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Affordability checks were one of the most

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controversial and hotly

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debated measures during

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the UK's gambling act review in 2022 and

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2023, seen by some as a

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simple tool to assess financial

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risks to a player and by others as a

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tyrannical invasion of privacy and

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personal data. Nevertheless,

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affordability checks were included as

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part of the white paper as

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suggested by the Social Market

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Foundation in a series of reports and

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recommendations. But now a senior fellow

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of the SMF has rolled

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back on his recommendation, asking the

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government to pause the implementation of

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affordability checks

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over concerns they are not frictionless.

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So why is there a change of

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approach and what does this

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tell us about the debate over gambling

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reform? Welcome back to iGaming Daily

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supported by OptiMove,

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the creator of positionless marketing and

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the number one player

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engagement solution for sports

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betting and iGaming operators. I'm

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Charlie Horner and today I'm joined by

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SBC Media's editor-at-large

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Ted Mamure and SBC news editor Ted Orm

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Clay. Ted M, how's

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things? Very well Charlie,

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glad to be back on our podline. Very

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good, no it's good to have

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you back and talking of good

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to have you back Ted Oc, welcome back to

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the show, how's things? Yeah

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pretty good, thank you Charlie,

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good to be back in the studio again

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feeling refreshed after a

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couple of days of annual leave

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and yeah it's always good to come back to

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a big news story to get stuck into.

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Yeah a big news story it is as well and I

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thought we'd left affordability checks

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behind us a good couple of years ago Ted,

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but it's back on the news agenda.

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Let's have another history lesson Ted

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because we all know that

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you're a history professor here at

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iGaming Daily, how did the idea of

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affordability checks come

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about in the UK and what has the

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industry reaction been like over the last

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few years? Okay I'm

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going to try and summarize

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affordability checks or kind of the

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journey of affordability

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checks as best as possible.

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So the idea was seeded from the first set

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of technical

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concentrations of the Gaming Act Review

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back in 2022 and in that kind of initial

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consultation phase

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DCMS asked stakeholders

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for feedback on protection layers needed

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to improve intervention

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and to minimize the risks

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of general consumers and gambling harms.

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So on a technical level

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what the UK Gambling Commission

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put forward was its case to go forth with

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affordability checks

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right and this was viewed

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as a measure that it had already begun to

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revise under its wider

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and kind of long-term policy

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of creating a single view of gambling,

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prevalence and activities

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that's been kind of its long-term mandate

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or its long-term

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strategy during the 2020s.

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Initially and straight from the off the

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kind of technical mandate of

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affordability checks

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was opposed by numerous stakeholders that

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we're going to get to, but

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DCMS backed the idea as a

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much-needed measure to modernize gambling

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protections in the

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smartphone era and gave the

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Commission regulatory clearance to

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proceed in 2023. So once they kind of

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published its blueprints

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there was kind of much lots of concerns

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on the design and the

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implementation but come August

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2024 the UKGC launched its initial pilot

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program which began on

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checking customers on the threshold

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of 500 pounds in that deposit, that was

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phase one. Six months later in February

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2025 it began phase two

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in which it would really put its kind of

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system in place of light

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checks at an affordability level

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of 150 pounds. Yet since then feedback

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has been limited on the

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measure and how the pilot has

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progressed. Come to it in kind of 2026

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and where we stand now there are many

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points of concerns on

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the technical application with pushback

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focused on privacy, false

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positives and actually the

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overall practicality and there's a fear

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now that we're leading the

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consumers to share kind of

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unwilling to share their data who might

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kind of migrate towards

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the unlicensed market.

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And from the developments this week that

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resistance appears to

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have been hard as the

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UKGC is told to put a pause on the

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affordability checks experiments.

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Yeah and we knew that this would have a

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lot of detractors as I said

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at the top of the show it's

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quite a controversial measure. You can

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see why certain

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stakeholders within the industry and

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from consumer groups might uphold was

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affordability checks but it said OC. It

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was quite surprising

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that this week the issue of affordability

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checks came back into the news this week,

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particularly because of who it was who

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was now voiced their

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opposition to the measures. Could

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you give a bit of background as to the

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latest update and why

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essentially we're talking about

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this today? Right so as you as you

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instead have just discussed Charlie the

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topic of affordability

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is quite a historic one in the UK. I mean

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if anything it

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predates the whole topic of

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affordability checks you know when we had

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the conversations

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about banning credit card

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transactions for gambling in the UK a

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number of years ago.

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Obviously it was a huge talking point

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throughout the gambling ad review between

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2020 and 2023. The reason

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it's come back in the news

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this week and as you mentioned why it's

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quite interesting you

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know that it has done the

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circumstances around it is that the

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person whose statement has re-raised it

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is is James Noyes who

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is from the Social Market Foundation the

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SMF. The SMF is a think

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tank which has been a very big

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proponent of gambling law reform, of

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regulatory reform in the

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UK over a number of years.

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As Ted mentioned it was a very active

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voice during the gambling

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ad review, a big proponent of

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affordability checks which materializes

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in the review is finance

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risk checks, the government kind

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of did a bit of a rebranding there. They

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wanted to put it across as

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something that would be very

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frictionless and light touch. I believe

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that the commission estimates

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only about 0.1% of UK betters

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will ever come up against these financial

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risk checks. James Noyes

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has now called for a pause

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of them and a review as to how they're

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working, the suitability of

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them. It's you know given that

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the SMF is a big proponent of these and

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last year was a big proponent of

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increasing UK gambling tax

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they wanted to see the highest threshold

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out of all the

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proposed thresholds last year.

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Given this this organisation's prominence

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in these debates it's

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quite interesting that he has

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joined the various voices calling for a

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review of them and a

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potential pause of them.

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This includes the likes of the British

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Horse Racing Authority which

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penned an open letter to DCMS

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earlier this month co-signed by a number

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of other stakeholders. Horse

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racing was also one of the big

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opponents of affordability checks during

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the gambling ad review. I

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think they were estimating

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losses of something like 60 million a

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year is what comes to mind from

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affordability checks.

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That was a figure that was often chucked

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around around 2021-2022. So

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yeah that's the reason it's

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01:07:56,772 --> 01:07:59,008
really interesting that it's come back to

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the news this week as you mentioned

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Charlie it's because of

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who it is who has raised them. Although

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we should also add that as

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James Noyes pointed out in his

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letter to the government this was his own

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opinion not that of the

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Social Market Foundation. He did

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emphasise that in the letter. Yeah Ted M

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I'll just throw it back over

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to you now because that is a

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significant voice to be vocalising their

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opposition to

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affordability checks isn't it?

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It is it certainly is and I think here

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we've got to kind of step

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back and look at who the Social

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Market Foundation are and how they brand

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themselves and this is

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a cross-party think tank

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and in its mandate it looks through UK

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policies in which it feels

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that it can have an unbiased

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01:08:47,690 --> 01:08:50,593
impact and it can get kind of cross-party

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01:08:50,593 --> 01:08:52,228
consensus and move

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forward and that was what

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it believed on the Gavin review that it

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should be toughened significantly

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tightened in the interest

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of the public and its protection the

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protection of consumers.

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Also that UK Gavin should face a

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01:09:11,747 --> 01:09:15,551
polluter charge and it actually supported

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01:09:15,551 --> 01:09:18,754
Gordon Brown or pitched

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01:09:18,754 --> 01:09:20,089
to Gordon Brown to support

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01:09:20,723 --> 01:09:27,062
the position of 50% tax on gambling. In

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terms of James Noyes himself

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01:09:30,099 --> 01:09:31,233
I think he's kind of viewed

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01:09:31,233 --> 01:09:35,004
as kind of the intellectual kind of

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01:09:35,004 --> 01:09:37,907
figureheads in the reformist camp of how

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gambling legislation should be reshaped.

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He's not a prohibitionist,

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he doesn't support a blanket

261
01:09:46,315 --> 01:09:49,018
ban on advertising but what he does want

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is much stricter

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protections at the consumer level.

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He wants to advocate for consumer redress

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01:09:57,059 --> 01:09:58,794
in terms of a gambling

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ombudsman and not and I think part

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of the reason why they backed the

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affordability checks is because it's

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going to kind of plug in

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with what the SMF think should be the

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wider scheme for UK gambling to get data

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01:10:16,011 --> 01:10:17,212
sharing practices or

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01:10:17,212 --> 01:10:19,448
a data shared scheme between the

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operators and the UKGC as the big

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technical goal of the review.

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And Noyes wrote this, he aired his

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opinion in an open letter to Lisa Nandy

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01:10:37,533 --> 01:10:41,237
who is the Secretary of State for Culture

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01:10:41,237 --> 01:10:43,005
Media and Sport which has

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oversight of gambling in the UK.

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What's the government stance on this?

282
01:10:48,677 --> 01:10:50,212
Have we heard anything from

283
01:10:50,212 --> 01:10:51,847
DCMS or the Gambling Commission

284
01:10:52,014 --> 01:10:55,084
in response to Noyes' communications? Ted

285
01:10:55,084 --> 01:10:56,218
O'See have you heard anything?

286
01:10:57,186 --> 01:10:59,288
Not yet, no I don't think anything has

287
01:10:59,288 --> 01:11:01,890
come out. I think we can

288
01:11:01,890 --> 01:11:03,492
probably expect the government to

289
01:11:04,093 --> 01:11:05,995
continue toeing the line that it has done

290
01:11:05,995 --> 01:11:06,929
for a while. They wanted to

291
01:11:06,929 --> 01:11:09,565
see the recommendations of

292
01:11:09,565 --> 01:11:11,166
the Gambling Act review seen out.

293
01:11:11,533 --> 01:11:13,435
Obviously that review was a really

294
01:11:13,435 --> 01:11:14,937
lengthy process as we mentioned

295
01:11:14,937 --> 01:11:17,439
earlier. It started in December 2020,

296
01:11:17,840 --> 01:11:19,208
ended with the publication of

297
01:11:19,208 --> 01:11:21,343
the white paper in April 2023

298
01:11:21,677 --> 01:11:23,345
and the recommendations are still being

299
01:11:23,345 --> 01:11:25,214
adopted. I don't really think the

300
01:11:25,214 --> 01:11:26,048
government has much of an

301
01:11:26,148 --> 01:11:28,851
appetite, especially with loads of other

302
01:11:28,851 --> 01:11:30,853
considerations and priorities right now,

303
01:11:31,120 --> 01:11:35,324
to really get stuck back into things like

304
01:11:35,324 --> 01:11:37,860
that. The Gambling Commission has

305
01:11:37,860 --> 01:11:39,128
reiterated a lot over

306
01:11:39,128 --> 01:11:41,030
the past year or so that these financial

307
01:11:41,030 --> 01:11:42,564
risk checks shouldn't be

308
01:11:42,564 --> 01:11:43,699
considered affordability

309
01:11:43,999 --> 01:11:45,834
checks in the same sense. They're meant

310
01:11:45,834 --> 01:11:49,004
to be very light touch. I

311
01:11:49,004 --> 01:11:50,306
think it's quite confident

312
01:11:50,406 --> 01:11:52,975
that they are frictionless. However, it

313
01:11:52,975 --> 01:11:58,213
did issue a statement sometime last year,

314
01:11:59,915 --> 01:12:03,652
in September last year, where this was

315
01:12:03,652 --> 01:12:04,987
part of a wider assessment it

316
01:12:04,987 --> 01:12:06,255
was doing of looking at what

317
01:12:06,255 --> 01:12:08,357
regulatory practices and what operator

318
01:12:08,357 --> 01:12:11,994
practices might be causing the most

319
01:12:11,994 --> 01:12:14,430
customer grievances.

320
01:12:14,797 --> 01:12:17,466
And one of the things they did mention in

321
01:12:17,466 --> 01:12:19,968
there was that financial

322
01:12:19,968 --> 01:12:22,171
vulnerability checks could be

323
01:12:22,171 --> 01:12:24,673
a regulatory practice that could drive

324
01:12:24,673 --> 01:12:26,909
customers to unregulated

325
01:12:26,909 --> 01:12:29,645
platforms perhaps, which was

326
01:12:29,645 --> 01:12:30,946
something obviously the industry has been

327
01:12:30,946 --> 01:12:32,448
arguing for some time. I

328
01:12:32,448 --> 01:12:33,349
think the commission has

329
01:12:33,749 --> 01:12:35,451
kind of recognized in the past the

330
01:12:35,451 --> 01:12:37,219
potential drawbacks of

331
01:12:37,219 --> 01:12:38,387
this measure, but overall

332
01:12:39,054 --> 01:12:41,123
is quite confident in what they're doing

333
01:12:41,123 --> 01:12:42,558
with it as one of the

334
01:12:42,558 --> 01:12:44,059
flagship measures of the

335
01:12:44,226 --> 01:12:47,229
Gambling Act review. I think you're going

336
01:12:47,229 --> 01:12:48,630
to look at DCMS's

337
01:12:48,630 --> 01:12:50,466
treatment and oversight of the

338
01:12:50,466 --> 01:12:52,801
Gambling review and anytime it's asked a

339
01:12:52,801 --> 01:12:54,169
direct question, especially in

340
01:12:54,169 --> 01:12:55,170
affordability checks,

341
01:12:56,071 --> 01:13:00,876
it just reverts back to its script of we

342
01:13:00,876 --> 01:13:01,710
believe that the check

343
01:13:01,710 --> 01:13:03,011
should be proportionate

344
01:13:03,278 --> 01:13:07,216
and frictionless. And I think we're given

345
01:13:07,216 --> 01:13:10,352
any cap. We could be

346
01:13:10,352 --> 01:13:12,087
getting to an end of year where

347
01:13:12,387 --> 01:13:14,556
we were told 2026 was the year of

348
01:13:14,556 --> 01:13:18,060
application and implementation. And we've

349
01:13:18,060 --> 01:13:19,094
now reviewed the levy

350
01:13:19,695 --> 01:13:23,565
and affordability checks. I don't think

351
01:13:23,565 --> 01:13:26,568
this department's filling its mandate.

352
01:13:28,737 --> 01:13:30,506
Yeah, we don't want to open up old wounds

353
01:13:30,506 --> 01:13:32,908
of the white paper or the

354
01:13:32,908 --> 01:13:34,009
Gambling Act review, because

355
01:13:34,476 --> 01:13:36,745
I think I can speak for all of us in the

356
01:13:36,745 --> 01:13:38,046
entire industry when I say

357
01:13:38,046 --> 01:13:39,748
we spent a little bit too long

358
01:13:40,182 --> 01:13:43,352
reporting on that storyline. But Ted,

359
01:13:43,585 --> 01:13:44,887
Ted, let's go to a quick

360
01:13:44,887 --> 01:13:46,422
break and then we'll analyze

361
01:13:47,055 --> 01:13:50,426
what this means and what we can glean

362
01:13:50,426 --> 01:13:52,027
about the future. So

363
01:13:52,027 --> 01:13:52,928
join us after the break.

364
01:13:54,196 --> 01:13:58,066
Welcome back to iGaming Daily. Now, you

365
01:13:58,066 --> 01:14:01,036
know I like to sort of exaggerate a

366
01:14:01,036 --> 01:14:02,671
little bit when I write

367
01:14:02,671 --> 01:14:04,807
the scripts for these things. So I like

368
01:14:04,807 --> 01:14:05,607
to take two polar

369
01:14:05,607 --> 01:14:07,176
opposites and then invite my

370
01:14:07,676 --> 01:14:09,344
esteemed colleagues to add a little bit

371
01:14:09,344 --> 01:14:11,980
of nuance. So I guess to

372
01:14:11,980 --> 01:14:13,415
kick us off for this debate,

373
01:14:14,349 --> 01:14:16,618
Ted M, what can we read into this

374
01:14:16,618 --> 01:14:19,888
situation? Does this sort of damage the

375
01:14:19,888 --> 01:14:22,157
credibility of those

376
01:14:22,157 --> 01:14:26,128
reformists who wanted to implement these

377
01:14:26,128 --> 01:14:27,229
affordability checks

378
01:14:27,229 --> 01:14:28,864
only for them to roll

379
01:14:28,864 --> 01:14:31,967
back on their ideas a few years later? Or

380
01:14:31,967 --> 01:14:33,035
on the other hand, does it

381
01:14:33,035 --> 01:14:34,002
show that they're sort of

382
01:14:34,203 --> 01:14:36,572
empirical and data-led and follow the

383
01:14:36,572 --> 01:14:39,208
evidence? No, I agree with

384
01:14:39,208 --> 01:14:40,275
you. I think there is a bit of

385
01:14:40,275 --> 01:14:44,179
damage there. And I think if you look at

386
01:14:44,179 --> 01:14:47,950
the the SMF and the way

387
01:14:47,950 --> 01:14:50,252
that they kind of pigeonholed

388
01:14:50,252 --> 01:14:53,622
gambling and what they wanted and kind of

389
01:14:53,622 --> 01:14:55,190
did lobby out the very

390
01:14:55,190 --> 01:14:56,425
senior figures in parliament

391
01:14:56,658 --> 01:14:59,628
to support their mandates. Now to have

392
01:14:59,628 --> 01:15:04,132
that kind of, you know, to go back and

393
01:15:04,132 --> 01:15:05,434
then we're now at the

394
01:15:05,434 --> 01:15:07,603
kind of the technical phase of the

395
01:15:07,603 --> 01:15:11,206
implementation of the key

396
01:15:11,206 --> 01:15:12,708
measures of the gambling review.

397
01:15:13,308 --> 01:15:14,943
And those of them seem to be progressing

398
01:15:14,943 --> 01:15:16,111
and I don't necessarily

399
01:15:16,111 --> 01:15:17,980
think that this is just the

400
01:15:18,013 --> 01:15:22,417
fault of the UKGC. The pilot is there to,

401
01:15:22,417 --> 01:15:25,254
you know, draft out or to

402
01:15:25,254 --> 01:15:27,322
highlight the practicality

403
01:15:27,523 --> 01:15:31,260
of putting this system in place. I think

404
01:15:31,260 --> 01:15:32,294
part of the problem is that

405
01:15:32,294 --> 01:15:33,729
affordability checks sounded

406
01:15:33,762 --> 01:15:36,732
great on paper and we're now finding out

407
01:15:36,732 --> 01:15:37,833
that the practicality is much

408
01:15:37,833 --> 01:15:41,670
harder. And also that if you

409
01:15:41,904 --> 01:15:45,240
we go back to consultation is that I

410
01:15:45,240 --> 01:15:47,276
think that affordability

411
01:15:47,276 --> 01:15:48,377
checks what kind of view there's

412
01:15:48,377 --> 01:15:51,413
this kind of panacea to every issue on

413
01:15:51,413 --> 01:15:53,148
the protection of the

414
01:15:53,148 --> 01:15:55,384
general consumer. The focus

415
01:15:55,384 --> 01:15:56,752
here should have been in a much bigger

416
01:15:56,752 --> 01:15:58,353
kind of big data play,

417
01:15:58,987 --> 01:16:00,689
data sharing, or just saying,

418
01:16:00,689 --> 01:16:02,691
look, who do we think are the vulnerable

419
01:16:02,691 --> 01:16:04,226
players? What are their

420
01:16:04,226 --> 01:16:06,395
triggers? What are kind of like

421
01:16:07,296 --> 01:16:10,332
the trends that we can see in play and

422
01:16:10,332 --> 01:16:11,767
improve kind of oversight

423
01:16:11,767 --> 01:16:14,336
there? I don't think that the

424
01:16:14,336 --> 01:16:16,605
SMF presented kind of any alternatives

425
01:16:16,605 --> 01:16:19,274
other than it's affordability checks or

426
01:16:19,274 --> 01:16:20,909
the the gamma review

427
01:16:21,043 --> 01:16:26,348
is trashed. Ted or C, come jump in here

428
01:16:26,348 --> 01:16:28,450
if you want. Yeah, I think

429
01:16:28,450 --> 01:16:30,085
it's hard to disagree with

430
01:16:30,319 --> 01:16:31,954
Ted's point there, given the

431
01:16:31,954 --> 01:16:34,056
affordability checks or financial risk

432
01:16:34,056 --> 01:16:35,724
checks as they became in the

433
01:16:35,757 --> 01:16:41,663
white paper were really the main thing

434
01:16:41,663 --> 01:16:42,631
that the SMF was

435
01:16:42,631 --> 01:16:44,833
calling for all those years.

436
01:16:45,767 --> 01:16:47,169
Again, I guess it is important to

437
01:16:47,169 --> 01:16:51,106
reiterate that James Noyes has stated

438
01:16:51,106 --> 01:16:52,407
this is his opinion and

439
01:16:52,407 --> 01:16:56,011
not that of SMF. Although, I mean, to a

440
01:16:56,011 --> 01:16:56,812
lot of people it will be

441
01:16:56,812 --> 01:16:59,715
hard to separate the two,

442
01:17:00,882 --> 01:17:03,385
given his role in the think tank over the

443
01:17:03,385 --> 01:17:04,653
past few years as well.

444
01:17:05,787 --> 01:17:09,458
Yeah, it is a bit damaging to their

445
01:17:09,458 --> 01:17:10,325
arguments. Obviously, it does

446
01:17:10,325 --> 01:17:13,128
also come after not that long

447
01:17:13,128 --> 01:17:15,530
after the whole debate about taxes last

448
01:17:15,530 --> 01:17:16,398
year that I was mentioning

449
01:17:16,398 --> 01:17:18,133
earlier in the SMF's role in that.

450
01:17:18,500 --> 01:17:22,104
So I think a lot of gambling stakeholders

451
01:17:22,104 --> 01:17:24,206
might be rolling

452
01:17:24,206 --> 01:17:25,374
their eyes a bit at this.

453
01:17:27,175 --> 01:17:30,312
Yeah, absolutely. Here's another point

454
01:17:30,312 --> 01:17:32,180
that I guess would have

455
01:17:32,180 --> 01:17:33,115
been brought up by many in

456
01:17:33,115 --> 01:17:35,250
the industry during the consultation

457
01:17:35,250 --> 01:17:37,152
periods and things like that.

458
01:17:37,552 --> 01:17:39,354
This idea that affordability

459
01:17:39,588 --> 01:17:42,524
checks would be fantastic if they were

460
01:17:42,524 --> 01:17:44,826
non-intrusive, was that

461
01:17:44,826 --> 01:17:46,094
always a little bit fanciful?

462
01:17:47,462 --> 01:17:49,331
By the nature of these checks, there has

463
01:17:49,331 --> 01:17:50,332
to be some friction,

464
01:17:50,599 --> 01:17:51,933
right? Can they always be,

465
01:17:51,933 --> 01:17:54,636
or can they ever be truly frictionless?

466
01:17:55,203 --> 01:17:57,339
How can they not be intrusive, Ted or C?

467
01:17:57,372 --> 01:18:05,747
Okay. So in the white paper, the main

468
01:18:05,747 --> 01:18:07,049
thing that the Gambling

469
01:18:07,049 --> 01:18:09,484
Commission was banking on,

470
01:18:09,484 --> 01:18:12,154
no pun intended, apologies, was open

471
01:18:12,154 --> 01:18:13,689
banking and the use of that

472
01:18:13,689 --> 01:18:15,123
technology of those practices

473
01:18:15,590 --> 01:18:20,395
as a way to seamlessly share data from a

474
01:18:20,395 --> 01:18:21,663
customer, their banking

475
01:18:21,663 --> 01:18:22,964
provider and the operator

476
01:18:24,066 --> 01:18:26,935
without the need for customers to then be

477
01:18:26,935 --> 01:18:29,371
directly handing over pay

478
01:18:29,371 --> 01:18:31,273
slips and bank statements and

479
01:18:32,007 --> 01:18:34,476
proof of income and things like that,

480
01:18:34,476 --> 01:18:35,610
which a lot of personal

481
01:18:35,610 --> 01:18:36,912
information that people wouldn't be

482
01:18:36,912 --> 01:18:39,281
happy sharing with an operator or any

483
01:18:39,281 --> 01:18:43,752
other third party really. I think they

484
01:18:43,752 --> 01:18:44,753
really need to prove

485
01:18:44,753 --> 01:18:47,722
that that can work properly to prove that

486
01:18:47,722 --> 01:18:49,291
these are non-intrusive.

487
01:18:49,891 --> 01:18:51,126
But again, to many people,

488
01:18:51,393 --> 01:18:52,828
a bit like what you've just mentioned,

489
01:18:53,095 --> 01:18:57,065
Charlie, to a lot of people, the notion

490
01:18:57,065 --> 01:18:57,933
of sharing something

491
01:18:57,933 --> 01:18:59,468
via open banking is still going to come

492
01:18:59,468 --> 01:19:00,268
across as intrusive.

493
01:19:00,535 --> 01:19:02,504
People are understandably very

494
01:19:02,504 --> 01:19:04,673
protective and very cagey about sharing

495
01:19:04,673 --> 01:19:06,675
financial information, personal

496
01:19:06,675 --> 01:19:08,376
information, those sort of

497
01:19:08,376 --> 01:19:13,949
details with anyone, whether it's a major

498
01:19:13,949 --> 01:19:18,587
operator or not. It's a very

499
01:19:18,587 --> 01:19:20,455
hard thing to prove, I think,

500
01:19:20,489 --> 01:19:21,823
that they are going to be non-intrusive.

501
01:19:22,224 --> 01:19:23,125
I guess the figure though

502
01:19:23,125 --> 01:19:24,693
that the UK Gambling Commission

503
01:19:25,360 --> 01:19:28,063
will hinge on quite a lot is the fact

504
01:19:28,063 --> 01:19:30,966
that it only applies to a very, very

505
01:19:30,966 --> 01:19:32,367
small fraction of people

506
01:19:32,734 --> 01:19:35,871
who meet these thresholds. The battle

507
01:19:35,871 --> 01:19:37,072
then is just this minority

508
01:19:37,072 --> 01:19:38,206
of people whose thresholds,

509
01:19:38,406 --> 01:19:40,809
who do meet the thresholds, how can you

510
01:19:40,809 --> 01:19:41,676
prove to them that it's

511
01:19:41,676 --> 01:19:42,677
going to be non-intrusive?

512
01:19:43,178 --> 01:19:45,747
That's the big question here and it's a

513
01:19:45,747 --> 01:19:46,715
really, really difficult one.

514
01:19:47,682 --> 01:19:49,718
There's always been so many liabilities

515
01:19:49,718 --> 01:19:54,156
on that transparency of who are that,

516
01:19:54,156 --> 01:19:56,892
kind of 0.05% of people that are going to

517
01:19:56,892 --> 01:19:58,326
be chased. The

518
01:19:58,326 --> 01:20:00,829
Commission even with the pilot

519
01:20:00,829 --> 01:20:03,598
program is yet to answer that. So we

520
01:20:03,598 --> 01:20:04,399
haven't even seen it

521
01:20:04,399 --> 01:20:05,901
transferred to a live environment.

522
01:20:06,801 --> 01:20:12,741
Again, going back to that mistake where I

523
01:20:12,741 --> 01:20:16,545
think what the

524
01:20:16,545 --> 01:20:18,446
Commission fundamentally got wrong

525
01:20:19,281 --> 01:20:22,484
was that it put all its basket, put a

526
01:20:22,484 --> 01:20:23,919
significant amount of eggs

527
01:20:23,919 --> 01:20:26,555
in the basket of affordability

528
01:20:26,655 --> 01:20:29,391
shakes. That was a measure that was

529
01:20:29,391 --> 01:20:31,226
transferred from its view

530
01:20:31,226 --> 01:20:33,595
that it wanted this mandate to

531
01:20:33,695 --> 01:20:37,599
create a single view of the player in

532
01:20:37,599 --> 01:20:40,969
this decade. I think how it

533
01:20:40,969 --> 01:20:41,870
just stepped up to that program

534
01:20:41,870 --> 01:20:43,438
and said the affordability checks are

535
01:20:43,438 --> 01:20:45,674
part of that remit, not of

536
01:20:45,674 --> 01:20:47,275
the Gambling Review. I think

537
01:20:47,275 --> 01:20:50,478
that there would have been better grounds

538
01:20:50,478 --> 01:20:53,815
to test the long-term viability of

539
01:20:53,815 --> 01:20:54,850
affordability checks

540
01:20:55,183 --> 01:20:57,652
and how can you roll it out, how it's

541
01:20:57,652 --> 01:20:59,287
going to be implemented over not

542
01:20:59,287 --> 01:21:00,589
necessarily a period of

543
01:21:00,722 --> 01:21:03,024
six months, but over a period of however

544
01:21:03,024 --> 01:21:05,627
long it needed, two years, three years,

545
01:21:05,627 --> 01:21:07,395
how to get it in by the end of the decade

546
01:21:07,395 --> 01:21:09,030
and how to actually work

547
01:21:09,030 --> 01:21:12,234
with UK finance on applying the

548
01:21:12,234 --> 01:21:16,071
best checks. I think what we're learning

549
01:21:16,071 --> 01:21:17,272
here and particularly over the

550
01:21:17,272 --> 01:21:18,406
conversations that we've had

551
01:21:18,406 --> 01:21:20,342
over the last week or so, Ted, is that

552
01:21:20,342 --> 01:21:22,844
organisations just need

553
01:21:22,844 --> 01:21:24,012
to talk to each other more.

554
01:21:24,246 --> 01:21:27,215
But it seems like a very difficult task

555
01:21:27,215 --> 01:21:29,784
bringing people into a consensus.

556
01:21:33,588 --> 01:21:36,725
One outcome of this that I have thought

557
01:21:36,725 --> 01:21:40,595
about is, is this a big win for the

558
01:21:40,595 --> 01:21:42,430
industry and in particular

559
01:21:43,031 --> 01:21:45,066
the BGC, the Better New Gaming Council?

560
01:21:45,634 --> 01:21:47,335
Because over the last six

561
01:21:47,335 --> 01:21:50,138
months on the show, we've maybe

562
01:21:50,171 --> 01:21:54,776
taken a little bit of a not critical view

563
01:21:54,776 --> 01:21:56,544
of some of the BGC's

564
01:21:56,544 --> 01:21:58,313
actions, but we've questioned

565
01:21:58,880 --> 01:22:00,615
their approach sometimes. But do you

566
01:22:00,615 --> 01:22:02,717
think this is a win for the

567
01:22:02,717 --> 01:22:04,019
industry and those who have long

568
01:22:04,019 --> 01:22:05,921
argued that stringent measures would

569
01:22:05,921 --> 01:22:08,056
ultimately send players to the black

570
01:22:08,056 --> 01:22:10,358
market? Ted M, you're

571
01:22:10,358 --> 01:22:12,594
looking a little bit curious on this one.

572
01:22:12,594 --> 01:22:13,361
Do you want to take this

573
01:22:13,361 --> 01:22:14,696
one first? Well, I mean, you

574
01:22:14,729 --> 01:22:18,233
could say it's nice to say I told you so,

575
01:22:18,233 --> 01:22:20,468
but it doesn't feel like a

576
01:22:20,468 --> 01:22:24,205
win. And again, we're doing

577
01:22:24,205 --> 01:22:26,708
about the BGC and that's another

578
01:22:26,708 --> 01:22:28,843
organisation that's going through a

579
01:22:28,843 --> 01:22:30,111
transition phase at the

580
01:22:30,111 --> 01:22:33,815
moment, post gambling review, and that

581
01:22:33,815 --> 01:22:35,550
it's kind of looking at the

582
01:22:35,550 --> 01:22:38,953
next era of UK online gambling

583
01:22:39,120 --> 01:22:42,657
and what part it plays in there. And I

584
01:22:42,657 --> 01:22:43,258
think it's where

585
01:22:43,258 --> 01:22:45,093
political sensitivities like, yes,

586
01:22:45,961 --> 01:22:48,430
look, affordability checks might not work

587
01:22:48,430 --> 01:22:50,966
out, but I think that

588
01:22:50,966 --> 01:22:52,567
the BGC has to kind of

589
01:22:53,735 --> 01:22:55,837
live in these political circles and isn't

590
01:22:55,837 --> 01:22:57,572
going to rock the boat. I

591
01:22:57,572 --> 01:22:58,473
don't think there'll be kind

592
01:22:58,473 --> 01:23:03,511
of any cheers from their side. Ted or C,

593
01:23:03,511 --> 01:23:04,612
do you think that this

594
01:23:04,612 --> 01:23:07,749
whole story really is a case of

595
01:23:08,550 --> 01:23:12,487
be careful what you wish for on the side

596
01:23:12,487 --> 01:23:15,323
of the reformist side of the debate?

597
01:23:16,791 --> 01:23:18,793
Perhaps, yeah. I mean, kind of relating

598
01:23:18,793 --> 01:23:19,828
it to the question you just

599
01:23:19,828 --> 01:23:22,330
asked that Ted has mentioned,

600
01:23:23,231 --> 01:23:27,168
sorry, I'd imagine a few people in the

601
01:23:27,168 --> 01:23:27,969
industry are feeling

602
01:23:27,969 --> 01:23:29,471
vindicated, even though they won't

603
01:23:29,471 --> 01:23:31,873
be very happy to be vindicated about

604
01:23:31,873 --> 01:23:35,443
something like this as Ted alluded to.

605
01:23:37,779 --> 01:23:40,081
There's always, the industry makes this

606
01:23:40,081 --> 01:23:42,050
argument a lot and people

607
01:23:42,050 --> 01:23:43,952
often talk down of it. And we

608
01:23:43,952 --> 01:23:45,787
have said on the podcast before that we

609
01:23:45,787 --> 01:23:46,521
think sometimes the

610
01:23:46,521 --> 01:23:47,922
industry relies too heavily on

611
01:23:47,922 --> 01:23:51,860
the black market argument against over

612
01:23:51,860 --> 01:23:54,062
regulation, over taxation and stuff. But

613
01:23:54,062 --> 01:23:54,929
yeah, there is always

614
01:23:54,929 --> 01:23:56,931
that to consider the idea that if

615
01:23:56,931 --> 01:23:58,700
something has brought in the

616
01:23:58,700 --> 01:24:00,268
customers' reality badly too,

617
01:24:00,268 --> 01:24:01,803
they will look elsewhere to find the

618
01:24:01,803 --> 01:24:02,804
products that they want,

619
01:24:02,804 --> 01:24:03,805
find the betting markets that

620
01:24:03,872 --> 01:24:05,673
they want and so on. And those might be

621
01:24:05,673 --> 01:24:07,976
provided by someone that is

622
01:24:07,976 --> 01:24:10,045
unlicensed, isn't paying taxes,

623
01:24:10,045 --> 01:24:11,379
isn't subject to the same player

624
01:24:11,379 --> 01:24:13,548
protection standards and things like

625
01:24:13,548 --> 01:24:14,449
that. And ultimately

626
01:24:14,449 --> 01:24:16,217
that is more detriment of the customer

627
01:24:16,217 --> 01:24:17,685
and the market. That argument

628
01:24:17,685 --> 01:24:19,354
does have some merits to it.

629
01:24:19,788 --> 01:24:21,389
And yeah, I think some people will

630
01:24:21,389 --> 01:24:22,290
probably be feeling

631
01:24:22,290 --> 01:24:26,694
vindicated by this. But ultimately,

632
01:24:26,995 --> 01:24:29,064
this is just a statement from James

633
01:24:29,064 --> 01:24:30,732
Noyes, just this is one

634
01:24:30,732 --> 01:24:31,566
individual, this isn't

635
01:24:32,167 --> 01:24:35,703
the the Gamba reform lobby at large.

636
01:24:36,504 --> 01:24:37,338
There'll be a lot of

637
01:24:37,338 --> 01:24:38,506
people who still have arguments

638
01:24:40,074 --> 01:24:43,545
in favor of these checks. This and

639
01:24:43,545 --> 01:24:44,946
coupled with some of the

640
01:24:44,946 --> 01:24:46,848
feedback we've heard about the

641
01:24:47,115 --> 01:24:49,284
new research education and treatment levy

642
01:24:49,284 --> 01:24:51,386
and some of the

643
01:24:51,386 --> 01:24:53,121
difficult transitions that have

644
01:24:53,354 --> 01:24:56,658
come about through that. Yeah, there's

645
01:24:56,658 --> 01:24:58,393
probably a few people who like Ted said,

646
01:24:58,393 --> 01:25:02,063
will be thinking, we told you so. I think

647
01:25:02,063 --> 01:25:04,799
it just really reflects

648
01:25:04,799 --> 01:25:05,967
the complexities of some

649
01:25:05,967 --> 01:25:08,470
of these things and some of the drastic

650
01:25:08,470 --> 01:25:09,471
changes that we're seeing

651
01:25:09,471 --> 01:25:10,271
in the industry throughout

652
01:25:10,271 --> 01:25:12,707
this decade. I'm just wary that we're

653
01:25:12,707 --> 01:25:13,842
running out of time, but Ted

654
01:25:13,842 --> 01:25:16,010
M, I'll give the final word to

655
01:25:16,010 --> 01:25:19,848
you. How do you think this whole debate,

656
01:25:20,215 --> 01:25:21,449
because it is a debate and

657
01:25:21,449 --> 01:25:23,251
as Ted also says, it's just

658
01:25:23,852 --> 01:25:26,521
the voice of one person involved in this

659
01:25:26,521 --> 01:25:28,089
debate, but it is something that's

660
01:25:28,089 --> 01:25:29,224
rumbled on for a while.

661
01:25:29,924 --> 01:25:31,793
How does this reflect on the governments

662
01:25:31,793 --> 01:25:34,095
and multiple governments gambling

663
01:25:34,095 --> 01:25:35,263
regulation strategy,

664
01:25:35,597 --> 01:25:38,066
because this is an amalgamation of

665
01:25:38,066 --> 01:25:39,033
stories that we've been

666
01:25:39,033 --> 01:25:41,302
talking about over the period of,

667
01:25:42,003 --> 01:25:43,271
I mean, you could say six months, you

668
01:25:43,271 --> 01:25:43,972
could say five years.

669
01:25:44,639 --> 01:25:49,444
It's a hard question to close today's

670
01:25:49,444 --> 01:25:53,381
podcast on. I can only reflect on, and

671
01:25:53,381 --> 01:25:55,016
I'll put this back to

672
01:25:55,016 --> 01:25:57,585
Ted OC here. You can only reflect on what

673
01:25:57,585 --> 01:26:00,021
you see. And again, this is

674
01:26:00,021 --> 01:26:02,891
going back to how does DCMS

675
01:26:02,891 --> 01:26:06,127
reply anytime it gets asked the question

676
01:26:06,127 --> 01:26:06,761
about UK gambling

677
01:26:06,761 --> 01:26:09,264
regulations, it just points back to the

678
01:26:09,264 --> 01:26:11,032
gambling review and says that they're

679
01:26:11,032 --> 01:26:12,066
waiting for the measures to be

680
01:26:12,066 --> 01:26:13,835
implemented. And then they can

681
01:26:13,835 --> 01:26:16,304
just point the UK, GC and say, Hey guys,

682
01:26:16,304 --> 01:26:19,274
it's on you. And we're only

683
01:26:19,274 --> 01:26:20,441
implementing the measures that

684
01:26:20,441 --> 01:26:26,581
they wanted. It's reflective of other

685
01:26:26,581 --> 01:26:29,384
markets. And I was actually

686
01:26:29,384 --> 01:26:30,385
thinking about this today,

687
01:26:30,852 --> 01:26:33,188
and following the levy, following the tax

688
01:26:33,188 --> 01:26:35,957
fees that I think UK

689
01:26:35,957 --> 01:26:38,927
gambling is on the platform and

690
01:26:38,993 --> 01:26:42,197
it's waiting for a very, very slow train.

691
01:26:43,731 --> 01:26:46,334
And all the poor times are saying

692
01:26:46,334 --> 01:26:47,769
everything's delayed.

693
01:26:51,072 --> 01:26:53,107
Not only delayed, but destination

694
01:26:53,107 --> 01:26:55,743
unknown. You said it.

695
01:26:56,377 --> 01:27:00,014
Yeah, I think that's a great place to

696
01:27:00,014 --> 01:27:01,816
leave it. So thanks a lot,

697
01:27:01,816 --> 01:27:03,451
Ted and Ted here in the studio

698
01:27:03,518 --> 01:27:05,587
for joining me on this one today. And

699
01:27:05,587 --> 01:27:08,156
thank you to OptiMove, our sponsor for

700
01:27:08,156 --> 01:27:09,090
supporting the show.

701
01:27:09,524 --> 01:27:11,826
And thank you to our audience for tuning

702
01:27:11,826 --> 01:27:13,928
into today's episode of iGaming Daily.

703
01:27:14,529 --> 01:27:16,164
And join us again tomorrow to keep up to

704
01:27:16,164 --> 01:27:16,664
date with all the

705
01:27:16,664 --> 01:27:18,433
latest global gambling news.