The Government has announced that betting shops and arcades (together with other “non-essential” retail outlets) are expected to be able to reopen from 15 June 2020 if the Government’s “five tests” to ease the current coronavirus lockdown are met and the operators of such businesses follow the COVID-19 secure guidelines.
The five tests are:
- Making sure the National Health Service (“NHS”) can cope and continues to have sufficient capacity
- A “sustained and consistent” fall in daily deaths
- Solid data showing the rate of infection is decreasing to “manageable” levels
- Ensuring that supplies of tests and personal protective equipment can meet future demand
- Avoiding a second coronavirus peak that would risk overwhelming the NHS (generally considered to be potentially the most difficult test to overcome).
Such businesses will only be able to open from the above date once they have completed a risk assessment, in consultation with trade union representatives or workers, and are confident they are managing the risks. They must have taken the necessary steps to become COVID-19 secure in line with current Health and Safety legislation. In this respect, the Government has published updated guidance for employers, employees and the self-employed working in all such business as are described above, entitled “Working safely during COVID-19 in shops and branches“, that you can download below.
The updated guidance takes into account best practice demonstrated by retailers that have been allowed to remain open and have applied social distancing measures in store.
Measures that should be considered in betting shops include placing a poster in the windows to demonstrate awareness of the guidance and commitment to safety measures, placing protective coverings on large items touched by the public such as seating, and frequent cleaning of objects and surfaces that are touched regularly, including betting terminals, gaming machines and hot drinks machines, for example.
In line with the Government’s previously published roadmap, the general hospitality sector (including other land-based gambling premises) will remain closed until further notice, because the risk of transmission in such environments is higher where long periods of person to person contact is required.
1. As reported by us here, the Betting and Gaming Council subsequently announced on 2 June 2020 that England’s land-based casinos will be ready to re-open their doors for business again from 4 July 2020, “abiding by strict anti-Covid standards”.
2. On 5 June 2020, the BGC published on its website a report of a visit by its CEO, Michael Dugher, to a Coral betting shop in central London in relation to which he commented: “I was hugely impressed with the new-look Coral branch. It’s great to see all the efforts they and other operators are making to provide a safe and enjoyable environment for their staff and customers alike”. You can download below a copy of that report.
3. On 12 June 2020, as reported by us here, it was reported that the Department for Digital, Culture, Media & Sport had, during the previous night, informed the UK amusement machine industry trade body (Bacta) that arcades are no longer on the list of non-essential high street premises able to reopen on 15 June 2020.
4. In advance of betting shops re-opening, the Gambling Commission has published (on the “AML News” page of its website) the following money laundering warning (together with other AML news items, on which we have reported here):
Scheduled re-opening of land-based betting shops on 15 June and new £20 notes
The recent government announcement of the re-opening of ‘non-essential’ shops on 15 June includes land-based betting shops.
Gambling businesses are reminded of their mandatory responsibilities under the Gambling Act 2005, the Licence Condition and Codes of Practice (LCCP), the Proceeds of Crime Act 2002 (POCA), The Terrorism Act 2000 (TACT) and other applicable laws to keep crime out of gambling.
Linked to the above point regarding the re-opening of some land-based businesses, on the 20 February 2020 the Bank of England launched the new polymer £20 note. Although the old paper £20 note continues to be accepted as legal tender, it will eventually be removed from circulation.
During the transition from the paper note to the polymer note, individuals with quantities of the paper £20 note, including notes that may be the proceeds of crime, are likely to try to exchange them before they are removed from circulation.
Where gambling businesses and their frontline staff have knowledge or suspicion of money laundering or terrorist financing involving the old paper £20 note, they must submit suspicious activity reports (SARs) to the UKFIU in the normal way.
More information about the new polymer £20 note can be found on the Bank of England’s website, here: https://www.bankofengland.co.uk/banknotes/polymer-20-pound-note