UK LEGAL COMMENT
The UK Gambling Commission has set out new rules for its Licence Conditions and Codes of Practice. Northridge Law’s Melanie Ellis looks under the bonnet…
New LCCP rules for customer interaction
T
he British Gambling Commission has finally issued a response to its Customer Interaction consultation and call for evidence. The time taken to respond may be partly explained by the volume of responses received – 971 to the consultation
and call for evidence and 12,125 responses to a supplementary short survey. The key outcomes at this stage are that the GC will, on 12
September 2022, bring in stronger and more prescriptive requirements for online operators to identify and interact with at risk customers (via a new Social Responsibility Code Provision 3.4.3) and in “early June” it will publish new customer interaction guidance for remote operators. Non-remote operators will continue to be subject to the
existing Social Responsibility Code Provision 3.4.1 on customer interaction and associated guidance.
No affordability guidance yet
A further consultation exercise will be conducted to determine specific steps operators will need to take in relation to preventing unaffordable gambling and identifying
consumers who are financially vulnerable. The GC intends to “work closely with the Government to ensure that the consultation proposals are set in the wider context of the Government’s Review of the Gambling Act 2005”. This means operators must continue to wait to receive more
detailed guidance on the requirements for affordability assessments, including at what spend level they must be conducted and what form they must take.
Identifying customers at risk
To assist operators in identifying customers at risk from harm, the GC has specified a set of core indicators: • customer spend • patterns of spend • time spent gambling • gambling behaviour indicators • customer-led contact
• use of gambling management tools • account indicators
The GC flags that “time spent gambling” has been added to the list, as compared to the previous guidance. Interestingly, this
30 MAY 2022
Tomasz Zajda/Adobe Stock
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