Removing free-plays and uniformity of the ID verification on deposit and withdrawal are two recommendations in the Fairer Gambling submission to the DCMS review.
On October 8th the Sunday Times ran a front-page article “Cartoons lure kids to online gambling”. By October 22nd it was able to headline a front-page story with “Gambling sites forced to stop luring children”.
The Advertising Standards Authority (ASA) and the Gambling Commission had joined forces to send a letter to operators, supported by the Committee of Advertising Practice and the Remote Gambling Association (RGA), requiring use of over 450 identified games to cease.
The Sundays Times editorial described their victory on child gambling as “swift and sweet”. With DCMS soon to announce the review on FOBT stakes, including TV advertising and responsible gambling measures, it is hard to envisage that there was not an instruction from DCMS to the Gambling Commission to get this sorted as soon as possible.
The Gambling Commission has a duty to enforce the licensing objective of prevention of harm to the young and vulnerable, so why had it failed to act prior to the Sunday Times story? Simply, the Gambling Commission philosophy is that it does not proscribe content limitations, it assumes operators will act “responsibly” unless proven otherwise. Self-regulation is always a recipe for failure, but even more so with a sector that primarily elected to venue offshore to avoid tax and regulation.
If “free-play” versions of the games were not offered, then it is very doubtful that many under-18s would have had access to them. Additionally, if the ID verification process to deposit funds was as stringent as the age verification process to withdraw funds then, assuming procedures are adequate, no under-18s would have been able to obtain access.
Removing free-plays and uniformity of the ID verification on deposit and withdrawal are two recommendations in the Fairer Gambling submission to the DCMS review. There are also vulnerable over-18s who are enticed into gambling through the free-plays. This is even more likely if there is no enforcement of requiring that free-plays operate on the same return to player basis as the real games – in other words, the free-play games are designed to make the player believe winning is much more likely than it actually is.
Those in the know would not be surprised that Warwick Bartlett of Global Betting and Gaming Consultants came out claiming that the Sunday Times story was “fake news”. Mr Bartlett, enjoying Isle of Man tax advantages, was a chair of the bookie trade body, the ABB, for a period of ten years.
So where do these kiddy gambling games come from? Gibraltar identifies 29 primary licensees, of which 12 are casino business to business (B2B) brands. Of the nearly £1.6 billion lost on remote slots last year, over £1 billion of this went to revenue sharers – the B2B brands. Gamblers do not understand that the high street brand they think they are gambling with is not the primary beneficiary of their losses. How can this possibly be “fair and open” gambling?
These 12 B2Bs include US-owned Scientific Games and Inspired, the two FOBT suppliers. Are FOBTs, or any other machines in the UK, offering free-plays on any game content that would appeal to young and vulnerable persons?
The RGA, the trade body for the offending operators, claims on its site that they offer Fair Honest Safe Fun. It extols the virtues of the “Let’s Talk Responsible Gambling” week organised by the Industry Group for Responsible Gaming and GambleAware, which enjoyed lobbying drinks in Westminster last week. The Senet Group, the bookie-funded responsible watchdog keeps watching, but never bites, barks or even whimpers.
The Gambling Commission wrote to the Sunday Times explaining that its expert advisor, the Responsible Gambling Strategy Board, was looking into the issue and explained that Gambling Commission powers to regulate remote gambling have only been in effect for a “just a couple of years”. However, this is not the exact picture as sites that are located in the UK have been regulated since the 2005 Gambling Act. It only takes a few short hours to understand that the Gambling Commission appears not-fit-for-purpose.
This makes the DCMS review outcome very critical as the Gambling Commission is the statutory advisor to DCMS. In the event that the Gambling Commission is incapable of giving sound evidence-based advice to DCMS on the gambling review, but the government still relies on that advice, then a judicial review could arise.