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Traditionally, the Commission’s attitude has been to take regulatory action against the corporate entities which possess its licences. The sanctioned entity in the Paddy Power ceilidh above was Paddy’s Manx licensee. However PML holders may increasingly face risk if the Commission gets too frustrated about certain areas of compliance where it feels the industry isn’t doing enough. One such area is the whole business of the transparency of the terms on which player incentives are advertised: the Commission and the ASA have both gone blue in the face to emphasise that all material ‘strings’ attached to these ‘free’ and ‘bonus’ offers must be telegraphed in neon lights in the ad copy, but the levels of ASA non-compliance and potential misleadingness to players remain high. It would not take too many more Paddy Power-style episodes for the Commission to decide that it needed to start to lean on PML holders in relation to social responsibility more widely, which would be a shame given the extraordinary success that the industry has had in keeping problem gambling at its current low level for the past fifteen years. There is not much, in terms of actual hard evidence, on which the industry can be faulted when it comes to social responsibility, including it must be said in relation to that bete noire of the press, FOBTs, but given that the PR agenda is still driven by daft scaremongering about social responsibility then part of the fightback should be a renewed effort to ensure the most scrupulous implementation of social responsibility regulation.

Wiggin specialises in the policies and procedures of compliance and offers training in all areas including specifically in relation to PML holders.