UK LEGAL
Next steps for financial risk assessments
The Gambling Commission has published a progress update on its financial risk assessments pilot, which has been running since August 2024. Northridge Law’s Melanie Ellis reports.
F
or remote operators, financial risk assessments will sit alongside the light-touch financial vulnerability checks and the three stage customer interaction process (identify, act, evaluate). Non-remote operators will continue, for now, to be governed by the premises-based customer interaction process (identify, interact, evaluate). Financial risk assessments are intended to apply to customers with higher loss levels. The final figures are yet to be confirmed, but the Commission’s original proposals, in its consultation response of 1 May 2024, was to use triggers of losses (deposits minus withdrawals) greater than £1,000 within a rolling 24-hour period or £2,000 within a rolling 90 day period, with lower triggers for customers aged under 25.
The Commission has explained that financial 14 JUNE 2025
risk assessments are not affordability checks, rather they are intended to be “a more targeted approach to identifying financial risk and difficulties”. As with the existing financial vulnerability checks, once these new checks are live operators will likely be expected to consider the information obtained alongside everything else they know about the customer and take proportionate action if financial risk is identified. The financial risk assessments pilot has involved operators in the highest three fee band categories, as well as operators in lower fee categories who chose to take part. During the pilot, operators sought financial risk assessments from credit reference agencies for any customer meeting the thresholds and reported their findings to the Commission, however operators did not act on the findings. A key point for the pilot was to assess
whether these checks could be completed in a frictionless way. On this, the findings are positive, with 97% of assessments being completed in a frictionless manner in stage 2 of the pilot. This means that 3% of assessments could not be completed, i.e. the credit reference agency was not able to provide information on the customer. Using the originally proposed thresholds, this would translate to 0.1% of customer accounts requiring a financial risk assessment, but the operator not being able to complete that in a frictionless way – these customers would likely need to be asked to provide documentary evidence. The Commission’s blog post on stage 2 of the pilot reveals a potential challenge when it comes to operators making decisions on the basis of financial risk assessment data. Operators involved in the pilot have found not
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72
