Major Customer Interaction Changes Afoot

In an article for this month’s Casino Life entitled “Major Customer Interaction Changes Afoot” (that can be downloaded below), David Clifton explains the consequences for UK land-based casinos of forthcoming new customer interaction requirements, that will be implemented on 31 October 2019 when changes to the Gambling Commission’s LCCP customer interaction provisions come into force.

We have previously commented on these forthcoming changes (and, importantly, the Gambling Commission’s new customer interaction guidance in relation to both non-remote and remote gambling businesses) in our website posting that you will find here.

David’s article concludes with the following comments:

Successive public statements dating back to 2013, published by the Gambling Commission following enforcement action against licensed operators, have emphasised that effective customer interactions constitute an essential aspect of ensuring that commercial imperatives do not “crowd out” management of regulatory risk.

The ever-mounting fines imposed on, and financial penalties incurred by, those found to have committed anti-money laundering and social responsibility failings should provide a sufficient warning of what will happen if operators do not sufficiently take into account the Commission’s customer interaction guidance with effect from 31 October.

In my view, this is a prime example of a situation where all UK casino operators should share examples of best practice and effective conduct of customer interactions. That collaboration should not only be with each other but also with other sectors within the gambling industry. If I can bring anything to the party in this respect too, you know where to find me!

The Commission’s  “Customer interaction – formal guidance for premises based operators” (to which David refers in his article) can be downloaded below.


  1. David’s:
    • Licensing Expert article for SBC News published on 15 August 2019 (entitled “Spotlight on upcoming customer interaction changes”focuses on the Gambling Commission’s guidance for both remote and non-remote gambling operators that its licence-holders (with the exception of holders of non-remote lottery, gaming machine technical, gambling software and host licences) will be obliged to take into account when the replacement LCCP Social Responsibility Code provision 3.4.1 comes into force.
    • subsequent article for iGaming Business entitled “Customer Interaction Alert” focuses on the Commission’s “Customer interaction – formal guidance for remote gambling operators” that you can access here.
  2. The Gambling Commission has invited ‘small operators’ to a free workshop (to be held at the Civil Service Club in London on 12 September 2019) on anti-money laundering and social responsibility. For more information or to book your place, you are invited by the Commission to email before 6 September 2019. The Commission says that the workshop will:
    • will cover topics including ‘knowing your customer’ and ‘customer interaction’ and
    • provide an opportunity to ask questions, raise concerns and learn more about its online portal e-services.
  3. On 25 September 2019, David is moderating the third in a “Responsible Player Journey” series of WrB Responsible Gambling Webinars, details of which can be viewed here. His webinar, entitled “Categorising different kinds of interaction and what they should look like”, is free of charge and you can find out more information (including how to register) here. David’s above-mentioned article for iGaming Business has now been published online by WrB.