Spotlight on upcoming customer interaction changes

David Clifton’s Licensing Expert article for SBC News published today is entitled “Spotlight on upcoming customer interaction changes”.

It particularly 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 on 31 October 2019, providing as follows:

  1. Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:
    • identifying customers who may be at risk of or experiencing harms associated with gambling
    • interacting with customers who may be at risk of or experiencing harms associated with gambling
    • understanding the impact of the interaction on the customer, and the effectiveness of the Licensee’s actions and
  2. Licensees must take into account the Commission’s guidance on customer interaction.

At the same time, the existing LCCP ordinary code provision 3.4.2 will disappear, on the basis that its existing provisions will be covered by matters contained within the Commission’s guidance.

David concludes his article (that you can download below) with the following warning:

Operators face a daunting task ahead. The task involved in achieving the Gambling Commission’s customer interaction expectations should not be under-estimated. Senior management must take ownership of that task if they want to avoid their company hitting the headlines for all the wrong reasons in future.

You can read our website posting on the new customer interaction requirements here. David has also written articles on this same subject:


  1. 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.
  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.