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UK LEGAL COMMENT


will of course affect any operators based in the UK who are currently relying on EU law arguments to provide services into some European markets. Anyone in that position will need to re-assess the risk of continuing to target that market. The number of markets where such arguments continue to hold weight has of course diminished in recent years as local licensing regimes have come into force.


Gambling Commission regulatory action: The Commission has a number of ongoing investigations and licence reviews, so we can expect to see further regulatory sanctions and public statements during the course of the year. A particular focus has been on white label operations and the Commission can be expected to clamp down on arrangements were unlicensed brand owners are carrying out functions such as regulatory compliance and customer interaction, which should be managed by the licensee. Work has also been taking place at the Commission in relation to the use of Non-Disclosure Agreements by operators reaching settlements with customers and the Commission’s interim guidance on this issue is expected to be fi nalised shortly.


Reporting requirements: A consultation is expected to begin in around April, on changes to reporting requirements to the Commission. This is likely to include a slight reduction to the number of key events which need to be reported, but some increased reporting requirements in relation to social responsibility matters, which may include the provision of more data in relation to customer interactions as part of regulatory returns. Responsible game design: One of the expected announcements at the Commission’s annual “Raising Standards” conference will be new provisions relating to responsible game design, which may take the form of a voluntary code or be incorporated into the LCCP. B2B providers have been working in focus groups to develop these provisions. The Raising Standards conference will take place in late March or early April.


Leaving the market: For some operators, the increasing regulation of gambling in Great Britain has meant it is no longer attractive, or possible, to remain in the market. The increase in remote gaming duty to 21% in April 2019 will also have been a key factor for some. The Commission is intending to release guidance to operators on how to close


down their licensed operations, which is surely a sign that this trend is set to continue.


Review of the Gambling Act 2005: Looking further ahead, the Conservatives promised a review of the Gambling Act 2005 in their election manifesto. This will not be the Government’s fi rst order of business in the New Year, but this may happen later in the year, or in 2021. The manifesto stated that the reviews will include “tackling issues around loot boxes and credit card misuse.” As discussed above, the use of credit cards for gambling is already being tackled by the Commission, with its proposals expected in January. A wholescale review of the Act will need to look at more than just regulating loot boxes to justify parliamentary time, but the recommendations of the All-Party Parliamentary Group on Gambling Related Harm will also need be considered. Of these, increased regulation of gambling advertising is most likely to see the light of day, with the prospect of further restrictions on advertising around sporting events. Restrictions on online slot machines may also be debated and while a £2 limit seems most unlikely to be imposed, speed of play restrictions could be brought in. There’s no doubt that the regulatory environment in


Great Britain will continue to be challenging. Compliance teams in particular will have another busy year keeping abreast of these changes and ensuring they are implemented in good time.


Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffl es, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and novel product ideas.


JANUARY 2020 33


albertocc311/Adobe Stock


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