W2 contributes to the GC Consultation on age and ID verification
In September of this year, the Gambling Commission launched a public consultation on age and identity verification procedures in online gambling. This reaffirms the Commission’s commitment to address underage gambling. The consultation was first outlined in Commission’s Review of online gambling back in March, and subsequently confirmed in the response to Responsible Gambling Strategy Board’s report on children, young people and gambling in June.
The consultation applies to all remote gaming and betting licensees, is open to the public, and the Commission is encouraging responses from not only current gambling license holders but also those considering applying for a licence, identity verification providers, consumers and anyone with a vested interest in gambling including those impacted by negative side of gambling.
The consultation runs until 27 November 2018 with a view to any resulting changes coming into force as early as April next year.
The proposals outlined in the cover two key areas – Age Verification and Customer Due Diligence:
1. Changes to Age Verification (AV)
At present gambling operators have 72 hours to carry out age verification checks on their customers, however, customers are not able to withdraw funds until AV checks have been completed.
This means therefore that the current process enables underage gamblers to deposit money and gamble for up to three days.
The new proposal eliminates the 72-hour period and suggests that operators should verify the ages of everyone before depositing money or playing and removes the dispensation for credit card funding. It will also apply to the majority of lotteries and instant win games which are free-to-play online via the operator website.
The Commission holds the view that although free-to-play games are not actually gambling they still promote behaviour which should not be encouraged in children and therefore AV provides a suitable deterrent to underage gamblers.
Although this may impose additional costs on the industry the commission notes that many gambling operators already perform AV checks, and innovative solutions in the AV provider market place does mean that these checks could be performed instantaneously and at low cost.
2. Changes to Customer Due Diligence (CDD)
It is generally accepted that licensees perform CDD, but this can be at varying stages of the customer lifecycle – registration, deposit, payout….etc. Therefore, accompanying the AV proposals outlined above the Commission also proposes that the licensees should bring CDD procedures to the forefront of the customer acquisition process, obtaining and verifying basic customer identification details (including name, address, date of birth and email addresses) before to allowing customers to gamble.
Licensees must also ensure that customer deposit and withdrawal methods match up with account holder details, and in-line with GDPR requirements, customers are clearly advised of the identity documents required, and when and how they will be used.
Citing the Gambling Commissions Review of online gambling (March 2018), many failings arise because operators do not know enough about their customers at an early enough stage of their relationship. These include cases where problem gamblers or criminals have gambled sums that were well in excess of what their profile would have suggested was affordable. In addition, the GC are concerned that operators may be treating their customers unfairly by requesting additional information only at the point where the customer has requested a withdrawal.
It is expected that early identification will reduce risk and enable more efficient crime detection, improve the customer experience by removing delayed withdrawals and reduce the potential harm created by exposure to gambling.
Following the precedent set previously it is unlikely that the Commission will outline how gambling operators should complete AV and CDD checks, however, operators should avail themselves of what is on the market to enable them to comply with these new measures.
As requested by the Commission, W2 Global Data will be responding to the consultation.
About W2 Global Data (W2)
W2 is an award winning provider of international Age, Identity and Anti-Money Laundering solutions. Based in the UK, but with a global footprint, we enable our customers to make timely and informed decisions through a single platform offering one of the widest range of screening solutions available on the market today.
Our work with UK regulators on the implementation of the Digital Economy Act 2017 puts us at the forefront of frictionless age verification and customer acquisition due diligence. Methods available to W2 users include traditional AV but also innovative methodologies using mobile phone and email address only, ekYC on a domestic and international scale including automated document verification and facial comparison, bank account and ownership validation, corporate due diligence and a wide range of anti-fraud mechanisms.
Our proprietary search engines and workflow logic means our customers have dynamic failover in the event of technical ‘outage’, checks can be routed to the verification method most likely to achieve a pass thus increasing match rates, and on-boarding due-diligence can be auto-linked to ongoing monitoring to maintain full regulatory compliance.
To discuss how W2 can help your business mage risk, stay compliant, reduce cost and improve the consumer journey talk to us today by getting in touch at firstname.lastname@example.org or calling 0330 088 9542.