A penalty from UKGC once again illustrates the need to understand and process self-exclusion guidelines.
Gambling operator NSUS Limited has taken the hit from UKGC to the tune of £672,829 penalty for social responsibility and anti-money laundering failures, with the penalties more clearly illustrating the scope of accountability that an increasingly active UKGC is going to hold operators to.
Trading as GGPoker and operating as www.ggpoker.co.uk, NSUS is also absorbing an official warning for the failures.
Failures include the inability to identify customers at risk of experiencing gambling-related harm; and failing to interact with customers identified at risk of experiencing gambling-related harm.
The Commission expanded on the requirements of operators in the NSUS example by adding the preventative nature of operators’ obligations when NSUS failed to control their email marketing.
The Commission cited NSUS’ failure to “take all reasonable steps” to prevent certain materials from being sent to customers who had previously excluded themselves. The violation was in the emails, with 125 being sent to self-excluded customers.
Clearly, when customers self-exclude, operators need to take measures to control email and all other marketing materials as well, to the extent that they determine whether what they are sending out will continue to tempt customers to play.
Editing or selecting marketing materials to be sent to specific customers seems like a reasonable obligation for operators to integrate to continue operating seamlessly and proactively.
This is also a more prominent reminder of the need for operators to be aware of the materials they are sending out.
AML Check Violations
Further anti-money laundering violations identified by the Commission on the part of NSUS include failures to conduct adequate anti-money laundering and terrorist financing assessments, risk assessments and failures to ensure the positioning of appropriate policies, procedures, and controls to prevent money laundering and terrorist financing.
Proactively Following Guidelines
This penalty constitutes a solid reminder to operators to be proactive in understanding and addressing financial security checks and guidelines and reviewing the guidelines regularly.
Stay in Touch
It appears operators would benefit by staying in communication with the commission and consulting with them on the language in question, new guidelines, or applications of policy.
Self-exclusion lists are tools used by players who have recognised that their gambling habits are harmful to them, and need help controlling them. The latest Commission penalties indicate how lists are only the beginning of the requirement, and operators must subsequently adapt their entire marketing approach organisation-wide.