UK Gambling Commission
relates to failure to identify source of funds in individual cases, failure in interactions with low numbers of excluded individuals and failure to identify/intervene in cases where individuals were losing large amounts of money. MITIGATIONS? The UK Gambling Commission has set out its principals for determining financial penalties 5 which, among others, includes these main points : • The seriousness of a beach, whether a licensee ought to have known about a breach and whether a breach is a repeat offence • Detriment to consumers and financial gain for licensee • A premium to any amount determined by the above considerations (among others) to act as a deterrent If the UK Gambling Commission is by some distance the keenest to impose financial sanctions and increasingly willing to impose £multi-million penalties, are there mitigating circumstances which could explain its actions? Is this evidence of institutional bias or just the kind of gold- plating of regulation and enforcement for which the UK has a reputation? Market size: There is no real evidence that the size of the
UK market alone would explain the difference in fines. The UK is broadly comparable to other markets (Figure 5) and highly channelized, so if anything, such comparisons are smaller than they might appear.
€ billion
UK
Italy
Germany
France
Spain
Netherlands
0.00 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00 18.00
Different regulatory responsibilities: The UK regulator has a duty to ensure there are adequate controls in place at gambling companies to prevent their platforms being used for money laundering or funding of terrorism. This does not appear substantively different from other regulators, Fig 5. Comparative market size GGR €billion. Source: Statista 2022
5 https://www.gamblingcommission.gov.uk/print/statement-of-principles-for-determining-financial-penalties
30 • IMGL Magazine • November 2022
Made with FlippingBook flipbook maker