UK industry analysts cannot stress enough: operators must maintain the highest levels of vigilance through the coming months – or risk an unthinkable regulatory backlash.
The coronavirus lockdown presents a number of challenges to gambling operators. Regulators, including the Gambling Commission of Great Britain, have been quick to point out that they will not accept any dilution of regulatory standards by virtue of the crisis and compliance and consumer protection must remain at the heart of business operations. Operators should pay keen attention to:
● Ensuring that business continuity and/or cost cutting measures do not undermine the ability of the operator to comply with its regulatory responsibilities.
● Checking that appropriate regulatory licences are held in order to offer alternative products in light of limited sports betting events.
● Exercising particular caution having regard to the potential increased risk of customers experiencing problem gambling and mental health concerns arising from isolation and ensuring SR interactions take place where appropriate.
● The need to refresh financial information held in relation to certain customers given the negative economic consequences of the Coronavirus generally.
● Ensuring that advertising materials (including those published by marketing affiliates) do not seek to exploit the current situation in a manner which is inconsistent with the guidelines or the overall spirit of advertising regulation.
The media, politicians and the regulators are watching the industry with great interest and now is not the time to drop the ball. Reputational damage and swift enforcement action will face those who do.
Founder, Clifton Davies Consultancy
Whilst cancellation of sporting events has been a catastrophe for the betting sector, the opportunity to convert customers to virtual sports and casino games has been quickly exploited. Playtech’s reports of an online poker and bingo resurgence may be partly explained by customers of land-based gambling premises (all of which have been subject to enforced closure since 21 March) looking for an online alternative.
With the potential for many customers to be engaging with new online gambling experiences, the disrupted income flow for many people and the Gambling-Related Harm APPG’s call for a £50 daily gambling limit for all customers, it is vital that UK-licensed operators pay heed to the UKGC’s “Guidance in light of COVID-19 outbreak”. It doesn’t need a complex SWOT analysis to appreciate that opportunity could quickly turn to threat, in the shape of regulatory enforcement action. New customers must be onboarded responsibly. Affordability checks and customer interactions have become even more important and should be refreshed regularly. A very careful eye also needs to be kept on the marketing techniques and practices of both operators and their affiliates to ensure that perceived opportunities arising from the coronavirus crisis are not exploited in a socially irresponsible manner.
Founder, Regulus Partners
The risk here is three-fold: that consumers potentially rendered more vulnerable by necessary policies of social distancing and isolation experience gambling harms (or experience other mental health issues that are blamed on gambling); that some operators demonstrate insensitivity to this risk (or incur allegations of avarice and profiteering); and that the powerful anti-gambling lobby (whose attentions have not abated) is now able to focus all its energies in one place (and at the same time condemn an entire industry for the failings of some). Despite it being well-flagged (by ourselves and the Gambling Commission among others), there are already signs that some affiliate operators have walked straight into this trap.
Some parliamentarians are calling for caps on online play during the period of emergency – and while this really should not be anywhere near the top of the Government’s concerns – the pressure seems unlikely to go away. This should be taken seriously. As the Government has demonstrated repeatedly, extreme times call for extreme measures and policies that would be unthinkable in normal circumstances (e.g. online limits, online curfews) become quite easy when the heat is on.
Meanwhile, those businesses who are perceived to be doing well in this period (particularly those who court controversy) may make themselves attractive targets for the programme of revenue raising that finance ministries will already be planning.