Remote customer interaction - Consultation and Call for Evidence (opens in new tab).

We will shortly be publishing the response to this consultation and updating the LCCP requirements. At that stage, all of the Commission’s formal guidance for remote operators on customer interaction will be updated and consolidated into one formal guidance document.

The Commission has also released publications setting out further information about problem gambling, reducing the risk of gambling-related harms and the steps the Commission is taking to improve standards:

This year also saw the misuse of the Government Priority Scheme by gambling consumers, through fraudulent use of Bounce Back Loans and Self-Employment Income Support Scheme explicitly for use on online gambling. Key indicators of this risk were identified and shared through the Commission’s emerging risk bulletins, highlighting particularly the risk of problem gambling and financial crime being co-dependent issues. It was expected that businesses would consider publications made by the Commission during this reporting period and mitigate these emerging risks through the review and amendment of their risk assessment, policies, procedures, controls, and employee training to increase consumer protection and reduce money laundering within gambling.

In October 2020 the Commission introduced new Licence Conditions for AML and CTF:

  • Licence condition 15.1.3 – Reporting suspicion of offences (All non-remote casino, non-remote bingo, general betting, adult gaming centre, family entertainment centre and remote betting intermediary (trading rooms only) licences)
  • Licence condition 15.2.3 – Other reportable events (All non-remote and remote casino operating licences)

The Commission also amended the following Licence Conditions:

Review of the impact and effectiveness of these new and amended Licence Conditions and how well the industry has embedded them into their day-to-day practices will be a future focus for the Commission.

All the above highlights the need for operators to:

  • apply a risk-based approach
  • to conduct robust due diligence and enhanced due diligence checks;
  • ensure that their ML/TF risk assessment along with their policies, procedures and controls sufficiently mitigate the risk of ML and TF
  • ensure that they are compliant with and stay up to date on customer interaction requirements, and that they take account of the current formal guidance for their sector
  • deliver robust and up to date employee training.
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