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This is

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Inside the Commission

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a Gambling Commission podcast

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Welcome to Inside the Commission,

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a podcast

all about gambling in Great Britain.

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Here we'll cover all the latest topics

and trends from across the gambling

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sector, and discuss

the big issues that matter to you,

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from consumer queries

to industry insights

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we'll bring you the facts

from the front line of regulation

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share the stats and stories

from those in the know.

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For all the latest discussions

and updates,

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Commission YouTube channel, or

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you can find us on your preferred platform

wherever you listen to your podcasts.

00:17:58:09 - 00:18:00:08

Welcome back to part two of our episode

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on our fair and open licensing objective

with Chief executive Andrew Rhodes.

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Where do we draw the line then?

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You know, because a lot of consumers

look to us as the regulator,

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as the police in some sort of way as

we can get involved in all of these cases

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and is it just through the

the LCCP or the rulebook

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or how do we actually make it

so it's simpler for people to understand

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if they've got a problem around

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withdrawals or I.D checks

and those sorts of issues?

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Is it straightforward?

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I don't think it is

entirely straightforward.

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I mean, this is why

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when we gave our advice

in the white paper, we said we thought

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there should be a statutory ombudsman

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The Commission is not a big organisation in the scheme of things. Globally

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as a regulator, we're quite a big gambling

regulator compared to other countries.

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But not in really big numbers

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And that's just because our market

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is just more developed

and has been around for a long time

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But we couldn't

be an ombudsman and I think

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where do we draw the line?

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I think we have to look at what

the overall strategic issues are.

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So, withdrawals and transparency

for consumers about

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why they've been asked to do something,

why they've been restricted?

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why have they been stake factored?

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You know, I saw a case recently

and I won't go

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into the details for obvious reasons

where a consumer had been told

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you've been subject to the Gambling

Commission mandated affordability check.

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They hadn't.

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Erroneous data

would come back from a different source.

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Absolutely nothing to do with regulatory

requirements or the Gambling Commission.

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And that customer was, frankly, misled.

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And things like that

are muddying the waters,

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and I think our job is,

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is to drive things

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forward in terms of clarity for consumers

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but you could only take so far

because if there are money

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laundering concerns, for example, or concerns

about fraud, which does come up

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quite often,

then you can't tip off an individual,

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well, I suspect you might be committing

fraud or suspect

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you might be laundering money,

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or I suspect this might be proceeds

of criminal activity.

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And there's a proper process for that.

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You know, there's fraud

intelligence units and there's obviously

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general law enforcement as well as us.

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So it becomes quite complicated

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and I don't think anyone

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should throw their hands up and go, well,

therefore we can't work it out.

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It's just not straightforward.

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What’s the industry’s role with it?

What would you say to someone

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listening from the industry now in terms of withdrawals

and I.D checks?

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They’ve got to be really clear, right,

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So, I think the industry's got

I think it's got a couple of obligations.

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One is, if you want lower friction

at the point of entry,

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you cannot simply introduce

friction later on.

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Right.

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We’re really,

really clear about that.

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So, you need to know who

your customer is, you’re required to

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So you should be getting the information

you need at the beginning.

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Right.

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And doing that as a swiftly

and as

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unintrusively

as you can, right, within reason,

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I think the industry has got to be

really clear with consumers about

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why it's doing certain things

and why it's asking for certain things.

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I'm not sure there are many other sectors

where you get away with,

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you know,

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saying some of those, doing

some of those things like, well, I just,

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you know,

I'm not going to take your business

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now without any explanation

or I'm going to ask you

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for a load of information

and not explain why.

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And I don’t think the industry's

been very good at that.

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Now, I say,

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now I say that, and

I should step back a little bit, actually,

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because I do think one of the problems

for the gambling industry

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is it gets treated

as a single homogenous industry.

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And it isn't, it isn't, so we license

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I looked the other day in a conversation,

I think it's,

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I think there were 2702 or something

licensees that were on the register.

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Now some of those will be really tiny

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and some of them will be the huge groups

you know, that we know about.

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Right?

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50% of gross gambling yield is, you know,

in the hands of 3 or 4 of those groups.

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So we've got to be careful

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not to say “the industry”

because not everyone does it all the time.

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But I do think the industry generally

hasn't been very good at this.

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And I think it's

I think it's hidden behind at times

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blaming the regulator because we can't

comment on individual cases.

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So it gets really difficult to say,

no, that's not true.

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Now, I don’t think that's really about

defending the reputation of the regulator,

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because I don't think

that should be our key focus.

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But I do think consumers are owed

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better explanations

as to why things are happening for them.

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So, more transparency

in terms of the process and what it’ll look like?

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Well, why? Why are you being asked for something?

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There will be times when you can't say

something but

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It's not all the time.

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And I've seen too many cases

where it's not

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It's not something they

they were unable to say anything about.

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I just think it needs to be better.

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And I think that needs to mature

a bit within the industry.

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So, I suppose if you've got consumers

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who are then frustrated, as you said,

we're not the ombudsman

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we don't deal with the complaints,

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is it the best route for those complaints

to go through

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an alternative dispute resolution say?

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I mean,

what that is, that is how the system works

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So firstly you should exhaust the complaints

process for the operator, because,

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an ADR will generally refer you back

if you haven't done that.

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So, it's not something

you escalate to straightaway.

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You should exhaust that

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then you should go to an ADR

and one of the things as I said earlier

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on, we've said there should be

an ombudsman that deals with these issues

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and also social responsibility issues,

because that doesn't exist at the moment.

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And that's something the government said

it would take forward

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from the White Paper,

and we'll wait and see what happens.

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But yeah, consumers

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should be going to an ADR

if they've not had a satisfactory answer

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from the operator.

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Okay. That's really helpful.

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So if you go back to the fair and open

discussion, then in terms of technology

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and how that's now

going to change the landscape

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and things like AI, for example,

and how that, sort of, is going to be

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a massive change, not just for gaming

and gambling for every industry.

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I suppose.

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What sort of challenges

does that pose for us as a regulator?

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And, you know, the industry is forging

ahead and evolving at a rapid rate.

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How are we keeping up with

that sort of stuff

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especially thinking

with our fair and open hat on?

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So there's

a couple of things going on around AI

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operators use of AI at

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the moment is mostly around

trying to drive consistency,

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of things like interventions.

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So, not necessarily interventions by AI,

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but understanding through use of AI

and its ability to simulate

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large amounts of information very quickly,

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whether or not

their approach is consistent.

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I think that feels like

a pretty sensible thing.

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There are other applications,

I think that will start to come along around AI

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in terms of, you know, how

they improve their margin, etc.

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I'm not quite sure how that will work yet.

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There are examples of bots

being used on the consumer side of things,

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which I think would really affected

certain products.

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There's a lot of talk,

I don't know, it wouldn't be our space,

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but I don't know what this looks like

in full reality.

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But there's a lot of talk about,

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poker and bots and how that's influenced online

poker.

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Certainly counterparts in Europe

have talked about, bots

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and AI being used around betting,

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on multiple lines, multiple accounts.

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There's been recent National Crime

Agency alerts about,

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identity spoofing through AI.

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So people paying for services

will spoof a load of documents

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for you to try and get around KYC

and things like that.

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That I think

is going to pose loads of challenges

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because when you start to think

about that, it's starting to attack

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the very core of ‘know your customer’

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and how does the operator know

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that they're really dealing

with the person they think they are?

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That opens up all kinds of other risks.

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And I think that's going to be an effort

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that's far wider than just

the Gambling Commission.

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And I think our, our own work

around technology

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and data and insights

been growing in the last few years.

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We've been investing heavily in research

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insight, our understanding of technology,

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trying different, approaches

and iterating different things around

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information

and how we can get a more accurate

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picture of what's happening

and detect things much earlier.

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and I know, people have been critical

of the Gambling Survey for Great Britain

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but it's a massive step forward compared to the health survey

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which was excellent in its time

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we're able to see things far more

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frequently at a higher level,

greater granularity.

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There aren't multi year gaps

between surveys,

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there isn't a year long gap

between the field work and the outputs.

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That's giving us a tremendous amount.

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The analysis that we've done

around open banking data,

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and what that's telling us about consumers

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real patterns of behaviour

is really insightful and important

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and I think we need to be doing more

and more of that,

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because we have to have a really refined

understanding of what's going on

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so that we aren't taking a really broad

brush

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to risks, we're looking,

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you know, we identify what they are

and look for them in specific places.

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And I think that's

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what the future regulation will be

is much more targeted intervention.

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And that really is what sits behind

financial risk checks as well, which again

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been talked about a lot, very heavily

criticised in certain quarters.

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But what that is actually about

is utilising available data and technology

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to, to not actually ask people questions

where they don't need to be asked

00:27:52:04 - 00:27:54:21

it’s to remove friction that exists

00:27:54:21 - 00:27:57:21

in the system now,

which is quite an analogue approach

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to something that would be more accurate,

more reliable, far less intrusive.

00:28:02:02 - 00:28:05:02

And I think that is

where all of this is, is going to.

00:28:05:12 - 00:28:08:12

You will always have a counterbalance

of people's privacy concerns.

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And that, I think, is,

00:28:11:22 - 00:28:12:18

you know, a fairly

00:28:12:18 - 00:28:15:18

obvious challenge for people in this day

and age.

00:28:16:12 - 00:28:19:07

And I don't, you know, I,

I don't think it's for me to figure out

00:28:19:07 - 00:28:22:14

the answers to all of that, but

I think it's going to continue to test us.

00:28:23:17 - 00:28:26:17

So as we come to the end of this

particular episode,

00:28:26:23 - 00:28:31:00

did you just want to sum up what you can

tell your message to the industry

00:28:31:00 - 00:28:34:16

and to our listeners in terms of the fair

and open licensing objective

00:28:34:16 - 00:28:39:05

and your summation where we're going,

what our feeling is from a Commission

00:28:39:05 - 00:28:42:06

point of view, and what message

you want them to take away from today.

00:28:43:17 - 00:28:47:17

I mean, I think I’d start with;

there are three objectives at the Commission

00:28:47:17 - 00:28:50:17

three licensing

objectives, the Commission’s got

00:28:51:10 - 00:28:55:04

I think there was a, in years gone by

and, I think for understandable reasons,

00:28:55:11 - 00:28:58:14

a much heavier emphasis

on the one about protecting the vulnerable.

00:28:59:05 - 00:29:02:14

And that's not to say that you stop doing

that in order to do the others.

00:29:02:14 - 00:29:06:18

What we've been able to do with

the changes we’ve made to resourcing

00:29:06:18 - 00:29:10:19

is try to focus much more evenly across

those three objectives.

00:29:10:19 - 00:29:13:19

So on the fair and open objective, it's

recognising

00:29:13:20 - 00:29:16:24

there's far more tension and far more,

00:29:18:07 - 00:29:20:00

I think

00:29:20:00 - 00:29:22:02

unwanted contact and friction

00:29:22:02 - 00:29:25:23

within the overall system

that supports gambling

00:29:25:23 - 00:29:30:02

so things like withdrawals, restrictions,

factoring and things like that,

00:29:30:09 - 00:29:34:18

which is a balance between the industry

protecting itself from certain things

00:29:34:18 - 00:29:37:18

but it shouldn't be disadvantaging

consumers unfairly.

00:29:38:04 - 00:29:41:24

And that's what we're really focused

on, is not trying to,

00:29:43:02 - 00:29:47:07

manage the market, that isn't our job,

but to make sure

00:29:47:07 - 00:29:50:22

that the industry is behaving responsibly

and it's transparent.

00:29:51:09 - 00:29:54:18

That's really where our focus is

00:29:55:07 - 00:30:00:03

Whilst we don't deal with individual

cases, doesn't mean we don't look at them.

00:30:00:13 - 00:30:03:18

I mean, I've personally looked

at quite a lot of cases

00:30:04:22 - 00:30:08:11

which, whilst I don't think it's

for me to intervene and fix them,

00:30:08:21 - 00:30:09:17

I think it is important

00:30:09:17 - 00:30:12:17

to see what the examples are

and what story they're really telling us.

00:30:12:23 - 00:30:14:15

There's a long way to go on this yet

00:30:14:15 - 00:30:18:15

and I've been quite open in public

with the industry about my challenge

00:30:18:15 - 00:30:21:19

to it and, sort of, what I expect it to do

in terms of transparency.

00:30:21:21 - 00:30:23:04

That hasn't happened yet.

00:30:25:11 - 00:30:26:04

But that

00:30:26:04 - 00:30:29:04

just means that

we will do something to make it happen.

00:30:30:22 - 00:30:32:02

Well, thank you very much, Andrew

00:30:32:02 - 00:30:35:02

For taking the time

to answer those questions

00:30:36:02 - 00:30:36:20

Cheers

00:30:37:12 - 00:30:39:01

This is

00:30:39:02 - 00:30:43:02

‘Inside the Commission’

a Gambling Commission podcast.

00:30:43:17 - 00:30:45:23

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