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March 23, 2020
The Commission recognises that these unprecedented circumstances will be having a significant impact on businesses and many will be facing uncertain and unsettling times. The Commission has a well-practised and comprehensive Business Continuity Plan, which it has invoked with the intention of minimising the impact on its regulatory work and the advice and services it provides.
A number of operators have already contacted the Commission to alert it to the challenges they face and seek its advice about how to respond. The Commission realises that the circumstances will create challenges for businesses. However, it notes that the changes will also increase the risks to some individuals, which means that despite the fact that these are challenging times “we must all continue to protect consumers”.
A reminder to operators
The Commission expects all licensees to follow the applicable Public Health guidance. Where facilities for gambling are being offered it expects all licensees to ensure that they have sufficient management, staffing and oversight in place to maintain compliance with the LCCP that apply to their licences;
Fees and applications
The Commission’s expectation remains that licensees ensure the maintenance of sufficient management, staffing and oversight in order to uphold the licensing objectives. Licensees should assess their ability to maintain compliance with the LCCP and consider voluntary partial or full suspension of their offerings should compliance not be achievable and until such time as a fully compliant service can be offered.
Unfortunately, the Commission says, due to the way that its fee system is structured it does not have the ability to reduce fees. It is also unable to fast track applications. It will continue to monitor the situation and will communicate any changes to expectations accordingly.
A reminder specifically for online operators
The social distancing measures that are being put in place will mean that more people will be at home and the Commission reminds online operators that they “must continue to act responsibly, especially in regards to individual customer affordability and increased social responsibility interactions”.
The Commission expects licensees to:
- assess individual affordability on an ongoing basis as customers may be experiencing disrupted income;
- increase social responsibility interactions and intervene where customers are showing signs of gambling related harm;
- onboard new customers in a socially responsible way and not exploit the current situation for marketing purposes;
- refresh the information they have on customers regularly;
- review the levels that trigger interaction for AML and SR; and
- ensure that gambling products have been tested by a test house before they are released to the market.
To read the Commission’s guidance on its website, click here