Raising Standards for Consumers - Enforcement report 2018 to 2019

Enforcement Proceedings Report 2018-2019 Archive: This report contains information and instructions at the time of publication.

Published: 27 June 2019

Last updated: 23 May 2024

This version was created or saved: 26 August 2024

Online version: https://www. gamblingcommission. gov. uk/report/raising-standards-for-consumers-enforcement-report-2018-to-2019

Chief Executive’s message

This report is the Gambling Commission's second annual enforcement report and provides an overview of the enforcement activities carried out over the past year and lessons that operators should learn from them.

We hope that this report will be read by as many people in the gambling industry as possible. Furthermore, this report will undoubtedly provide additional instruments that the industry can apply and learn lessons from for the future.

The goal of our enforcement work is to improve the gambling industry's reputation through targeted actions that protect consumers and the general public and help operators create such a culture:

• By acting in this way, we lower the risk level for licensing purposes and reduce the harms associated with gambling.
• By taking into account the interests of our customers, treating them fairly and communicating in an understandable way so that they can make an informed decision about whether to gamble or not.
• By working openly and in a spirit of cooperation with the European Commission.
• By refraining from actions that are not in line with the letter or spirit of the normative framework established by the Commission.

While progress was made in some areas during 2018-2019, which we welcome and want to build on, there were still too many cases where we had to take tough measures to protect consumers and the public. For example, we carried out a significant number of investigations into online gaming operators. As a result of these investigations, several online casino operators and members of their senior management were subject to public liability and sanctions related to anti-money laundering violations. Enforcement action during the economic year has resulted in the imposition of £19 million in fines, the revocation of three sole proprietorship licences, the issuance of warnings to four PML licence holders and the issuance of two notices containing behavioural advice to PML licence holders.

We carried out more than 160 supervisory and criminal investigations last year, more than in any other year. We also processed 2, 000 business reports and conducted hundreds of risk-based damage assessments.

As a more proactive effort, we have been working with operators to raise standards and have held a successful programme of co-creation workshops and webinars where operators discussed a range of issues and contributed ideas, debate and solutions. We are pleased with the initial results these efforts have produced and look forward to continuing and expanding this work next year. We will also evaluate the impact of these efforts to ensure they lead to higher standards for consumers.

There is no doubt that much work remains to be done to make UK gambling fairer and safer. Our enforcement activities are an important part of the Commission's work.

Neil McArthur, CEO

Safer gambling

Introduction

We have clear expectations of operators on safe gambling and we expect them to actively work with each other to reduce and minimise harm, working together to accelerate progress and generate evidence of effectiveness.

We want to focus on 'what works' and expect operators to empower and protect consumers first.

This area of ​​regulatory oversight is broad and includes appropriately identifying and dealing with potential risks and people who may be at risk of harm, ensuring terms and conditions are clear, fair and understandable to consumers, and not targeting vulnerable or self-excluded customers. Examples include:

Social responsibility codes are included in the Licence Conditions and Codes of Practice (LCCP) and must be followed as a license condition, i. e. as a requirement to hold a licence.

From the annual 'Participation in Gambling 2018: Behaviours, Awareness and Attitudes' report, 30% of respondents believe gambling is fair and trustworthy, while 79% believe there are too many gambling options currently available. 71% believe gambling is a risk to family life. In addition, the UK's 'Gambling Behaviours' report found that ... According to the 2016 report, around 2 million adults experience at least moderate negative consequences from gambling, of which 340, 000 are classified as problem gamblers.

Our initiatives on the protection of buyers have been active in many fields. As stipulated in the 2019-2020 business plan, we can enhance the stereotype on the protection of customer rights from the industry, understand our customers, and utilize the gained knowledge to protect customers. Continue seeking to present in such a form. We will support them by sharing advanced skills and promoting collaboration through workshops, interactive events, and partnership programs.

In April 2019, we started a new national strategy to reduce gambling harm. This thre e-year strategy is to guide and coordinate initiatives to reduce harm related to gambling. For the first time, health authorities, charitable organizations, regulatory authorities, and companies will work together to work effectively. This strategy requires actions and efforts to implement two strategic priority areas: prevention and education, treatment and relief. As part of a new strategy, we will continue to take a strong approach to ensuring compliance with the law, improve surveys and evaluations on gambling harm, and spread effective solutions widely.

We previously announced instructions for industries on dialogue with customers in online gambling. These guidelines can help you identify those who can be gambling or have any danger, and to make sure that the system is reasonably reliable. Operators need to apply these guidelines to evaluate their briefcases and procedures. Operators must consider whether they are in response to our expectations or need to be more regulated.

We have also seen many cases where customers are allowed to bet in a short period of time without operators. These problems could become even more serious on weekends and nights. The issue of funding is further discussed in this topic related to both the dialogue with customers, such as the purpose of AML/CFT.

In addition to the signs of progress, there are other fields that are creating avan t-garde practice and cooperation. However, it is still possible to organize with other sections and share technology so that the welfare of the buyer is fully considered.

Our notable enforcement cases

We have taken regulatory action against a number of licensees who have failed to respond to requests for customer engagement to identify customers who are or are likely to be problem gamblers. Major public statements have subsequently been made and, in notable cases, licenses have been tested:

• RANK GROUP (Nov 2018)
• MARK JARVIS (Oct 2018)
• VIDEOSLOTS (Nov 2018)
• PADY POWER BETFAIR (Oct 2018)
• DUB ALDERNEY (Nov 2018)
• CASUMO (Nov 2018)

Case studies

VIP A casino operator that moved from brick-and-mortar to online

• Made a "contact visit" to the buyer's residential address, but was now in the self-exclusion period
• Unlike personal politicians, agreed to provide the buyer with a loan for online use.
• Did not record interactions with customers and did not use all available information when assessing whether customers had symptoms of gambling addiction.

The bookmaker, who had a long-standing customer relationship, showed symptoms of serious gambling harm and spent £34, 000 via debit card on B2 slot machines at one betting venue, of which £11, 250 was spent. Failure to meet customer engagement standards when the pounds were stolen. These failures were due to deficiencies in company policies and procedures:

• Failure to recognise who had the capacity to drive customer engagement or how challenges could be escalated.
• Failure to make effective decisions and to use all appropriate sources of information to manage and ensure effective interactions with customers. Employees knew the customer had recently suffered a dismal loss, which could have increased their vulnerability and made it difficult for them to make decisions.
• Failure to consider the possibility of identifying at-risk consumers who did not have obvious symptoms or exhibit known behaviours associated with gambling addiction. Employees were aware that the customer had stayed in the store for an extended period of time, but this did not raise any concerns and was not considered a sign of potential harm. Separately, the extent of the buyer's spending was unusual enough to warrant further investigation, but no investigation was carried out.

Online operators, Betting Exchange Control, have repeatedly identified customers with signs of gambling and have not interacted with them. Operators allow customers to bet on exchanges, and are responsible for their social responsibilities for all funds passing through the money laundering (AML) and all the funds. Similar disadvantages from customers have been confirmed in online and retail environments.

Safer gambling health check

Good practice

You need to ask yourself about the following important issues regarding dialogue with customers and identify a problematic player:

• Do you provide rules and procedures so that you can identify customers who may be gambling or dangerous? In the event of a space} problem, communicators with customers in a timely and effective way Are the resources for taking a sufficiently assigned?
• Are you interested in customers? Are you following your customers?
• Space｝ Do you record the interaction with customers and use that information for customer decisions?
• Space｝ Are you doing sufficient things to track your customers on different platforms and identify different customer accounts?
• Is there a system that identifies a potential problem player? Does the system include an appropriate and realistic trigger point (not only financial) when a normal game model becomes abnormal? How to protect new or unknown customers (if the game model is not yet in place).
• Can the process be followed by the growing demand? Does growth or aggregation affect customer management skills?
• Space｝ How do you evaluate these measures and procedures and verify their effectiveness?
• Space} Has your staff know the harmful gamblers and how to inform them of the issues that occurred? Is it clear the procedure after the problem is raised? Is the procedure for weekends or late nights?
• If a space} problem occurs, can I intervene in the situation early and establish an interaction with customers?
• Is the space｝ policy and dialogue with customers distributed?
• Space｝ Are you paying attention to the special risks of these customers? Is commercial consideration priority over customer protection?
• Did you think about how to implement the revised LCCP? Did you consider the configuration necessary for complaints from October 2019 in collaboration with management?

Anti-money laundering

Introduction

Work to secure this is still one of the main concerns so that gambling is released from atrocities and criminal interests.

We are actually waiting, Licensians is completely closely at the various guidelines we have released, observing the status of our own license regarding the funding of the ant i-money laundering (AML) and the terrorist funding (CTF). Dedicate concerns. The latest information on under/ fit obligations is regularly published on the website.

Licensei is required by aristocrats for appropriate head updates last year:

• Space} We have created five video series in collaboration with the National Crime Agency to improve our knowledge of the unjustified reporting process.
• Cas h-controlled development groups for money laundering have announced mutual evaluation results on the UK.
• We follow the advice on the Landbase and online casinos on "Fighting Money Laundering and Training Terrorism" and the "Criminal Justice Revenue Act 2002) to all other operators. Updated advice on duty and responsibility. The main purpose of these updates is that, like LED or SUSPECTS, gambling-online devices used in transactions related to money laundering are in Gibraltar and are related to SARS Operators when affecting British customers. It was to link the change.
• In the framework of coordinating revitalization of the National Center to fight financial atrocities, we conducted a series of audits for casiners throughout England. The purpose of these visits is to communicate the appointment and assistance to the casino business operator, increase the awareness of major flaws in the field of money laundering and terrorism, and also discover during the test of law and law execution. It was to identify the avan t-garde practical field.

Several operators have taken law execution measures for infringing under/ fitting. The number of visible cases is as follows:

• Casmo Service Limited (January 2018)
• DUB ALDERNEY (Nov 2018)
• Paddy Power Betfair (October 2018).

For the past few years, we have conducted important investigations in the online gambling field.

The work of confirming that the ratio and legal exempts have been demonstrated many times do not claim the actual leaders, procedures, and local businesses. All gambling regulatory authorities, whose wrong ideas are formed, are similar, and cannot control our instructions and implement the legislation requests applied in England. This is not a matter of regulation, but a rudimentary thing about violating the English law, so the situation must change. Those who cannot learn these lessons face the dragon's measures afterwards.

We are integrated into operating systems and faced excessive dependence on threshold tasks intended to steer for experts. However, although they seem to be conceptually logical, they are very common i n-house skills and paid, based on actual access to risk profiles and customers. do not have. Operators do not have time to participate when gambling is untouched in a short period of time, for example, to register the method obtained in a criminal way toward lon g-term time.

This year's report provided help information so that operators had the opportunity to show their personal adjustments on the threshold and accessibility issues.

We continue to monitor cases that are not good for compliment, such as some businesses that are more integrated between teams that are responsible for funding and public explanations. It is encouraging other businesses to have the opportunity to introduce such cooperation into their existing practices.

We are also stimulated by the great deals of some businesses on customer profiling systems and methods. AML is a field that can benefit both businesses and customers with the cooperation and evaluation between business operators.

There are many times when the operator does not provide important staff, and it will be aware of how many employees report about money laundering, how to operate and have other effects. There is a possibility of holding constant research, white funds and terrorism funds on whether you can.

Risk of money laundering and terrorist funding, politics, procedures and management, profiling of customer risks, customer care, current predictions, intensive customer testimony, and intensive current predictions. We are still excited about the contradiction. For many operators, all of them were reborn as "ticks" without knowing the importance of ris k-based conditions.

We continue to impose more and more strict financial fines (or payments in exchange for cash fines), in order to provide a clear sign in the industry.

Case studies

This year, we conducted a survey of many online casiners who were convicted of our own license for under and public responsibilities. As a result, fines, warnings and licenses were imposed.

Our survey was shown by multiple violations by compliance with AML-politicians, risk assessments, and money laundering:

• Space} did not implement the following immutable predictions in business.
• In the atmosphere that suggests the exaggeration of the risk of money laundering itself, we used sufficient measures to enhance customer bunting-screening and strengthen the forecast forecast, taking into account risks.
• Store the evidence and the absolute record of the confirmation documents that are considered as part of a tradin g-related test with the buyer's priority and the buyer.
• To prevent business related to money laundering and terrorism funding, the following is developed and maintained, taking into account the dangers of politicians and procedures related to specific problems.
• Ensure the appropriate study of the appropriate personnel for recognizing, how to recognize, how to do it, and how to do it, and how to do it, and how to do it, and how to do it. thing.

During the investigation, a license was attached to the license on November 1, 2014, and the license conditions were 12. 1. 2. 1-Measures to fight money laundering for business operators located in foreign laws. All o n-line licenses are rarely recommended to confirm and master these requests.

Anti-money laundering health check

Good practice

In the direction of this year, we announced a recommendation to the business operator under the name of a public statement. In order to believe in complying with your own license, it is a footprint to deal with concerns about gaining it on the right:

• Are you assigning enough resources to secure the ratio of AML claims?
• Sora｝ Are you sure you have a different, burning, or managing method for everyone who needs management, in terms of cheap, underlying, underlying, and managing?
• Sora｝ Are you convinced that your politicians, procedures, and management methods provide our instructions to Under? Do you really want to meet the requests of the European Commission if you meet the requests on AML from other regulatory authorities?
• Has your evaluation on the risk of money loaneding and terrorism funding reflected in your work? Did you provide the risk assessment of the committee's money laundering and terrorist funding and the highest risk moment in our leadership?
• Space｝ Are your politicians, procedures, and dangerous management measures discovered during the risk of money laundering and terrorism? Are they being reviewed when the risk changes?
• Space｝ Is the risk of money laundering and terrorism raising? Are you really looking for a currency threshold as a resort or other risk point?
• Space｝ Is the penetration of scoring on a specific buyer determined in consideration of the risk profile of the buyer? Are you checking the editing of the relationship with the customer risk profile?
• Space} Are you convinced that employees are conducting the following surveys on under/ fat operations and are continuing to leak? What is it?
• Do you provide employees with appropriate resources and training and have the ability to work fairly and voluntarily?
• Is there a system or method for managing the work}?
• Space｝ Do you regularly evaluate the appropriateness and performance of your company's sithetem and management device to reduce the risk of money launding and terrorism?
• Space｝ Do you know your buyer (KYC)? Do you understand the overall understanding of buyers' funding sources, especially VIP customers? Are you critically evaluating the acquisition of customer funding?
• Do you have the buyer testify about the family structure of the class at the time of registration and evaluate your profits depending on whether it is easy to access?
• Space} If necessary, do you record customer support and transactions?
• Is the Space} reco n-sile regulated by risk? Is there any procedure that can talk timely if you give space} anxiety? Space} Is the conclusion recorded as follows?
• Did you confirm that the fact that there is no paid opinion is compatible with the license standard?
• Is the hazard accepted at the appropriate level in the organization?

Marketing and advertising

Introduction

At the beginning of the year, our efforts on compliance and compliance in this field have led to improvements in attitudes, but many businesses are still a lot to ensure transparency and public explanation in advertising communication. Must be done.

LCCP calls business operators to sell gaming products in a socially responsible manner and comply with all related clause in the CAP code and BCAP code (British advertising code). We are concerned that some businesses continue to advertise inappropriately, so we will take forced measures for misleading advertisers to a business. I got to

We work closely with regulatory partners such as advertising standards (ASA) (opened in new tabs) and competitive market (cma) (opened in new tabs) so that advertising promotion does not deceive consumers. In 2018, CMA announced an executive findings for several businesses in connection with online promotion. They basically, if the status is important in bonus promotional advertising, or if the conditions and situations related to bonus promotion are unclear, there are any opportunities that businesses do not comply with the Consumer Rights Protection Law. I emphasized that there was. We have revealed that all businesses will take measures to make advertising materials compliant with the CM A-defined framework, and to find out how these changes are being implemented. ・ The test was conducted.

In October 2018, we added a configuration to LCCP to increase the number of applications in major fields. We incorporate compliance with English marketing code into public responsibilities, and that businesses that violate any nuances of the code can be a total range of our regulatory options, including fine. We clarify in the requirements that the marketing of the service must be clear and should not be misunderstood for the buyer, and the business operators have a direct mail of electric advertising without the consent of the buyer. A new statement to guarantee not to send has been added. Businesses have also introduced changes to clarify our agreements to be responsible for the effects of their three people, including advertising partners. < SPAN> At the beginning of the year, our efforts on compliance and compliance in this field have led to improvement of attitudes, but businesses have yet to ensure transparency and public explanation in their advertising communication. You need to do a lot.

LCCP calls business operators to sell gaming products in a socially responsible manner and comply with all related clause in the CAP code and BCAP code (British advertising code). We are concerned that some businesses continue to advertise inappropriately, so we will take forced measures for misleading advertisements to some businesses. I got to

We work closely with regulatory partners such as advertising standards (ASA) (opened in new tabs) and competitive market (cma) (opened in new tabs) so that advertising promotion does not deceive consumers. In 2018, CMA announced an executive findings for several businesses in connection with online promotion. They basically, if the status is important in bonus promotional advertising, or if the conditions and situations related to bonus promotion are unclear, there are any opportunities that businesses do not comply with the Consumer Rights Protection Law. I emphasized that there was. We have revealed that all businesses will take measures to make advertising materials compliant with the CM A-defined framework, and to find out how these changes are being implemented. ・ The test was conducted.

• LCCP calls business operators to sell gaming products in a socially responsible manner and comply with all related clause in the CAP code and BCAP code (British advertising code). We are concerned that some businesses continue to advertise inappropriately, so we will take forced measures for misleading advertisers to a business. I got to
• In October 2018, we added a configuration to LCCP to increase the number of applications in major fields. We incorporate compliance with English marketing code into public responsibilities, and that businesses that violate any nuances of the code can be a total range of our regulatory options, including fine. We clarify in the requirements that the marketing of the service must be clear and should not be misunderstood for the buyer, and the business operators have a direct mail of electric advertising without the consent of the buyer. A new statement to guarantee not to send has been added. Businesses have also introduced changes to clarify our agreements to be responsible for the effects of their three people, including advertising partners.

Case studies

Leo Vegas May 2018

We are concerned that the operator does not pay enough attention to the images and words used to advertise gambling products, and are unlikely to appeal to children. In cooperation with the ASA, we have advised businesses and the British professional soccer league so that gambling ads and sponsor links are not displayed on children's soccer websites. For example, a club website section for youth.

• {Rust}
• {Ruit}

A new guide about gambling (open on a new tab).

Between April 2017 and January 2018, LeoVegas or its subsidiary posted 41 ads on the site, of which

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• credit

10 presented the information required to perform informed decisions in an unclear way and deceived consumers. 3.

This does not meet the requirements of social liability standards 5. 1. 7 (2) and 5. 1. 7 (2) (a):

• especially

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• In addition, 1. 2 (1) (a) is as follows:
• Quoted
• There was space for these cases:

rumor

• {rumor}
• {Please note}.
• LeoVegas has accepted the precedents of breaching these claims and has made changes and improvements to its processes and procedures to eliminate these breaches. These include:
• Reviewing and revising all policies and procedures regarding compliance with advertising claims to ensure consistency.
• Hiring advertising compliance officers in the legal and partnerships teams.
• Advertising staff learning program including CAP standards
• Marketing approval as part of the ratio certification process
• Actively seek CAP consultations where necessary
• Limit the number of affiliates and exclude email or SMS messages.
• Improve processes for partner attraction, violations and termination

{RUCE}

Marketing and advertising health check

Good practice

Review rules and standards for working with partners

• RUCE}Train partners in keeping promises with the support of information programs and management
• Conduct ratio audits of departments to identify and eliminate problems detected.
• We recommend that you consider the following:
• Do your advertising and marketing materials comply with the CAP and BCAP codes, license conditions, norms and practices? If in doubt, do you take advantage of the advice on copying provided by the CAP Group? Have you verified that CAP and BCAP publish on the ASA Council website the standards you must maintain to ensure compliance?
• Is your marketing message clear and fair? Do your advertising communications contain important limitations or qualifications that consumer aristocrats should be aware of?

Illegal gambling

Credibility

Do you manage your marketing materials after attracting affiliates? Are you confident in the reliability of your affiliate contract terms? Do you regularly audit your affiliates' activities to meet your compliance policies?

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Do you allocate sufficient resources to ensure marketing and advertising compliance?

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space} Is marketing and advertising held accountable at the right level in your organisation?

The most important part of our law enforcement activities is exercising our powers to initiate criminal cases and conduct criminal investigations if there is a fear of a crime under the Gambling Act 2005 (opens in a new tab). By law, we have a duty to prevent crimes related to gambling.

We adopt a tiered approach towards suspected criminal activity. If we suspect that an individual or company is engaging in unlawful communications with UK consumers, we first set requirements to stop their activity. If these requirements are not met, we take more aggressive action, which may lead to the initiation of a formal criminal investigation. After a criminal case is initiated, we have wide investigative powers at our disposal.

Affordability

We will continue to communicate with UK consumers and use suppression methods, where necessary, for unlicensed online operators that do not comply with our suspension notices. Our methods include blocking unlicensed operators from interacting with UK consumers through hosting sites, payments and connections to social networks.

This year, we have blocked 31 external operations by unlicensed operators, which is a lower number than in previous years.

• We are serious about stopping gambling offered to children and continue to stop the activities of those offering illegal products, such as gambling with skins, to UK consumers and young people. In cases where suspension letters do not lead to the closure of websites or pages on social networks, swift operational measures are taken.
• Separately, we work with the police and local authorities to investigate cases of illegal gambling, for example in hippodromes in pubs. We also fight against illegal stocking of slot machines and unauthorized advertising.

In recent years, our law enforcement teams have seen many cases where people are harming themselves with gambling, but they continue to do so without effective intervention. Some of these people funded their own gambling by illegally allocating monetary funds from companies, taking very difficult loans or illegally using vulnerable members of society. The aggregate of all these cases was an ineffective monitoring system used by operators to identify and manage risks.

There is data from public sources with every opportunity to suggest to operators that they should consider the availability of loans to their large customer base and to better assess the risks and measures to affect them. According to the Office for National Statistics, Annual Survey of Hours and Earnings: 2017 Preliminary and 2016 revision results:

Monthly personal disposable income

{space}	Section 4 - In April 2017, the median weekly gross earnings of workers in absolute employment in England was £550.	{space}.	Section 11 - In April 2017, the professional groups with the highest median weekly earnings of workers in absolute proletarian Denek included managers, directors and adult civil servants, at £824 per week.	Based on the above, 50% of workers in absolute employment in England receive a gross job of at least £29, 000 per year, and 50% of managers, directors and senior civil servants in absolute employment in England receive a gross job of at least £43, 000 per year. These figures incorporate income tax, national insurance contributions and living expenses such as, but not limited to, data, mortgage or rent payments, mobile association agreements, tariffs, food and energy bills.	The Yougov1 survey asked a representative sample of people across the state how much they have left to spend each month on their "discretionary income", i. e. after tax (including council tax), housing, utilities and food costs. Data was collected over a 52-month period from June 2018 to June 2019. All members of the selective survey are residents of England aged 18 or over. Below are the results broken down by age:
Monthly income	7%	6%	7%	9%	6%
18-24	25-34	35-44	45-54	55+	45-54
Less than £125	24%	35-44	21%	23%	23%
£125 - £249	15%	18%	21%	23%	16%
£250 - £499	6%	13%	9%	8%	7%
19%	4%	6%	5%	4%	4%
17%	2%	4%	4%	3%	3%
16%	1%	2%	2%	1%	1%
14%	2%	3%	3%	3%	4%

10%

£750 - £999

£1, 000 to £1, 249

£1, 250 - £1, 449

£1, 500+

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According to data from each age group, the British citizens have disposable income from £ 125 to 499. This is equivalent to less than 1. 500 pounds per year and less than 6. 000 pounds. However, these disposable income figures include automobile transportation expenses, fuel expenses, monthly contract (mobile phones, cars, life insurance, etc.), car contents (maintenance, repair, maintenance), clothing, and surroundings. There is no unavoidable expense, such as taking care of this.

Disposable income data defines several benchmarks required to predict a social responsibility (SR) trigger that helps detect gambling harm. SR triggers should be set to this level to track most of the custome r-based basis based on information from the information sources that are generally available.

• Without the introduction of a system based on this data, the operator has the risk of not being unable to know whether the customer is spending the required amount or the funding from the legal source.
• In fact, not all business models are similar, and we argue that there are customers with different income and disposable income. However, we hope that our businesses can prove this, fully reflect the customer's basis, and build a system to provide. < SPAN> According to data from each age group, the British citizens' disposable income is £ 125 to £ 499. This is equivalent to less than 1. 500 pounds per year and less than 6. 000 pounds. However, these disposable income figures include automobile transportation expenses, fuel expenses, monthly contract (mobile phones, cars, life insurance, etc.), car contents (maintenance, repair, maintenance), clothing, and surroundings. There is no unavoidable expense, such as taking care of this.
• Today, there is almost no evidence that the gambler disposable income is higher than the general public, and if you waste your personal disposable income in the entire gambling, you will feel most harmful. Control triggers should be the starting point of dialogue with customers, and not to decisively confirm that customers are suffering from gambling harm, but operators are about their customers and their play. It helps to identify cases where you need to know more.
• In some cases, in order to reduce the risk of CP and money laundering, the check is not necessary, and there is an operator that does not provide the prediction of the currency method that is resigned and r e-entered into the account. I'm doing it. According to our survey, this task is related to SR duties, and if a person embezzles money, the second paid money is considered the latest embezzlement crime. The operator will investigate this problem and take a confirmation to confirm that it is not.

In fact, not all business models are similar, and we argue that there are customers with different income and disposable income. However, we hope that our businesses can prove this, fully reflect the customer's basis, and build a system to provide. According to data from each age group, the British citizens have disposable income from £ 125 to 499. This is equivalent to less than 1. 500 pounds per year and less than 6. 000 pounds. However, these disposable income figures include automobile transportation expenses, fuel expenses, monthly contract (mobile phones, cars, life insurance, etc.), car contents (maintenance, repair, maintenance), clothing, and surroundings. There is no unavoidable expense, such as taking care of this.

Disposable income data defines several benchmarks required to predict a social responsibility (SR) trigger that helps detect gambling harm. SR triggers should be set to this level to track most of the custome r-based basis based on information from the information sources that are generally available.

Today, there is almost no evidence that the gambler disposable income is higher than the general public, and if you waste your personal disposable income in the entire gambling, you will feel most harmful. Control triggers should be the starting point of dialogue with customers, and not to decisively confirm that customers are suffering from gambling harm, but operators are about their customers and their play. It helps to identify cases where you need to know more.

Compliance

Introduction

Without the introduction of a system based on this data, the operator has the risk of not being unable to know whether the customer is spending the required amount or the funding from the legal source.

We use a number of tools to carry out compliance work. These include:

Corporate evaluation

In some cases, in order to reduce the risk of CP and money laundering, the check is not necessary, and there is an operator that does not provide the prediction of the currency method that is resigned and r e-entered into the account. I'm doing it. According to our survey, this task is related to SR duties, and if a person embezzles money, the second paid money is considered the latest embezzlement crime. The operator will investigate this problem and take a confirmation to confirm that it is not.

Targeted assessment

In fact, not all business models are similar, and we argue that there are customers with different income and disposable income. However, we hope that our businesses can prove this, fully reflect the customer's basis, and build a system to provide.

Thematic assessment

For example, in order to evaluate the use of services for the wealthy, businesses have been checked for financial statements and / or real estate ownership of companies owning housing. The subsequent trigger for customers was set to the level of the company's amount, the total value of the company's net assets and the value of the property. Operators who adopt this method often could not identify gambling addiction indicators.

Security audits

In some examples, financial statements were displayed, and the following views were shown:

Assurance statements

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Workshops

Space｝ Company reports were reduced, so it was hardly contained as an independent document to justify the selected trigger level.

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Space reports were unofficial, including the risk of no serious distortion.

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• When a business operator sets a specific trigger for a customer base that does not represent the entire population, it has to rely on various sources, but it is enough to justify the level of the set trigger. Information must be included.
• 1 The data was extracted from Yougov's profile survey, and the investigation participants are all 18-year-olds of glutors-Briten residents. The question was made from June 2018 to June 2019.

This section summarizes activities to confirm the compliance with regulatory requirements for this year. The positive experience confirmed during the review and the "verification of compliance" for operators based on areas that require improvement are summarized. < SPAN> For example, in order to evaluate the possibility of the use of services for the wealthy, the business operator has been checked by the financial statements and / or real estate ownership of the company owning a house. The subsequent trigger for customers was set to the level of the company's amount, the total value of the company's net assets and the value of the property. Operators who adopt this method often could not identify gambling addiction indicators.

An example of how we work

In some examples, financial statements were displayed, and the following views were shown:

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Space｝ Company reports were reduced, so it was hardly contained as an independent document to justify the selected trigger level.

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Space reports were unofficial, including the risk of no serious distortion.

Compliance health check

Your staff:

• Space｝ The company had low cash levels and most of the net assets were related to fixed assets, so there was no fluid asset to support the cost levels set by businesses.
• The information on the company's revenue was limited, and there was no certificate of salary or dividend. When such information was obtained, the tax burden on the customer due to drawings, personal situations, living expenses, etc. was not taken into account.
• In conclusion, it is recommended that business operators consider the level of customer base and disposable income as the starting point for reviewing the trigger system and setting a reference trigger. By doing so, the vulnerable customers can be identified quickly and respond appropriately.
• This section summarizes activities to confirm the compliance with regulatory requirements for this year. The positive experience confirmed during the review and the "verification of compliance" for operators based on areas that require improvement are summarized. For example, in order to evaluate the use of services for the wealthy, businesses have been checked for financial statements and / or real estate ownership of companies owning housing. The subsequent trigger for customers was set to the level of the company's amount, the total value of the company's net assets and the value of the property. Operators who adopt this method often could not identify gambling addiction indicators.
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Your customers:

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• When a business operator sets a specific trigger for a customer base that does not represent the entire population, it has to rely on various sources, but it is enough to justify the level of the set trigger. Information must be included.
• 1 The data was extracted from Yougov's profile survey, and the investigation participants are all 18-year-olds of glutors-Briten residents. The question was made from June 2018 to June 2019.
• This is an absolute evaluation of operators' operations that covers governance, risk management, audit, and regulatory requirements, and is a comprehensive test of consistency with the harmless gambling and AML of the operator.
• If a new theme is identified, we will select a business group and conduct evaluations by theme by theme.
• Every year, we call on larg e-scale businesses to evaluate the interior of the LCCP and licensed goals to the extent to which the risks are managed in an introspection. Based on this, we identify advanced skills and points to be improved, and share them with other businesses. In addition, the value of evaluation work is defined using the exemption.
• From 2018 to 2019, we conducted a ratio of about 1. 200, including group evaluation, motivation evaluation, and safety audits. The largest land bass and online operators and almost all small operators participated in these assessments.
• The main role of our compliance team is to examine and evaluate whether the operator is applying for a license. If you don't think the operator is doing anything, we can:

Third parties:

• Cooperate with businesses and make them comply
• Formulate an action plan and keep the business agreed.