In seeking to understanding the current licensing and compliance landscape as operators are under unprecedented scrutiny, G3 speaks to the experts at SMP eGaming’s about the help that’s available.
What services do you offer eGaming companies to meet compliance and regulatory obligations?
SMP eGaming provides a number of services to eGaming companies. We oﬀer clients a multijurisdictional licensing consultancy service, assist companies with license applications, and help develop a framework to support an organisation in meeting its compliance and regulatory obligations.
With an unbiased and objective approach, we work with client’s day to day to ensure they undertake their responsibilities and remain in good health with their license conditions.
Essentially, we work as an extension of their compliance department. We can provide assurances they are following the rules and regulations that licenses hold clients to and that their procedures and policies all match up accordingly. We also have our Compliance 365 programme – an invaluable subscription-based model which provides rolling health checks to operators on the various areas of regulations throughout the year, access to our training academy, and ad hoc advice.
What type of compliance advice and support do you typically provide to established operators?
An established operator may have not kept pace with the changes in regulation and not realise that their processes and procedures may have become disconnected within the business, which could mean that they are not in line with their licence conditions. In such a situation, we would step in, perform a gap analysis, and ensure they are up to date with the relevant regulations.
We would also ensure that their procedures are clearly deﬁned in their policies and assist them in remedial work required to bring the business into line. For example, with responsible gambling issues, operators may be doing the right things but not in a way that provides suﬃcient evidence to regulators that they are looking after their customers.
We help our clients go from being reactive to proactive – we advise them about monitoring and what to look out for, be it trigger points, thresholds or transactional activity to identify bogus and fraud abusers.
There has been a substantial rise in the number of player exclusion initiatives across the industry. Should there be greater player protection or an onus on player responsibility?
First and foremost, operators should have tight controls in place and be aware that they have a responsibility to the player by ensuring that they make the right tools available to assist them to keep control over their activity online. Operators should interact with their players, understand their behaviour, and check a player’s aﬀordability.
If they have a concern, point them in the direction of help. New rules from the UK Gambling Commission mean that operators are required to check the aﬀordability of their customers. The crux of the issue is that operators need to better understand their customers so they can diﬀerentiate between a VIP player and someone who actually has a problem.
Whilst the focus is and should be on the operator to ensure these processes are in place, customers should also behave responsibly and avail themselves of the tools available. Operators should step in when they have a concern and advise a player to take a period of self-exclusion or use the tools available and advise them of services such as Gamstop and Gambleaware.
Should operators be granted greater powers to conduct affordability checks?
There are positive signs that operators are beginning to understand the importance of aﬀordability checks. When you sign up to an online operator, many now have pre-set deposit limits that, unless amended, players cannot exceed. Initially limiting player spend before they can understand the proﬁle of their customer is advantageous for all parties and a step in the right direction.
Regarding access to services which will investigate a player’s ﬁnances to check aﬀordability; a player’s activity online should be a leisure activity and it would be invasive to the degree that they impact peoples’ lives if operators could dig deeper into their personal ﬁnances. With the introduction of a ban on use of credit cards for gambling in the UK market from April, this will also help to combat problem gambling at source.
Where can you draw the line without being intrusive, providing gambling operators with this information could also have the opposite eﬀect as if you can determine that players have a larger disposable income, would enhanced marketing then take place? The emphasis is on the operator to remain responsible and undertake aﬀordability checks with the customer, ensuring transparency and trust between the parties.
What common difficulties do you face in assisting clients with their licensing applications and compliance frameworks?
All operators are diﬀerent; therefore, the policies and procedures of operators need to be bespoke to the products and services they oﬀer. License applications would depend on the jurisdiction as the requirements of one gaming authority can be vastly diﬀerent to another.
Instead, we need to keep abreast of changes in all jurisdictions in order to assist our operators to ensure they remain in good health and implement any changes to procedures that are required. By way of an example, most licence jurisdictions now require speciﬁc AML training.
As a result, many of our clients have signed up to the SMP Compliance Academy where multi-jurisdictional regulatory training is available.
In which jurisdictions do you offer your services?
We oﬀer services across multiple international jurisdictions, including the UK, Isle of Man, Malta, Guernsey and Jersey. We can also oﬀer our compliance and AML frameworks to jurisdictions where the regulation may not be as strict, in these areas we would build a framework based on a case of best practice.
As such, we can provide our services to any tier level of jurisdictions as we set the best possible standards for our operators. By encouraging operators to meet all licensing conditions and perform to the best of their ability, we have had over ﬁfty license applications approved across multiple international jurisdictions.
With our specialist knowledge and experience, no one is better placed to meet your licensing requirements than SMP eGaming. We also provide assistance with new start-ups looking to incorporate companies and help to provide assistance in corporate management for new operators in the marketplace.
Should operators be better at in-house compliance?
The answer ultimately depends on the size and scale of the organisations. For example, largescale household-name operators have hundreds of employees across the UK and millions of customers. It is imperative for such a large-scale operator to achieve the highest possible standard of compliance.
By bringing in a third party such as SMP eGaming, we are uniquely positioned to give objective and unbiased advice on a wide range of compliance issues. At the same time, we also have the ﬂexibility to provide a smaller operator with a bigger compliance department than they would otherwise have at their disposal.