Gala Interactive (Gibraltar) Limited is to pay a total of £2.3 million for failing to effectively interact with two high-spending “VIP” customers who were displaying problem gambling behaviour whilst playing Gala’s online games and, in the process, gambling away approximately £1.3 million of stolen money.

One customer lost £837,545 over 14 months and was subsequently imprisoned for four years for stealing from an employer. The other lost £432,765 over 11 months and was subsequently imprisoned for four and a half years for acquiring, using or possessing criminal property.

The Gambling Commission’s investigation also found that Gala had failed to have in place written policies and procedures that could have curbed the problem gambling behaviour.

As explained in the public statement relating to this investigation dated 6 November 2017 (that can also be downloaded below), the overall penalty package comprises:

• £1 million payment to fund research relating to the causes of problem gambling and  
• payment of £1.3 million to the victims of each of the above-mentioned customers

and, in addition, Gala has volunteered to pay a further £200,000 to fund research relating to the causes of problem gambling.

In relation to the above penalties, the Commission has described as an “aggravating factor” the fact that, during a previous case regarding similar failings (whilst the two above-mentioned customers were gambling with Gala), Gala assured the Commission that customers of concern would be identified sooner and effectively handled. The amount of the penalty package now imposed reflects the warning given by the Commission when announcing its new more robust enforcement policy that repeat offenders should pay a heavier penalty for their failure to learn and change.

The Commission suggests that, in order to avoid making the same mistakes as Gala Interactive, resulting in breaches of LCCP Social Responsibility Code provision 3.4.1.1 (e)(i) & (ii) relating to customer interaction (including specific provision for “high-value” or “VIP” customers), operators should consider the following questions:

• Are you checking on the wellbeing of customers whose behaviour may indicate problem gambling?
• Do you have policies and procedures in place that will help you do this?
• Are you using all information (including customer spend levels and emotional state) to spot problem gambling behaviour?
• Do your policies and procedures make specific provision for social responsibility requirements when interacting with VIP customers?
• Are you keeping accurate records of these interactions?

Sarah Harrison, Chief Executive of the Gambling Commission is quoted as saying: “We will continue to take robust action where we see operator failures that harm consumers and the wider public. It is the responsibility of all operators – particularly key decision makers in those companies – to ensure they are protecting their customers and step in when there is behaviour that might indicate problem gambling. This did not happen in this case and the £2.3m penalty package should serve as a warning to other operators.”