IMGL Magazine April 2022

UK Gambling Review

a positive step forward in the overall change process. Step 7 – Consolidate improvements and produce still more change: Enabling the use of short term ‘wins’ as evidence to argue for further regulations and contribute to the momentum needed to facilitate large-scale change. Step 8 – Institutionalise new approaches: People should understand the new approach and how the change has facilitated positive outcomes. Effective communication through ‘change champions’ is required. We should therefore expect pressure from public health and other anti-gambling lobbyists to be sustained and even intensified irrespective of the depth of market curtailment enacted by the Government and regulator. The creation of a gambling ombudsman (if that is what the Government decides to do) would create a further realm of market regulation alongside the activities of the Gambling Commission. It is not the creation of an ombudsman that prompts concern but how that ombudsman is likely to discharge its duties in the face of inevitable lobbying. Act V – A Blueprint for International Reform The coda to the drama in Great Britain may serve as a prelude for events overseas. Even those not particularly interested in the British market should consider the risk of regulatory contagion. This is especially relevant in jurisdictions that have recently legalised online gambling or that are in the process of so doing. History tells us that rapid expansion of opportunities to gamble is often succeeded by a backlash as the benefits of competitive, regulated markets become taken for granted and the costs become more apparent. Britain’s position as the first major economy in the world explicitly to permit online gambling (having never explicitly prohibited it) and its long-held (until fairly recently) reputation for regulatory competence has made it an important reference point for governments seeking to accommodate the internet within licensing frameworks. Britain still has a reputation as a country that does gambling well as evidenced by the near absence of criminal involvement in operations, the small size of the unregulated market and relatively low rates of ‘problem gambling’ and ‘gambling disorder’. There is a risk, therefore, that Britain shifts from being the poster boy for cautious liberalism to being the blueprint for graduated prohibition, following the ‘tobacco road’ that will see smoking stubbed out in this country by 2030. The public health lobby is global in nature and commonly cites restrictions gained in one territory in support of demands for changes in another (in much the same way that proponents of gambling expansion cite claimed benefits in one state to

tinker with market regulation through changes to the Licence Conditions and Codes of Practice. The key point to make here – and indeed in respect of the entire process of market re-regulation – is that at each stage, the public health lobby will push the authorities to go further. This is because it perceives gambling to be an ‘Unhealthy Commodity Industry’ – an activity that bestows no benefits and has the capacity to do harm regardless of dosage. In short, it is positioned as the ‘new tobacco’. Those who hold this view are likely to be unstinting in their persecution of the industry and its consumers. No level of harm reduction is ever likely to appease those who hold a dogmatic objection to gambling on the grounds of morality or self-interest. The public health gambling playbook was set out by David et al. in a 2019 article in the Australian and New Zealand Journal of Public Health. It describes a relentless push for ever tighter restrictions, with each advance being used as a springboard for the next. The final three stages of its eight- step plan reveal a conscious and deliberate strategy: Step 6 – Plan for and create short-term wins: Each ‘win’ in terms of policy change should be framed and communicated as

IMGL Magazine • April 2022 • 33

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