Rank Group incurs £500,000 penalty for failing to protect a VIP problem gambler

Pursuant to a regulatory settlement announced today by the Gambling Commission, the Rank Group PLC (t/a Grosvenor Casinos and online at www.grosvenorcasinos.com) is to pay £500,000 for failing to follow Gambling Commission rules that protect problem gamblers.

The full terms of the penalty package are set out as follows in a Public Statement, that can be downloaded below:

  1. Payment in lieu of a financial penalty of £500,000 which will go to GambleAware to pay for;
    • analysis of data sets of high spending customers to identify risk indicators associated with harmful gambling
    • thematic research into patterns of play to identify harmful gambling traits.
  2.  Agreement to provide an anonymised dataset of high-end online and offline casino customer play for GambleAware’s research. The analysis of this data will focus on staking patterns, size of stakes, speed of play and other characteristics of this area of gambling.
  3.  Rank has considered the extent to which it had benefitted from its engagement with the customer over the course of the relationship and has terminated the relationship making an agreed divestment
  4.  Payment of £5,000 towards the Commission’s investigative costs.

In terms of background, an investigation by the Commission revealed that Rank:

  • failed to interact with a very high net value customer who lived overseas and who was displaying problematic behaviour,
  • contacted him during a self-exclusion period and
  • did not follow rules for the provision of credit.

According to the Commission:

  • the customer in question gambled substantial amounts with Rank’s land-based Grosvenor Casino and online at www.grosvenorcasinos.com and
  • in one 24-hour period the customer lost £1million that had been credited to his account.

The Commission says that, in determining the appropriate outcome, it took the following factors into account:

  • proactive and timely self-reporting by Rank of all the issues identified,
  • Rank being open and transparent from the outset of the investigation and fully co-operative throughout,
  • Rank carrying out thorough internal investigations and taking action to address failings and weaknesses; it also kept the Commission informed throughout this process, and
  • a demonstrable insight into the seriousness of the failings.

Richard Watson, Gambling Commission executive director, is quoted as saying:

We expect all operators to protect any consumer who maybe experiencing problems with their gambling, and operators shouldn’t fall into the trap of thinking that VIP customers don’t experience difficulties. No matter how wealthy customers are, operators still need to monitor them effectively to ensure they aren’t showing signs of problem gambling. It is certainly not appropriate to visit customers during a period when they are self-excluded. This penalty package would have been a lot higher were it not for the positive action Rank took in terms of self-reporting their failures and being open and transparent during our investigation.

The Public Statement includes what the Commission believes to be “valuable learning for operators’ non-remote and remote (online) facilities”, suggesting that operators should consider the following questions to avoid the same issues:

  1. Do you have systems in place to identify potential signs of problem gambling?
  2. Do these include appropriate trigger points for when the usual pattern of gambling becomes unusual (these should not be just financial)?
  3. Do your customer interaction policies and procedures also cover VIP customers?
  4. Are you alert to the particular risk these customers bring? Are commercial considerations overriding customer protections?
  5. How promptly are details of self-excluded customers removed from your marketing databases?
  6. Are your data sets ring-fenced to prevent access to self-excluded customers’ details for marketing purposes?
  7. How do you manage high net worth customers?
  8. Are your VIP teams/managers sufficiently trained and do they work within the same controls as the core of the business?
  9. How do you manage credit in respect of high net worth customers?
  10. Is your online registration system sufficiently robust?

Readers wishing to know more about the regulatory requirements in relation to VIP customers are reminded that in January this year David Clifton moderated a panel session at the KnowNow Social Responsibility for Gambling Operators conference that posed the question “How serious is high-roller problem gambling?”. It focused on the LCCP social responsibility code provision 3.4.1 (dealing with customer interaction), which has required as follows in relation to VIP customers since May 2015:

“Licensees must put into effect policies and procedures for customer interaction where they have concerns that a customer’s behaviour may indicate problem gambling. The policies must include ….. (e) specific provision for making use of all relevant sources of information to ensure effective decision making, and to guide and deliver effective customer interactions, including in particular ….. (ii) specific provision in relation to customers designated by the licensee as ‘high value’, ‘VIP’ or equivalent”.