Stricter UKGC guidelines and recent enforcement have raised a conundrum for many operators as to how to make good decisions in the suddenly heightened compliance environment.
Protection of Youth First
Based on open public consultation, the measures start with new more stringent operator guidelines for rapid verification of customer age and identity details.
The Old System
The protective measures prioritise youth: until now online gambling businesses had been allowed 72 hours to carry out age verification checks, with no withdrawals permitted until completion of age verification; in instances where the individual did not pass minimum age guidelines, the operator was required to return stakes to said individual.
New Age Check Guidelines
Now, the new more stringent safeguard against children gambling calls for operators to verify customer age before the customer can deposit funds into an account or gamble with the licensee either with their own money or free bets or bonuses, plus customers must be age-verified on licensee websites before accessing free demo versions of gambling games on operator sites.
The heightened protections also increase the ability of the UKGC and operators to identify those who attempt to gamble after self-exclusion: customers will not be verified for nor permitted to play until they provide correct details, which will be checked against both the operator’s own self-exclusion database and the verified data held by national self-exclusion mechanism Gamstop.
UKGC Requires Accountability
The procedures reflect the UKGC's overall heightened commitment towards protection, and the increasing onus on operators to implement and maintain ethical behavior across the board in order to maintain what amounts to per-emptively compliant behavior.
All members of society young and old need to be protected from aggressive outreach preying on their vulnerability to addiction, and operators are being held more accountable: this is the deeper message of the UKGC in the ongoing updates to policy being issued to licensees as directives.
UKGC Leaders Speak on Measures
The measures were lauded by UKGC Chief Executive Neil MacArthur “to protect children and the vulnerable from gambling-related harm, and reduce the risk of crime linked to gambling. They will also make gambling fairer by helping consumers collect their winnings without unnecessary delay.’’
MacArthur further expressed his organisation's commitment to making sure that the guidelines governing the largest market in the world are the “safest and the fairest.”
Safe and Fair
And “safest and fairest” remain the operative terms here. The difference between marketing to a customer and preying on addiction may seem a subtle line from the operators side, but ethical behavior and decision-making should remain a reasonable expectation of any individual exercising common sense and fundamental courtesy.
Anyone with a professional understanding of appearances, and empathy for fair market values should be able to recognize when they are using language or marketing content or promotional devices which are too overt. Further, the content specialists who may be hired to reach out to the gaming market have to exercise more restraint, or be oriented by their employers of the need to avoid aggressive communication to maintain a sense of ethics in their approach to marketing--as opposed to being over the top.
Accountability Oversight Penalties
From the recent high profile £322,000 Petree fine for failing to recognize money laundering failures
to the suspension of EveryMatrix Software Limited License for breakdowns in compliance activity within its customer interaction framework to the £5.9m Ladbrokes bust for “past failings in anti-money laundering and social responsibility,” the UKGC is demonstrating it's seriousness about penalizing operators who facilitate illegal money laundering wittingly or unwittingly.
Protection is a Spectrum
The aforementioned penalties are part of the greater policy of protecting society at large from unscrupulous behavior which easily extends to or can lead to aggressive advertising behavior and hasty or incomplete background checks.
The New Climate
Marketing to a demographic which contains a vulnerable segment is not the same as marketing other products. The UKGC is putting the onus on operators to know the difference.
While the distinction may be straightforward for most individuals, the need to ensure compliance across an entire organisation of lesser stakeholders now becomes the primary challenge for any senior executive--with his or her company's fortunes clearly now at stake. If operators are unsure of their culpability when ethical questions are raised with certain content or marketing techniques, an old adage comes to mind in the form of a new suggestion: when in doubt, leave it out.