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change the industry’s financial relationship with its customers. So, you're looking at additional product restrictions and account restrictions in one way or another.


Will it achieve it? I think the buzz phrase in the government's White Paper is ‘balance’. We will see whether the balance goes too far away from the industry's legitimate right to go about its business interests but only time will tell about that. Te Gambling Commission have recently put out a press release saying they are going to embark on all sorts of evaluation processes to ensure they do meet the objectives of the White Paper.


How do you assess the balance between customer freedom and customer protection? Will the severity of the proposed curbs drive punters to the black market, or even stop them gambling entirely?


Tere are different types of punters. Tere is what you might call the general recreational punter who puts £50 on the football every weekend. I don't think they're really going to be impacted at all - or they certainly shouldn't be - by the way in which these changes will be made. I think they're looking at your higher risk customer, for example someone who can gamble a lot of money quite quickly or people who can sustain long-term losses that are unaffordable for them, with spend being a proxy for harm.


Tere's been quite a lot of focus on the black market, i.e. if you don't provide customers with what they want they're going to channel elsewhere. If you look at other jurisdictions we have a relatively liberal system. We regulate pretty much every form of gambling customers might want to do but if you look elsewhere, like France, online casino is illegal and they have a rampant black market because people want to do it. You have to provide a framework in which to do it and ultimately you want that to be a regulatory framework rather than an unlicensed framework.


'Affordability' which is an important concept in the White Paper Te word affordability itself isn't mentioned in the White Paper - which focuses on“financial vulnerability” - but it's not going to be anywhere near as severe as perhaps some commentators were looking for. It's not going to be that someone loses £100, and you start asking where that money came from.


I think there will be balance. Tere's been a lot of focus on financial vulnerability. But things like product restrictions, the way in which products are presented and designed, is also really very important. Te way they're marketed, how bonus schemes work and how they're being restricting or evolving will also have an impact. It will be interesting to see how that complete package works out over the next few years.


How closely with other international markets be looking at the effectiveness of the measures, particularly regarding the statutory levy on betting companies to fund public health initiatives, stakes limits for young adults and tighter financial affordability checks?


I generally think there are two jurisdictions I consider to be ahead of the game when it comes


P66 WIRE / PULSE / INSIGHT / REPORTS


to gambling regulation for online, in terms of their sophistication : Australia and the UK. It's always good to look at what both are doing as they are a bell weather of where things may go for other jurisdictions. You've got to remember that gambling is considered in different ways in different jurisdictions. For some, it's seen as a revenue raising exercise and for others it's something quite different.


We are still the largest regulated online gambling market in the world and the most evolved. We are now in the next phase of our online gambling regulatory framework whereas others are still introducing their first, such as the US, where there are pockets of online casino and online sports betting is very recent. If you look at some of the promotional advertising particularly in the US, I know that if you ran some of those promotions in the UK, you would almost certainly recieve enforcement action very quickly. But we approach gambling in a slightly different way to other jurisdictions. I don't know whether they're all going to ape us but what policymakers will look at in interest is the impact of these changes on our industry.


At the back of the White Paper, the government have set out what the adverse impact is going to be on the industry. It will be interesting to see whether that is right or wildly out. Te 'impact on the industry' isn't just on dividends to shareholders - it means unemployment, tax – a real implication on the broader economy.


Of course, it's all relative, but it has an impact. Tey'll all be looking at how these changes impact the financial performance of the industry. Some of the initiatives being brought in will be closely watched. If the impacts aren't so great in terms of people going to the black market or stopping gambling altogether, I think there's going to be lots of calls in a number of other jurisdictions to introduce similar initiatives.


What can other international markets be doing to prevent tighter measures being implemented? What can - and should - operators and other stakeholders be doing better?


When the 2005 Gambling Act came in, one of the things it did was in effect remove a load of restrictions on the ability to advertise gambling. Operators naturally made the most of that new freedom and one of the consequences of that is the relative ubiquity of gambling now, as well as the lifting of certain restrictions regarding licensing for betting shops which allowed them to balloon in number too. Suddenly it's there and very visible. For a number of people, they're okay with gambling per se, but don't want it rubbed in their faces or their children's faces.


I think some of the changes coming in the UK are a reaction to the industry making the most of the opportunities it was given. If there's one thing that operators in other jurisdictions should do is to think carefully about the way they use what appear to be regulatory relaxations. Try and look slightly longer term rather than short term. It's interesting to see how as other jurisdictions mature, like the US particularly, whether the issues we have experienced in the UK that have led to a whole revamp of our regulations will do the same.


“When the 2005 Gambling Act came in, one of the things it did was in effect remove a load of restrictions on the ability to advertise gambling. Operators naturally made the most of that new freedom and one of the consequences of that is the relative ubiquity of gambling now, as well as the lifting of certain restrictions


regarding licensing for betting shops which allowed them to balloon in number too. Suddenly it's there and very visible. For a number of people, they're okay with gambling per se, but don't want it rubbed in their faces or their children's faces.”


Steve Ketteley


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