David Clifton is quoted in a CDC Gaming Reports article by Scott Longley entitled “The need to know of customer onboarding” that you can download below.
It should be noted that this article was written during October 2020 prior to:
- the Gambling Commission’s High Value Customers Industry Guidance coming into effect on 31 October 2020 and
- commencement on 3 November 2020 of its “Remote Customer Interaction Consultation and Call for Evidence” (with a particular emphasis on customer affordability checks) that closes on 12 January 2021.
To underline David’s comments quoted within the article, getting operators to understand more about their customers is at the root of all that the Gambling Commission is demanding.
As the enhanced checks requirement in the new HVC Industry Guidance has underlined, ‘KYC’ has moved on to ‘UYC’ with more of the same to come, as evidenced by the Commission’s above-mentioned consultation on customer interaction.
The customer interaction guidance that came into effect in October 2019 explained more about the Commission’s expectations of all operators in relation to customer affordability.
That was reinforced by the additional such guidance in May 2020 requiring affordability assessments for all customers picked up by modified financial thresholds and triggers introduced to reflect the Commission’s fear of a rise in problem gambling statistics during the Covid-19 lockdown.
Even though that fear does not appear to have materialised, the Commission’s additional guidance remains in force and it has recently emphasised its expectation that online operators must act responsibly during the second lockdown in England.