UK LEGAL COMMENT
2020 – A Year of Challenges
Northridge Law’s Melanie Ellis looks back at a year that will live long in the memory – and forward, to the Gambling Act review
T 30 JANUARY 2020
his time last year, I predicted that UK gambling operators’ compliance teams would have a challenging year keeping abreast of upcoming regulatory changes. This has proved to be accurate, although the impact of these
regulatory changes was somewhat trumped by the impact of the pandemic, particularly for land-based operators. January 2020 saw the introduction of additional AML
requirements due to the implementation of the 5th Anti Money Laundering Directive. This included more prescriptive requirements for EDD on customers from high-risk countries and a requirement to conduct a risk assessment before launching any new product. It was also announced that, as of 31 March, all remote operators would be required to participate in GAMSTOP.
This was an important milestone, placing all UK remote operators on a similar footing, as well as protecting customers who sought to exclude themselves from all remote gambling.
In April, the ban on credit cards being used for remote gambling came into effect. The ban also meant operators could not accept deposits from e-wallets, unless the provider could demonstrate that the account had not been funded using a credit card. In June, the Gambling Commission clarified that this meant operators needed to reject all payments from money services businesses that has not developed a block to prevent credit card deposits being used to fund gambling accounts. After reviewing data on the impact of the first national lockdown on gambling behaviours, in May the
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