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Raising Standards for Consumers - Enforcement report 2018 to 2019

The enforcement report for 2018 to 2019. Archived: Report represents information and guidance valid at the time of publication.

Case studies

A casino operator who had onboarded a VIP from its land-based operations to its online:

  • conducted a ‘keep in contact visit’ at the customer’s home address whilst they were in a period of self-exclusion
  • made arrangements for the provision of credit to the customer for use online, contrary to its own policies
  • failed to record customer interactions and make use of all available information when assessing whether the customer was showing signs of problem gambling.

A bookmaker who had a long-term relationship with a customer failed to follow customer interaction codes when that customer showed signs of experiencing serious harms from gambling and spent £34,000 through debit cards on B2 gaming machines in one betting shop, of which £11,250 was stolen. These failings flowed from the following flaws in its policies and procedures:

  • failure to identify who may initiate customer interaction or set out how concerns may be escalated
  • no reference to making use of all relevant sources of information to ensure effective decision making, and to guide and deliver effective customer interactions. Staff were aware that the customer was recently bereaved, which can lead to increased vulnerability and impaired decision making
  • failing to include provision to identify at risk customers who may not be displaying obvious signs of, or overt behaviour associated with, problem gambling. Staff were aware of lengthy periods of time spent by the customer in the premises, but this did not raise concerns and was not considered a sign of potential harm. In addition, the customer’s level of spend was sufficiently unusual to warrant further investigation but this did not take place.

An online operator running a betting exchange failed to identify and interact with customers showing signs of problem gambling on numerous occasions. Any operator who offers customers the opportunity to bet on an exchange is liable in respect of both anti-money laundering (AML) and social responsibility provisions for all money through the exchange. Similar customer interaction failings were identified in its online and retail environments.

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