Overall, licensees are being asked to implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. Currently, many operators take a risk-based approach, tracking their top 10% highest spenders, potentially missing many gamblers at risk of harm.
The new guidance formalises best practice for operator’s responsible gambling strategies; looking for early signs of potential vulnerability. The new regulation continues to ensure all including operators, players, solution provider and the Gambling Commission address and keep responsible gambling at the forefront of the conversation.
Historically, when new regulation has been released there can be unexpected consequences. People will often find ways around new processes. For example, the banning of credit card usage for gambling last year could have meant that some potentially vulnerable individuals sought alternative less regulated loans. In essence, potentially pushing the risk under the table. With the new regulation, operators need to be vigilant at setting triggers and updating these constantly in line with risk trends in order to best protect players and stay ahead of those circumventing the new processes.
Operators will also need to ensure they fully understand a customer and their play patterns, without this deep knowledge these signs could go unnoticed. Conversely, players gambling well within their means may have a less enjoyable experience as a result. Operators will undoubtably look to ensure that unnecessary friction is kept to a minimum.
Customer transactional behaviour is an important tool to help flag identifiers of potential vulnerability. A common theme across the recent fines has been allowing an individual to make multiple deposits over a short space of time of varying amounts without sufficient safeguards in place. LexisNexis® Risk Solutions acquired RiskNarrative™ (fka. TruNarrative) back in 2021. Besides the complete onboarding customer journey which RiskNarrative offers via its orchestration platform, they also provide transactional monitoring, giving operators the ability to track customer transactional behaviour over time, helping to flag anomalies. This helps operators to Identify, Act and Evaluate, which are the three key terms the Gambling Commission are using in this latest update.
Another tool operators can use to gain insight into a player’s vulnerability is self-exclusion databases. This technology is used extensively in markets like the Netherlands and is an effective way to help protect players. Having the insight into whether a player has historically self-excluded with another operator is a great way to help protect them from any further harm. LexisNexis® Threatmetrix® technology can help alert you to this at both application and at any point in a customer journey, along with insight into the individual and their device. This means you can really build a comprehensive picture of a player.
We have all heard prediction of a new recession before the end of the year, meaning people and companies alike, will look at ways to cut back on spending. Most operators will already have multiple APIs, potentially feeding into their own bespoke back office – if they are lucky enough to have this.
The problem here is, each API will need updating with any new system brought in, this means it is not just the cost of the new system but the cost of updating the current ones to ensure each are feeding into the others correctly. This is all additional funding, to be found, in already tightened budgets. This is without implementing constant monitoring of players.
The Gambling Commission says “licensees must build processes which include the need to identify risk, take appropriate action and evaluate the impact of that action, which then returns to further monitoring, identification, action and evaluation. This is not a one-off process but should be considered throughout the customer’s relationship with the licensee.”
This will require a solution that can build a comprehensive picture of a player, including how much they spend on average, when they play, how they play, how much they lose vs win, how much they deposit, how much they withdraw… The list goes on, and any changes to these patterns need to trigger alerts, update the player risk level and then provide this information to a person who can reach out and help. This is not a solution that can easily be built in house overnight. As the new guidance does not specifically say what risk and appropriate action looks like, this leaves operators open to additional costs and fines from the Gambling Commission.
As I touched on in the last question. Multiple third parties equals multiple APIs. Best case, these are fed into an inhouse bespoke back office, designed to show the auditor how a decision has been made. More often than not, the budget and infrastructure isn’t there, leaving the onboarding and compliance teams using multiple systems each with different back offices, allowing for too many errors to be made along the way.
A lot of the fines recently aren’t because operators haven’t been doing what they can to protect players, but instead are because they haven’t been able to provide evidence about a decision made two years ago, for example. Right now, it feels more like when; not if, you get a knock at the door regarding an audit. So, having a single view of a player and a comprehensive easily recallable audit trail is critical to demonstrating the right decision is made.
There are a number of ways that LexisNexis Risk Solutions can help with this, at a lot of different price points. Alongside ThreatMetrix® which I touched upon earlier, we have LexID®; customers are assigned an identifier so we can track them across brands and identify them across all of our products, providing this single view.
The LexisNexis® RiskNarrative™ platform delivers operators the ability to combine multiple data providers (including LexisNexis Risk Solutions products), transactions and behaviour monitoring, and case management in one place; with an audit trail of all interactions and decisions made.
Alec Cudworth, Gaming Specialist. LexisNexis® Risk Solutions