Tim Miller, the Gambling Commission’s Executive Director for Policy and Research and Senior Responsible Owner for the White Paper, delivered a speech at the Global Gaming Expo (“G2E”) in Las Vegas on 10 October 2023. In his speech, Mr Miller discussed (1) the “growing importance” of international collaboration with other gambling regulators, (2) how this is assisting in tackling illegal online gambling and (3) the progress of the White Paper and changes to the law and regulations in Great Britain, which remains the largest licensed online gambling market in the world.

This blog, whilst not intended to be a comprehensive overview, will summarise those three key themes from Mr Miller’s speech.

Growing importance of international collaboration

Mr Miller stated that gambling is a global industry and that leading operators and suppliers are now (mostly) multi-national businesses. The Gambling Commission’s motivation to collaborate with international regulators has been piqued, as it witnesses more large British or European operators seek to establish themselves in North American jurisdictions.  Indeed, Mr Miller declared:

“Increasingly we regulate the same companies; we address the same risks; we face the same challenges.”

In an effort to provide clarity about what the Gambling Commission means by strengthening its relationships with other regulators abroad, Mr Miller explained that the Gambling Commission continues to look to support new regulators in burgeoning jurisdictions and learn from their experiences, suggesting:

“The more gambling regulators know of each other’s rules, standards and markets, the more we are sharing information and best practice, the more we support each other then the more effective we will be.”

Consistent with the Gambling Commission’s tough stance on compliance and enforcement (indeed, Mr Miller mentioned the Gambling Commission broke its own record for “the largest ever settlement” twice in the last financial year), Mr Miller also gave a clear warning for licensees who are non-compliant in one jurisdiction not to be surprised if they are “the subject of regulatory conversation in other jurisdictions.”

Further collaborative efforts mentioned by Mr Miller include:

1. He, alongside the Gambling Commission’s Chair, Marcus Boyle, hosted a roundtable discussion at G2E with North American regulators on the practical steps the Gambling Commission will take to enhance regulatory collaboration;
2. the Gambling Commission is close to concluding a number of Memoranda of Understanding with US regulators, which look to establish clear working relationships with those regulators; and
3. the Gambling Commission continues to build stronger links between the North American Gaming Regulators Association and the Gambling Regulators European Forum.

Collaboration improving the combat against illegal online gambling

Mr Miller used illegal online gambling as an example of why international collaboration is important: what is illegal in one jurisdiction may not be in another, and some jurisdictions do not regulate online gambling at all. The key point made here is, as Mr Miller states, “legitimate, licensed operators from one jurisdiction can actually be the illegal or black market [operators] in another.” Tackling illegal online gambling is therefore a particular focus of the Gambling Commission and one which it relies on international collaboration to deliver greater results in making gambling safer, fairer and crime-free.

In terms of results, Mr Miller announced that by engaging and collaborating with payment providers, internet search providers and product and game developers, the Gambling Commission has delivered a 46% reduction in traffic to the “largest illegal sites coming into [the Great Britain] market.” Notably, Mr Miller indicated that the Gambling Commission’s Chief Executive, Andrew Rhodes, will be providing further information on this topic in a speech at next week’s International Association of Gambling Regulators conference.

Lastly, Mr Miller explained that the Gambling Commission continues to hold discussions with regulators in Europe and as far away as Australia to improve its response to illegal online gambling and influence on those outside of the gambling industry, declaring:

“The collective voice of gambling regulators across the globe pressuring big tech companies, banks and even some other jurisdictions to address the role they play in facilitating illegal gambling, will be much harder to ignore.”

Update on Great Britain’s changing regulations

Referring to the Gambling Commission’s first consultation following the White Paper released on 26 July 2023, Mr Miller indicated that the Gambling Commission has already received “thousands” of responses to these consultations. We strongly encourage stakeholders within the industry to respond to this consultation before it closes shortly on 18 October 2023.

Additionally, Mr Miller indicated there has been progress with the GamProtect project, which grew out of the Gambling Commission’s challenge to the gambling industry to produce a holistic view of risk of harm, known as the Single Customer View. Mr Miller indicated that the Gambling Commission has been working with the Betting and Gaming Council and the Information Commissioner to set up a pilot for this project and ensure the data gathered will only be used to protect people from harm.

Lastly, Mr Miller indicated that the Gambling Commission is finalising its new methodology for the collection of Participation and Prevalence data as part of the Gambling Survey of Great Britain. The Gambling Commission expects this survey (1) to have 20,000 respondents per year, (2) will be the “largest of its kind in the world when up and running”, and (3) will become the “new gold standard” of gambling data in Great Britain. Mr Miller stated the Gambling Commission is clear that “better data will lead to better regulation and better outcomes for both consumers and operators as a result.” As we have discussed previously, this is something we strongly support; better evidence and data should lead to better regulation, but time will tell.

Summary

Gambling is a global industry with global gambling businesses. The Gambling Commission’s desire to increase collaboration, especially against the backdrop of the Gambling Act Review and its previous speeches, is unsurprising. As Mr Miller acknowledged, “[n]o regulator – regardless of their experience or scale can be the world police” for the gambling industry. Watch this space to see what increased collaboration amongst international regulators means!