Is it best to win a war or to avoid one?

Emotive language to get the reader interested, but very relevant to the modern gambling world… read on.

This job description for a major gambling company appeared over a week ago:

“What will you be doing? 

  • Prohibiting Bonus Hunters from abusing promotions.
  • Ensuring registrations are clean from multiple accounts and fake accounts.
  • Liaising with the Fraud Department in order to carry out investigations & actions.
  • Withholding pay-outs to customers abusing of the bonus system.
  • Pro-actively detecting bonus abuse rings in order to mitigate abuse on certain promotions.
  • Document validation on accounts that have been suspected to be linked/bonus abusers.
  • Manually crediting/removing of bonuses from customer’s accounts.
  • Proactively determine fraudulent activity and act according to documented processes with regards to account actioning, document requests and additional checks required
  • Reactively and proactively conduct analysis of transactional and customer records to link unidentified transactions and accounts to known fraudulent activity
  • Keep an eye out for possible money laundering patterns and communicate your suspicions by submitting appropriate Internal Risk Reports (IRR) to the AML Team
  • Perform targeted checks on high-risk customers through various tools at your disposal, and if needed request the relevant KYC documents in compliance with any regulatory governing bodies and based on determined customer risk level
  • Make appropriate recommendations on how to improve internal processes and tools. Be willing to challenge the status-quo, ensure these recommendations are recorded and followed-up on accordingly
  • Undertake necessary administration work, including dealing with customer correspondence and record-keeping/case management”

You now know there is a ‘war’ going on between gambling companies and some customers.  In some ways unsurprisingly, this job description confirms the long held view that people who gamble and win money must be ‘wrong-uns’. It’s akin to saying that all responsibility for gambling addiction lies with the person. You know what J4P means, ‘When the FUN stops, stop’ and all that other PR.

Whilst every business has the right to protect itself from crime and J4P massively supports keeping crime out of gambling, what this job description doesn’t reveal is the other ‘side of the coin’.

When you constantly receive emails about:

  • Refusals to pay out  under 1K due to so called ‘security checks’
  • Bookmakers refusing to lay £10 sports bets
  • Losses of over 200K with no affordability checks;
  • Losses of over 20K in under 24 hours when a company already knows the person is vulnerable
  • Online gambling companies ‘spying’ on their customers to maximise profit
  • Regulators and government unwilling to take action that may help the ‘war’ end

…you know there is another ‘side to the coin’ and you know why emotive language is the least of our problems.

We received an email from one of our registered ‘friends’ who was very unhappy about this job description. We quote:

“Withholding pay-outs to customers abusing the bonus system.” – “Must be breaking several consumer rights laws. They’re basically saying, “We’ll let customers take the offer up and then, when they’ve risked their own money and won, we’ll refuse to pay out claiming they’re bonus abusers.”  I know that this has been covered by the recent CMA action, but to see an online operator put it in their job advert shows that they’re not even that bothered.”

“Document validation on accounts that have been suspected to be linked / bonus abusers,” “Perform targeted checks on high – risk customers through various tools at your disposal”.  – “I agree 100% that such checks are needed for fraudulent activity and to stop money laundering. However, to try and use the KYC checks to delay payment to a customer, because they are suspected (not even confirmed – “suspected”) as a bonus abuser is just wasting everyone’s time.”

Now you know both sides of the coin; where next?

Surely it’s obvious: You ban promotions, make gambling companies take sports bets at the odds they advertise to a minimum liability and work out what is truly a breach of contract or a crime and what isn’t?

No breach of contract or a crime should be decided by a company alone, be they a gambling company or not, and those things certainly shouldn’t be decided on ‘a suspicion’, but they are being.  In fact, as the job description highlights people are being employed to do just this.  Think about that; being specifically employed to disregard consumer law.

When a regulator has sole responsibility for an industry that some would prefer to be illegal (not J4P) it should not let a ‘war’ continue in the industry it regulates, especially when it could intervene and help reduce the ‘war’ to a minor skirmish.

Despite it being clear that certain interventions will help, the UK is presently not benefitting from robust regulation, so the ‘war’ will continue and ‘wrongs’ on both sides will not be reduced.