David Clifton to moderate ‘UK Re-Wired’ panel session at SBC Summit Barcelona on 21 September 2022

At 3.30pm on 21 September 2021, David Clifton is moderating a panel session entitled ‘UK Re-wired – UK Gambling Act 2005 under the Spotlight’ at this year’s SBC Summit Barcelona – the ‘Global Betting and iBetting Show’ – being held between 20 and 22 September at Fira Barcelona Montjuïc.

David’s panellists will be:

  • Guy Harding, Commercial Strategy & Safer Gambling Director, oddschecker
  • Sophie Platts, Head of Safer Gambling and External Affairs, Entain Group
  • Adam Doyle, Head of Gaming, TruNarrative
  • Tom Banks, Head of Corporate Affairs UK/ Global, Kindred

The organiser’s marketing material for this session reads as follows:

How have the generational outcomes of the 2005 Gambling Act Review disrupted the terms of play of the UK gambling market for all participants and stakeholders? Who were the winners (if any) of a fraught and highly contested two-year probe of UK gambling regulations and market standards? How will operators contend with a further period of regulatory adjustment in light of settled judgements on consumer rights, safer gambling protections, affordability, RET duties and corporate governance?

As matters presently stand, it is open to doubt whether the UK Government’s long-awaited Gambling Act Review White Paper will have seen the light of day by 21 September. Following its summer recess the House of Commons does not resume business until 5 September when the appointment of the new Conservative Party leader to replace Boris Johnson as Prime Minister is likely to dominate Parliamentary attention for a good period of time.

It may therefore remain the case on 21 September that the panel discussion will revolve around continued speculation regarding future gambling regulatory change in the UK which is summed up:

However, we fully anticipate that rumours of future gambling regulatory change in the UK will remain rife and we encourage readers to book their tickets here for the SBC Summit Barcelona to learn more from David’s excellent and well-informed panel of speakers listed above. The full agenda for the conference can be accessed here.

David looks forward to seeing Clifton Davies clients and friends (old and new) from the worldwide gambling industry in Barcelona next month.



1. We have reported further on the above in our 24 September website posting here.

2. The below photograph of the very well attended panel session in full flow at the SMC Summit Barcelona on 21 September shows (left to right): David Clifton, Adam Doyle, Sophie Plates, Guy Harding and Tom Banks:


3. Commenting on the panel session, Earnings+More have reported as follows:

4. CDC Reports has picked up on other aspects of the panel session, stating as follows in its ‘Operators call for clarity on UK regulatory expectations article’:

Kindred head of UK corporate affairs Tom Banks said that although casinos have been taking steps to improve player protection by their own volition, clarity on what good looks like in the eyes of the regulator is still critical.

Oddschecker head of commercial Guy Harding agreed, pointing out that definitions and benchmarks vary wildly across jurisdictions, making it hard to guess the expectations of a single regulator.

“I was reading a report which looked at what the Division of Gaming Enforcement in New Jersey was looking at for affordability thresholds”, Harding said. “And we’re £2,000 over three months, but they were looking at $100,000 deposit over 90 days and a million dollars in stakes over 90 days. That shows the relative thresholds for New Jersey versus the UK.”

Harding said it’s not just affordability that is yet to be defined, highlighting that some operators refer to “recreational customers” as being those that are low risk.

“But no one has said what that even means”, he stated. “And the other thing to bear in mind is it’s a moving feast. So if you’re a recreational customer at inception or sign up, you won’t always be and it’s the flows people need to be very careful of.”

Entain Group head of safer gambling and external affairs Sophie Platts said her company had established a five-year partnership with Harvard Medical School to identify at-risk player behaviours and work out how best to intervene.

“We gave them our anonymized data sets. They reviewed them and looked at different cohorts of customers. And one of the things that was most surprising for a lot of people is that the highest-spending customers were actually some of the lowest when you compare them on PGSI [Problem Gambling Severity Index]. So it isn’t necessarily all about financial spend. Lots of behavioural indicators are missed from this conversation as well”, she explained.

Both Platts and Lexis Nexis Risk Solutions head of gaming Adam Doyle also raised the problem of gaining access to data and doing so without creating so much friction in the user journey that the product loses appeal or data-protection rules are violated.

Platts said Entain is working on a single-customer-view pilot with the UK’s Information Commissioner’s Office and the Betting & Gaming Council.

“We will look initially at those on a higher harm level, basically, those that have perhaps self-excluded from one of our brands. We want to tell other operators, ‘This person was self-excluded; you might want to watch and make sure they don’t spend too heavily with yourselves’. And then those that have been highly flagged on our algorithms as well”, she said.

This is a rudimentary step towards creating an industry-wide database of gambling customers, which prevents those at risk of harm from being known to and blocked from one operator, but able to gamble with another due to a lack of information sharing.

Banks called for greater access to customer data in order to improve player protection. He said in Kindred’s experience, just one in 10 customers is willing to supply payslips or bank statements to an operator.

“So the other nine out of 10 are either going elsewhere or eventually, if every licensed operator has to do that, there’s only one other place, or a couple of other places, they can go, and the grey market is one of them”, he said.

5. The 28 September 2022 edition of The Pinchpoint also picks up on comments made during the Panel session moderated by David Clifton at the SBC Summit Barcelona on 21 September, reporting as follows:

Declines and falls

A recent post from Regulus Partners examined the long-term trend in activity and value of individual customers at a number of the largest operators. The short version is they are both in decline.

While the pandemic occurred over the period shown above, the downward trends for revenues per active across slots, betting and other forms of gaming are clear. As Regulus points out, the year-on-year comparisons for Entain, Flutter and 888-William Hill show total online revenues off by ~15% with betting down a “painful” 26%.

This is the commercial backdrop to the reform of the gambling industry, of which affordability checks are a major part.

Some might argue that this shows that government can relax: fewer gamblers, spending less money. Affordability is not a problem.

Others might argue the opposite: it could lead to operators concentrating more on higher spending customers, precisely that cohort which campaigners argue has the most risk of harm. Affordability is a critical problem.

So what does the gambling industry think?

Waiting for instruction

As was noted by Tom Banks, head of corporate affairs for the UK and global at Kindred, during a panel session at SBC Summit in Barcelona, in the absence of clarity on what measures might be part of any White Paper, many operators within the sector “have taken steps anyway”.

But that same panel also highlighted how much the industry is still flying blind when it comes to the crucial issue of affordability. As Sophie Platts, head of safer gambling and external affairs at Entain, put it “the balance we are trying to strike is to get enough information to ensure someone is comfortable with their levels of spend but we don’t want to introduce a lot of friction”.

Since the summer the working assumption has been of detailed considerations of financial positions being made at £1,000 over a 24-hour period and £2,000 within 90 days.

But that is only a working assumption and the ongoing lack of clarity clearly leaves the market wide open to bad actors to take advantage.

It should be clear to policymakers that the current situation is absolutely the worst of all worlds. Decisions that need to be made are being delayed, definitions around such important areas as affordability are yet to be set and the broad objectives of government policy appear to be all at sea.

This is why no decision is, in itself, a decision: industry leaders fear being caught between the profit motive and social responsibility.