Those were the forecasts that were

In this month’s ‘Licensing Expert’ article for SBC News, entitled ‘Those were the forecasts that were’ (that you can download below), David Clifton goes back to his December 2020 article for SBC News entitled Ten forecasts and a hope for 2021” to find out how accurate those forecasts have turned out to be twelve months later.

He concludes that, in this highly unpredictable world in which we all currently live, he is making no forecasts whatsoever for 2022!


At the end of his article, David draws attention to the following ‘almost final’ UK regulatory developments of this year, saying:

Before we move on together to 2022:

  1. Keep an eye on the 9 February 2022 deadline date to respond to the Gambling Commission’s Consultation on changes and updates to its Licensing, Compliance, and Enforcement Policy.
  2. Check out the 25 November 2021 speech by the Deputy CEO of the Commission at the Bacta Annual Convention when she summarised current regulatory priorities including collection of participation & prevalence statistics.
  3. Of interest is the refined list of gambling reform demands being pursued by the Gambling Related Harm APPG and Peers for Gambling Reform but I think it’s premature to expect that list to remain so confined as time goes by next year.
  4. Very important AML and social responsibility learning is to be derived from the Greentube Regulatory Settlement, the regulatory sanctions imposed on Buzz Bingo and the report by the Commission on the conclusion of its investigation into IMME Limited.
  5. Definitely worth reading are the keynote speeches delivered by (a) Gambling Minister, Chris Philp, and (b) Gambling Commission CEO, Andrew Rhodes, at the 9th Annual GambleAware Conference. Of particular note was the former’s reference to the need for affordability checks to be proportionate “because people’s circumstances differ”, adding comment that “demanding payslips or bank statements from every customer spending £100 or so is likely to be unwelcome, disruptive and disproportionate to the risks”.
  6. Please do not under any circumstances ignore the essential reading material for all UK licensed gambling operators and suppliers that is contained within the Gambling Commission’s Annual Compliance and Enforcement Report for 2020-21 – in my opinion, significantly less coherently structured than previous editions and flawed by the absence this time around of critical material on ‘Customer Interaction/Social Responsibility’ and ‘Triggers/Social Responsibility’. That is not least because these are areas in which considerably greater clarity with regard to the Commission’s current and future expectations of its licensees is required.
  7. You will note that I have used the phrase “almost final UK regulatory developments of this year”. That is because it remains possible that, this side of the New Year, we may yet see the above-mentioned material missing from the Commission’s Compliance and Enforcement Report, i.e. within (a) its forthcoming Response to its Remote Customer Interaction Consultation and Call for Evidence and (b) any accompanying notification of future LCCP changes and updated Customer Interaction Guidance. We may also see a fresh Commission consultation on thresholds for identifying key financial risks in terms of ‘significant losses in a very short time, significant losses over time and financial vulnerability’ as flagged up by the Commission’s Executive Director, Tim Miller, at the KnowNow Annual Conference back in September.
  8. Showing little sign of compromise any time soon is the continuing difference of opinion between the BGC and the Gambling Commission over the illegal black market threat.