Betting and Gaming horizon scanning: UK regulatory roadmap: Summer 2023 edition

The latest edition of the UK Regulatory Roadmap outlines the major upcoming and ongoing regulatory changes that will impact the gambling and gaming sector.

The long-awaited UK Gambling White Paper (High Stakes: Gambling Reform for the Digital Age) proposes a number of changes to the gambling sector. These include greater protection for players and young people, additional provisions for consumer redress, socially responsible advertising, expanded powers for the Gambling Commission (the "Commission"), and reforms to land-based gambling. A summary of the main proposals can be found here. Many of the proposals will be developed through consultation over the next 12 months. The Gambling Commission also published its advice to the government on the review of the Gambling Act 2005. It contains both recommendations to the government and the Commission's commitments. In June, the All Party Parliamentary Group on Harmful Gambling (APPG) published a White Paper Inquiry. The Inquiry will assess the proposals in the White Paper and submit recommendations for consideration during the consultation. The APPG is holding an evidence briefing to consider measures that it believes have been ignored.

They have also written a more detailed article analysing the proposals in the White Paper and considering how it may impact the industry. Mishcon's Tom Whitton and Sian Harding are also featured in the latest issue (July 2023) of International Masters of Gaming Law. You can read their full article, entitled "Gambling Law White Paper: Raising Rates for the UK Gambling Sector", here.

• Post-White Paper Consultation (Ongoing)

On 26 July 2023, DCMS announced a consultation on proposals for betting limits on online gambling games. This is the proposed introduction of betting limits on online gambling games. Four options have been presented in the consultation; namely (a) limiting the maximum bet on online slots to £2 per spin, (b) £5 per spin, (c) £10 per spin, and (d) £15 per spin. Additionally, for players aged 18 to 24, three options have been offered: (a) limiting online slot bet limits to £2 per spin, (b) limiting them to £4 per spin, or (c) subjecting them to the same rate caps as the rest of the adult population. The consultation closes on 20 September 2023.

On the same day, the European Commission published a comprehensive consultation on proposed changes to the Licence Conditions and Codes of Practice (LCCP), Remote Gaming Technology Standards and Software (RTS), and the Regulatory Commission's way of working. Some aspects of this consultation were anticipated in the White Paper:

1. Proposed changes to the level of consent required for direct marketing, calling for finer granularity of direct marketing consent for different products (treating bookmaking, casino, bingo, lottery as separate lines of business, each requiring opt-in consent) and different marketing channels (e. g. requiring opt-in consent for email marketing even though PECR does not require it).
2. Strengthening age checks on sites by requiring test buying on a wider range of sites and specifying that they must carry out age checks on customers they believe to be under 25 (current guidelines require such checks to be carried out on those they believe to be under 21).
3. Extending the rules currently applied to gambling games (regarding the speed and intensity of play) to all online games.
4. Introducing the requirement for (a) a financial vulnerability test to be carried out when a player's net profit or loss is £125 in 30 days and £500 in 365 days, and (b) a financial risk assessment to be carried out when a player's net profit or loss is £1. 000 in 24 hours and £2. 000 in 90 days.

In addition to the four topics mentioned above, the Commission's consultation also covers two topics not mentioned in the White Paper:

1. Rules on roles that require a private operator license
2. Composition and decision-making process of the European Commission's regulatory committee.

The consultation will close on 18 October 2023. The Gaming Commission said in its blog that it plans to hold a second round of consultation in late autumn on the following issues:

1. Socially responsible incentives
2. Gambling management tools

Preparatory consultations on this will start in the summer, including data collection and discussions with stakeholders.

Consultation affects relatively ambiguous topics, especially, such as cashing risk of "disgusting" checks. This consultation is an important opportunity to consider the position of services in the white paper and express anxiety. We wrote some tips for consultation.

• The Premier League restricts the bed sponsors to T-shirts (continued)

The England Premier League (EPL) announced a while ago that the club (voluntarily) agreed to remove gambling sponsors from the front of the 2025-26 season. This latest poster is conducted by the main stakeholders (EPLs, clubs, digital technologies, culture, and media, and sports) in the aggressive review of the Gambling laws of the English government. It is the result of the consultation. Please read this notebook for details about this event and its impact.

• A fresh middle for businesses that interact with third parties (2 quarters of 2023)

The committee is the expectation and regulations of the Licenser for those who are not licensed by the committee, for example, the interests of "White Label" trademarks and suppliers (see here) on their website "Middle". It explains the above direct obligations.

The center has a duty of a license to a third party, who is a contract partner, in cooperation with LCCP (see the status of 1. 1. 2 in public liability norms), and the license is a unique contract with a third party. It must be linked to a specific clause to the situation, and in effect, it is obliged to produce itself as if these third parties were linked to what recognition criteria and what kind of practical norms were followed. I remembered that it was a cover. It is also important to monitor and observe whether a third party complies with LCCP.

In a unique announcement on the development of the center, the committee warns License as follows. "We remind you of all operators in Licensei and the Committee's obligations for the gambling site marked by Snow White, and the committee carefully monitors the license to participate in these business relationships." < SPAN> Consultation affects relatively vague topics, especially, such as cashing risk of " -off" checks. This consultation is an important opportunity to consider the position of services in the white paper and express anxiety. We wrote some tips for consultation.

{space}

The Premier League restricts the bed sponsors to T-shirts (continued)

The England Premier League (EPL) announced a while ago that the club (voluntarily) agreed to remove gambling sponsors from the front of the 2025-26 season. This latest poster is conducted by the main stakeholders (EPLs, clubs, digital technologies, culture, and media, and sports) in the aggressive review of the Gambling laws of the English government. It is the result of the consultation. Please read this notebook for details about this event and its impact.

• A fresh middle for businesses that interact with third parties (2 quarters of 2023)

The committee is the expectation and regulations of the Licenser for those who are not licensed by the committee, for example, the interests of "White Label" trademarks and suppliers (see here) on their website "Middle". It explains the above direct obligations.

The center has a duty of a license to a third party, who is a contract partner, in cooperation with LCCP (see the status of 1. 1. 2 in public liability norms), and the license is a unique contract with a third party. It must be linked to a specific clause to the situation, and in effect, it is obliged to produce itself as if these third parties were linked to what recognition criteria and what kind of practical norms were followed. I remembered that it was a cover. It is also important to monitor and observe whether a third party complies with LCCP.

• {space}
• The England Premier League (EPL) announced a while ago that the club (voluntarily) agreed to remove gambling sponsors from the front of the 2025-26 season. This latest poster is conducted by the main stakeholders (EPLs, clubs, digital technologies, culture, and media, and sports) in the aggressive review of the Gambling laws of the English government. It is the result of the consultation. Please read this notebook for details about this event and its impact.
• A fresh middle for businesses that interact with third parties (2 quarters of 2023)
• The center has a duty of a license to a third party, who is a contract partner, in cooperation with LCCP (see the status of 1. 1. 2 in public liability norms), and the license is a unique contract with a third party. It must be linked to a specific clause to the situation, and it is virtually obliged to produce yourself as if these third parties were linked to what recognition criteria and what kind of practical norms were followed. I remembered that it was a cover. It is also important to monitor and observe whether a third party complies with LCCP.
• We welcome the fact that websites with a snowy white market are actually overwhelmingly more prevalent in the UK gambling market. It is noteworthy that in assessing the risk of money laundering and terrorist financing in the UK gambling industry, partners with "white signs" are incorporated into the highest risk list. The European Commission's commitment to such devices was stated in its Compliance and Enforcement Report for 2019-2020, in which it said, "There is a concern that unlicensed operators who may not have the chance to pass the initial training suitable for licensure may be tempted to apply the "white label" model to offer gambling offers in the UK." However, in its instructions to the government to review gambling laws, the European Commission concluded that the control measures to eliminate such risks are in fact sufficient.
• This Fresh Middle sells the Commission's proposals on consolidating information on advanced experiments and strengthening its own expectations for operators that enter into contracts with third parties in its instructions to the government to amend gambling laws. At least, no substantial changes in the basic commitments have occurred.

{space}

Verification and numerical gaps in the 2023-2026 phase (2nd quarter of 2023)

Having determined the need to improve access to information, research and evidence (and instructed the government to review gambling legislation), the Commission published the "Verification Gaps and Priorities" in May 2023 (see here).

The document includes the Commission's proposal to resolve this challenge for up to three years, to ensure that any settings in adaptations are based on scientifically justified circumstances. In it, six key topics were highlighted, with potential adaptations in future stages:

• Early role skills in gambling and "pass-by" products (i. e. awareness of children and young people's gaming behaviour and exploring pathways into gambling);

{space}

Range and diversity of gambling skills (awareness of how gambling fits into consumers' lives and everyday emotions);

• Harms and vulnerabilities associated with gambling (awareness of all the ways in which purchasers experience harm from gambling);
• space}The impact of operator practices on consumer behaviour;
• Product characteristics and risks (gain insight into which products are at risk of harm).
• Illegal gambling and crime (understand the link between crime and gambling, and the impact of the "black market").
• It is good that the Commission wants to ensure that significant evidence exists, and it is also good that it is in fact making its own research more widely accessible and making data sets cheaper for broader analysis.

However, the Commission is open to real-time gaps in the evidence base and observes its conclusions based on them. This suggests that the regulator is considered impeccable and that there is an opportunity to eventually rely on the "precautionary principle" (to a greater extent than may be required by unpleasant cases).

What is more worrying is that the proposed recommendations for the White Paper, due in 12-18 months (i. e. before the end of the Commission program), will likely be based on missing precedents. This may result in what is effectively a warning measure based on the White Paper, which will not be easily revisited in the future.

{Space}

Commission Secretariat Update for Cazno - Spread Funding (2nd Quarter of 2023)

• The amendments include requests to:

Space

Space}Conduct a risk assessment to identify and evaluate the risks related to the financing of distribution;

• Introduce and support politicians, procedures and controls to reduce the risks of financing distribution and control him;
• {Space}Ensure the communication of internal reports to appointed employees if one suspects or knows that a person or another person is actually participating in distribution financing.

{Space}Conduct a questionnaire survey of personnel regarding distribution financing operations.

This update includes a list of three countries (3ZA) of three countries with the highest level of risk, including renewal of funding cleaning. As before, the operator has been enhanced (based on the rules 33 (1) (b)) to reduce the risk formed in a business relationship with a person located in a third country with the highest level of risk. You must use caution (WAD) and constant prediction.

• Businesses are familiar with the risk of distributed funding in the national treasury when conducting personal evaluation of risks, and their risks in risk, politicians, procedures and research are explaining the risk of distribution funding. It is a footprint to believe the fact that it will be updated.

Businesses are at least in this state, and in order to improve their caution and certain predictions, the Supreme Riku shown in the attached document 3ZA to improve their caution and secure certain predictions. It is still required to secure cooperation between the state list and the NPC unique process. The fundamental shows that this information is integrated under risk assessment and political leaders.

{space}.

• On February 2, 2021, the Gambling Committee announced the ban on the four functions in the online slot, but the only: (A) illusion of speeding up and controlling results, ( b) The slot rotation speed is 2 or 5 seconds or more, (c) Auto games, the ability to bring some, actually those players will blur the control of your game, and (D) Sounds and graphics that create the illusion of victory when the profits are actually equal or below the bet. Other new demands include clearly for the player, for his total cost or profits and time, include an application for playback and display during the online phrase games session on October 31, 2021. I am.

In fact, it is noteworthy that the report says about the fact:

{space}