August 15, 2019
The Gambling Commission of Great Britain has announced that gambling using credit cards is to be banned. The announcement comes in the form of a Consultation but readers of the Wiggin blog will recall that when the 72-hour age verification window was abolished, operators were given only a short timescale to comply on the basis that what the Commission called the ‘direction of travel’ was obvious from the previous consultation. So it seems that ‘consultations’ are not so much about whether the regulator should do something but rather how it is going to do it.
A prohibition on the use of credit cards for remote gambling would mirror the equivalent prohibition on the use of credit that applies to land-based. The prohibition reflects the fact that the moral pendulum of politicians and the media in relation to gambling has swung back to its ‘Victorian’ setting and it is deemed morally unsatisfactory that a person should borrow money in order to gamble. Borrowing money to buy a car, a holiday, a case of expensive champagne or a trip to Mars with Elon Musk is fine, but using your credit card to put a bet on the horses is not. At least one respondent to the call-for-evidence talked about individual choice and responsibility but they seem to have been a lone voice. A small number of faith groups pointed out that there is no ‘moral case’ for this sort of gambling using borrowed money. That is true but only if your antecedent premise is that your moral rules automatically override your fellow-citizens’ freedom of choice.
Of greater significance is that many respondents to the Commission’s ‘call for information’ pointed out that credit cards are easy and convenient ways of incurring debt, something which seems to have prompted the Consultation to speculate more widely on the use of debt (howsoever obtained) for gambling. The Consultation therefore expresses concern that persons prevented from gambling with credit cards might turn to other sources of debt to fund their gambling. The concomitant of this is that operators will be expected to ‘introduce protections’ to stop their customers gambling with ‘other forms of borrowed money’. So the ‘direction of travel’ is clearly that at some point operators may well be told that they may not accept stakes comprised of borrowed money even though many persons – perhaps the overwhelming majority – who use credit cards to gamble may not be at risk of harm and that credit cards are conveniently visible to operators’ social responsibility monitoring regimes.
Perhaps the most telling contribution to the ‘call for evidence’ was from the ‘Step Change’ charity which helps people with debt problems. Step Change pointed out that people in trouble with gambling debt had obtained credit from several sources and that only a holistic approach to all forms of borrowing would serve to help those persons. The other major charity respondents – The Money Charity and The Money and Mental Health Policy Institute – made the same point. These insightful contributions from these organisations working at the coal face suggest that the excessive use of debt by a minority of players might well be a problem but that in these sad and unacceptable cases it was just part of a bigger disaster that people had fallen into. What is really needed is accelerated use of AI on all available data to pick up the symptoms of pathological and unaffordable gambling before they take root.