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Gambling Censorship News


2019

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'It's for your own good'...

Australia's internet censor warns gamblers to withdraw their funds from foreign gambling websites that are just about to be blocked


Link Here11th November 2019
Full story: Internet Censorship in Australia...Wide ranging state internet censorship
Australia's internet censor will block gambling websites hosted offshore under new powers now in effect. Gamblers have been warned by The Australian Communications and Media Authority (ACMA) to withdraw their funds now from any unlicensed overseas gambling sites before they are blocked.

Internet gambling sites such as Emu Casino and FairGo Casino which are run from Curacao in the Caribbean will be among the first to be blocked, the Sydney Morning Herald reported.

ACMA said on Monday it will ask ISPs to block websites in breach of the Interactive Gambling Act 2001 using new internet censorship powers now in effect. ACMA chair Nerida O'Loughlin said

In many cases these sites refuse to pay significant winnings, or only a small portion. Customers had also experienced illegal operators continuing to withdraw funds from their bank account without authorisation. There is little to no recourse for consumers engaging with these unscrupulous operators. If you have funds deposited with an illegal gambling site, you should withdraw those funds now.

ACMA publishes a list of licensed gambling services where people can check if online gambling websites are licensed in Australia on their website.

 

 

There's a parliamentary group trying to suffocate each and very pleasure in life...

Anti-gambling MPs call for 2 pound limit for online casino bets


Link Here5th November 2019
An All Party Parliamentary Group is not an official committee it s just a group of MPs, in this case those that campaign against gambling. The Gambling Related Harm Group obviously started off from the premise that gambling is harmful. Anyway the group has just published a campaign report and accompanying press release. The group writes:

Cross Party MPs call for £2 limit on online slot machine games to tackle gambling harm

The Gambling Related Harm All-Party Parliamentary Group (GRH APPG) has called for stake and deposits limits to be introduced on online gambling products, in its interim report into the online gambling sector.

This report follows a six-month inquiry into the harms caused by online gambling. The inquiry was launched following growing disquiet among parliamentarians, charities, academics, families and individuals, at the high levels of harm caused by online gambling, in some cases tragically leading to suicide.

The report raises concerns about the lack of action from the Government and the Gambling Commission to effectively address the harms caused by the online gambling sector. This inaction has allowed the industry to continue to prey on vulnerable gamblers.

The report also highlights the disparity in content controls and stake and deposit limits between online and offline games. It notes that the Government has accepted the principle that harm can be reduced by reducing staking levels and it is clear that stake and deposit limits are needed in the online world to limit harm. The cross-party group argue that there is no justification for having slot machine style games online with staking levels above £2, in line with land based venues.

The report further notes that the Gambling Commission is looking at other aspects of regulation but has made no mention of what is clearly one of the key issues to address -- stake and prizes online. As such, the Parliamentarians have raised concerns that that the Gambling Commission is not fit for purpose.

The group calls on online gambling operators to sign its 'Charter for Regulatory Reform', to signal their intention and support for the policy proposals and recommendations, outlined in its report.

The key recommendations of the report are:

  • That the Government should urgently introduce new gambling legislation with a focus on harm prevention;

  • That stake and prize limits be urgently introduced online. The report finds no justification for online slot machine style games with staking levels above £2, as it is offline;

  • That the Gambling Commission needs to urgently improve its standards in the area of online gambling;

  • That that there is an urgent need to ban the use of credit cards to gamble online. It is inconceivable that gamblers are able to fund their addiction using debt;

  • That improved affordability checks is urgently needed and that banks be given an increased role in relation to affordability checks;

  • That VIP accounts and the inducements offered to gamblers should be restricted;

  • That online gambling operators significantly improve the measures they take to protect vulnerable and at-risk gamblers. Operators should also simplify their terms and conditions for easy comprehension;

  • That the sector needs to urgently adopt a more responsible approach to advertising to protect children and the vulnerable;

  • That a 'duty of care' be placed on gambling operators, and that they should commit to fund blocking software, offered without charge to gamblers who self-exclude from their website;

  • That the treatment of gambling addiction and support for gambling related harm, be part of the NHS remit;

  • That a 'smart statutory levy' of 1% be introduced to fund research and that the commissioning of research be transferred from GambleAware and the Gambling Commission to independent UK research councils and a public health setting.

Due to the political context, the group is yet to meet with the new Gambling Minister or any representative from the Gambling Commission. This therefore is an interim report, and the group will publish its full report after its final hearings.

 

 

UK's Child Commissioner recommends action against loot boxes, and for age verification...

Report contains little to advance progress in the child safety game, maybe the government needs to buy another and hope for better luck next time


Link Here22nd October 2019
Full story: Loot boxes in video games...Worldwide action against monetisation of video games
The argument about loot boxes being gambling is very tiresome. The debate about whether they are akin to gambling has become more important than the debate about how to keep children safe. Surely Loot boxes can be deemed an unacceptable monetisation method for children on its own merits, without trying to match apples to pears.

Longfield seems a bit new to the job, she is now calling for small games to be fully vetted by censors when this approach was given up ten years ago due to the unmanageable volume and unviable economics of expensive censors checking small games.

She is also dreaming that age verification is some sort of panacea for all societies ills. Parents generally know exactly what age their kids are, but the knowledge doesn't magically make for an idyllic childhood.

Anne Longfield, the Children's Commissioner for England, has published a report, Gaming the system' which looks at the experiences of children who play games online. The Children's Commissioner's Office commissioned the research company Revealing Reality to speak to groups of children who play online games like FIFA, Fortnite and Roblox about what they love and what worries them about gaming, both to shine a light on their experiences and to inform policy recommendations.

With 93% of children in the UK playing video games, the Children's Commissioner is today calling for new rules to tighten up gambling laws and to address the worries children have expressed about how they feel out of control of their spending on online games.

However, it also reveals the drawbacks, in particular highlighting how many children are spending money on 'in-game' purchases because they feel they have to in order to keep up with friends or to advance in the game.

The report also shows how some children feel addicted to gaming and do not feel in control of the amount of time they spend playing games. Younger children told us they are playing games for an average of two to three hours a day, whereas older children are playing for three or more hours.

To address the concerns raised by children in the report, the Children's Commissioner makes a number of recommendations, including:

  • Bringing financial harm within the scope of the Government's forthcoming online harms legislation. Developers and platforms should not enable children to progress within a game by spending money and spending should be limited to items which are not linked to performance.

  • All games which allow players to spend money should include features for players to track their historic spend, and there should be maximum daily spend limits introduced in all games which feature in-game spending and turned on by default for children.

  • The Government should take immediate action to amend the definition of gaming in section 6 of the Gambling Act 2005 to regulate loot boxes as gambling.

  • The Government's age appropriate design code must include provisions on nudge techniques and detrimental use of data, as proposed in the draft code.

  • Games that are distributed online should be subject to a legally enforceable age-rating system, just as physical games are. There should be a requirement for an additional warning to be displayed for games which facilitate in-game spending. The Government should consult on whether age ratings of all games should be moderated pre-release, just as physical games are.

  • Online games should be a key focus of digital citizenship lessons in schools, rather than lessons focusing exclusively on social media. Teachers involved in the delivery of these lessons should be familiar with how key online games that are popular with children work.

 

 

Immersive and addictive technologies report published...

Parliamentary committee whinges about the lack of age verification in games and their monetisation via loot boxes


Link Here 12th September 2019
Full story: Harmful Content...2007 Parliament Inquiry: Internet And In Video Games:

Call to regulate video game loot boxes under gambling law and ban their sale to children among measures needed to protect players, say MPs. Lack of honesty and transparency reported among representatives of some games and social media companies in giving evidence.

The wide-ranging report calls upon games companies to accept responsibility for addictive gaming disorders, protect their players from potential harms due to excessive play-time and spending, and along with social media companies introduce more effective age verification tools for users.

The immersive and addictive technologies inquiry investigated how games companies operate across a range of social media platforms and other technologies, generating vast amounts of user data and operating business models that maximise player engagement in a lucrative and growing global industry.

Sale of loot boxes to children should be banned Government should regulate loot boxes under the Gambling Act Games industry must face up to responsibilities to protect players from potential harms Industry levy to support independent research on long-term effects of gaming Serious concern at lack of effective system to keep children off age-restricted platforms and games

MPs on the Committee have previously called for a new Online Harms regulator to hold social media platforms accountable for content or activity that harms individual users. They say the new regulator should also be empowered to gather data and take action regarding addictive games design from companies and behaviour from consumers. E-sports, competitive games played to an online audience, should adopt and enforce the same duty of care practices enshrined in physical sports. Finally, the MPs say social media platforms must have clear procedures to take down misleading deep-fake videos 203 an obligation they want to be enforced by a new Online Harms regulator.

In a first for Parliament, representatives of major games including Fortnite maker Epic Games and social media platforms Snapchat and Instagram gave evidence on the design of their games and platforms.

DCMS Committee Chair Damian Collins MP said:

Social media platforms and online games makers are locked in a relentless battle to capture ever more of people's attention, time and money. Their business models are built on this, but it's time for them to be more responsible in dealing with the harms these technologies can cause for some users.

Loot boxes are particularly lucrative for games companies but come at a high cost, particularly for problem gamblers, while exposing children to potential harm. Buying a loot box is playing a game of chance and it is high time the gambling laws caught up. We challenge the Government to explain why loot boxes should be exempt from the Gambling Act.

Gaming contributes to a global industry that generates billions in revenue. It is unacceptable that some companies with millions of users and children among them should be so ill-equipped to talk to us about the potential harm of their products.

Gaming disorder based on excessive and addictive game play has been recognised by the World Health Organisation. It's time for games companies to use the huge quantities of data they gather about their players, to do more to proactively identify vulnerable gamers.

Both games companies and the social media platforms need to establish effective age verification tools. They currently do not exist on any of the major platforms which rely on self-certification from children and adults.

Social media firms need to take action against known deepfake films, particularly when they have been designed to distort the appearance of people in an attempt to maliciously damage their public reputation, as was seen with the recent film of the Speaker of the US House of Representatives, Nancy Pelosi.

Regulate 'loot boxes' under the Gambling Act:

Loot box mechanics were found to be integral to major games companies' revenues, with further evidence that they facilitated profits from problem gamblers. The Report found current gambling legislation that excludes loot boxes because they do not meet the regulatory definition failed to adequately reflect people's real-world experiences of spending in games. Loot boxes that can be bought with real-world money and do not reveal their contents in advance should be considered games of chance played for money's worth and regulated by the Gambling Act.

Evidence from gamers highlighted the loot box mechanics in Electronic Arts's FIFA series with one gamer disclosing spending of up to £1000 a year.

The Report calls for loot boxes that contain the element of chance not to be sold to children playing games and instead be earned through in-game credits. In the absence of research on potential harms caused by exposing children to gambling, it calls for the precautionary principle to apply. In addition, better labelling should ensure that games containing loot boxes carry parental advisories or descriptors outlining that they feature gambling content.

  • The Government should bring forward regulations under section 6 of the Gambling Act 2005 in the next parliamentary session to specify that loot boxes are a game of chance. If it determines not to regulate loot boxes under the Act at this time, the Government should produce a paper clearly stating the reasons why it does not consider loot boxes paid for with real-world currency to be a game of chance played for money's worth.

  • UK Government should advise PEGI to apply the existing 'gambling' content labelling, and corresponding age limits, to games containing loot boxes that can be purchased for real-world money and do not reveal their contents before purchase.

Safeguarding younger players:

With three-quarters of those aged 5 to 15 playing online games, MPs express serious concern at the lack of an effective system to keep children off age-restricted platforms and games. Evidence received highlighted challenges with age verification and suggested that some companies are not enforcing age restrictions effectively.

Legislation may be needed to protect children from playing games that are not appropriate for their age. The Report identifies inconsistencies in age-ratings stemming from the games industry's self-regulation around the distribution of games. For example, online games are not subject to a legally enforceable age-rating system and voluntary ratings are used instead. Games companies should not assume that the responsibility to enforce age-ratings applies exclusively to the main delivery platforms: all companies and platforms that are making games available online should uphold the highest standards of enforcing age-ratings.

 

 

All bets are off...

Switzerland issues its first blocking list of banned foreign gambling websites


Link Here4th September 2019
The Swiss Lottery and Betting Board has published its first censorship list of foreign gambling websites to be blocked by the country's ISPs.

The censorship follows a change to the law on online gambling intended to preserve a monopoly for Swiss gambling providers.

Over 60 foreign websites external link have been blocked to Swiss gamblers. Last June, 73% of voters approved the censorship law. The law came into effect in January but blocking of foreign gambling websites only started in August.

Swiss gamblers can bet online only with Swiss casinos and lotteries that pay tax in the country.

Foreign service providers that voluntarily withdraw from the Swiss market with appropriate measures will not be blocked.

 

 

Grand Theft Auto at The Diamond Casino and Resort...

The latest excursion from Rockstar Games courts controversy as it is set in casino where players can buy chips but can't cash them in


Link Here 26th July 2019
Grand Theft Auto Online's newest scenario is the Diamond Casino and Resort in Los Santos. And of course the games features a rather one-sided form of gambling where only the house can win.

Players can buy game money which can be used to gamble at the tables of the Diamond Casino. There's no mechanism to cash in any winnings for real money, but presumably it can be used elsewhere in the game. But just like the real world, players can certainly lose and may be tempted to spend more real money in a forlorn hope of winning their losses back.

Given that loot boxes are causing so much controversy around the world, then this latest venture is surely asking for trouble. Forbes comments:

And in the sense that gambling is the sort of thing that can lead to problematic behavior, it's not hard to imagine how these new mechanics could start causing people with addictive personalities some issues.

Reddit has published a list of 50 countries where online gambling has been banned, and it is speculating that these could lead to the game being blocked in those countries. And indeed there have already been reports of the game being blocked in several countries, but these reports seem in need of confirmation.

 

 

Gambling on internet blocking...

Switzerland preserves gambling monopoly by blocking foreign competition


Link Here25th June 2019
Swiss gamblers will be able to bet online only with an approved monopoly of casinos and lotteries.

The provision of the new Swiss gambling law which restricts online gambling to a few authorised Swiss-based casinos comes into effect on July 1.

Last June 73% of voters approved the overhaul of the country's gambling law despite claims by opponents of government censorship.

A list of unauthorised gambling providers will be published on the websites of the Federal Gaming Commission external link and the Lotteries and Betting Commission external link . Those on the blacklist will be automatically blocked by Swiss ISPs by means of DNS blocks.

Swiss gamblers signed up with foreign casinos will have to contact them directly for any money due as Swiss regulators have no jurisdiction over them. Or perhaps they will continue to use foreign websites using VPNs or encrypted DNS courtesy of Firefoox

 

 

A date with a censor...

ASA bans William Hill advert suggesting that betting may help in finding friends


Link Here15th May 2019

A paid-for message from William Hill seen on the dating app Tinder, on 11 March 2019, stated:

Stuck in the friend zone? You won't be for much longer if you use this Cheltenham free bet offer. Join William Hill with code W40 and bet £10 on any Cheltenham race to get 4 X £10 free bets. T&Cs apply. This was followed by a link to download the William Hill app. Issue

A complainant challenged whether the ad breached the Code by linking gambling to sexual success.

ASA Assessment: Complaint upheld

The CAP Code required that marketing communications for gambling must be socially responsible and that they must not link gambling to seduction, sexual success or enhanced attractiveness. The ASA acknowledged that William Hill had removed the ad. However, we considered that the text Stuck in the friend zone? You won't be for much longer if you use this Cheltenham free bet offer suggested that those who gambled would be more likely to develop a friendship into a sexual relationship and therefore linked gambling with sexual success. We therefore concluded that the ad breached the Code.

The ad must not appear again in the form complained about. We told William Hill to ensure they did not link gambling to sexual success.

 

 

Go straight to jail, do not pass Go, do not collect 200 pounds...

Advert censor bans online casino adverts referencing the game, Monopoly


Link Here 8th May 2019

A banner ad for Monopoly Casino, seen 7 February 2019 on the Mirror Online website, featured an image of the character Mr Monopoly and text which stated Monopoly Casino, SUPER MONOPOLY MONEY and PLAY NOW.

A complainant challenged whether the ad was likely to be of particular appeal to children.

Entertaining Play t/a Monopoly Casino did not believe the Mr Monopoly character was of particular appeal to children. They outlined that the character was depicted as shown since the inception of the Monopoly brand, with the character shown in traditional, adult attire. Monopoly Casino said that the character did not possess exaggerated features and did not mimic any style of cartoon character seen in current children's programming. The characterisation of Mr Monopoly as a traditionally dressed older gentleman was a conscious decision in recognition of the character's universal appeal. In relation to the ad's background, Monopoly Casino said that the colours used were not garish or overly vibrant and did not draw inspiration from youth culture.

Monopoly Casino highlighted that they had also taken actions to target the ad only to those aged over 18 years of age.

The Mirror Online also said that age targeting could be applied to the ad so that it was not targeted at children. They did not believe the ad had appeal to children and they said that the ad included a label which stated 18+.

ASA Assessment: Complaint upheld

The CAP Code stated that gambling ads must not be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture. Gambling ads could not therefore appeal more to under-18s than they did to over-18s.

The ASA understood that Monopoly Casino had taken steps to target the ad only at those over 18 years of age. However, the steps taken could not ensure that under-18s were not exposed to the ad and we therefore considered whether it complied with the Code's requirement that gambling ads must not be of particular appeal to children.

The ad's branding referenced a regular edition of the board-game Monopoly, and included two red and white Monopoly logos. We considered that Monopoly was a family game generally played by or with children, and that under-18s would therefore recognise and find the ad's references to it appealing. In addition, the ad featured a prominent image of the Mr Monopoly character which had exaggerated features reminiscent of a children's cartoon, which meant the image would also be appealing to under-18s. Taking account of the ad as a whole, we considered that the use of the Monopoly logo and the depiction of the Mr Monopoly character meant that the ad was likely to appeal more to under-18s than to over-18s. We therefore concluded that the ad was of particular appeal to under-18s and breached the Code.

The ad must not appear again in the form complained about. We told Entertaining Play Ltd t/a Monopoly Casino to ensure their ads for gambling products did not have particular appeal to those under18 years of age.

 

 

Would you stake your identity on a 10 quid free bet?...

Age verification will become full identity verification for online gambling sites from 7th May


Link Here 15th April 2019
Age verification for online gambling is set to evolve into full identity verification from 7th May 2019. The other big change is that all verification will have to be completed prior to any bets being placed. Previously age verification was required only when people tried to withdraw their winnings. There were many complaints that gambling companies would then inflict onerous validation requirements to try and avoid paying out.

I would hazard a guess that the new implementation will quash an awful lot of the TV end media adverts that try and get new members with a small joiners bonus. Now it will be a lot more hassle to join, and maybe there will be less interest in trying out new websites just to get a free introductory bet.

Here is an example explanation of the new rules: see article from eyesdownbingo.com

 

 

Political correctness overrides truth...

Advert censor takes issue that sporting knowledge helps in gambling success


Link Here13th March 2019

A TV ad for Sky Bet, seen on 30 August 2018, promoting their Request a Bet service. The football presenter Jeff Stelling said, Forget 'anything can happen', in sport anything does happen. But could it be better? With Request a Bet it could. Spark your sports brain and roll all the possibilities into one bet. Three red cards, seven corners, five goals: lets price that up. Or browse hundreds of request a bets on our app. The possibilities are humongous. How big is your sports noggin? Sky Bet, Britain's most popular online bookmaker. When the fun stops, stop. A large screen behind the presenter featured various odds and statistics as well as a graphic of brain waves emanating from his head. Issue

Two complainants, who believed it implied that those with a good knowledge of sports were likely to experience gambling success, challenged whether the ad was irresponsible.

ASA Assessment: Complaints upheldd

The ad contained a number of references to the role of sports knowledge in betting, such as spark your sports brain and how big is your sports noggin. It also included a well-known sports presenter, who viewers would recognise as having a particular expertise in sports, and on-screen graphics used to depict brain waves and various odds. The ASA considered that, taking all those elements into account, the ad placed strong emphasis on the role of sports knowledge in determining betting success. We acknowledged it was the case that those with knowledge of a particular sport may be more likely to experience success when betting. However, we considered that the ad gave an erroneous perception of the extent of a gambler's control over betting success, by placing undue emphasis on the role of sports knowledge. We considered that this gave consumers an unrealistic and exaggerated perception of the level of control they would have over the outcome of a bet and that could lead to irresponsible gambling behaviour. We therefore concluded that the ad breached the Code.

The ad must not be broadcast again in the form complained of. We told Bonne Terre t/a Sky Bet to ensure in future that their ads did not condone or encourage gambling behaviour that was socially irresponsible, for example by creating an unrealistic perception of the level of control consumers would have over betting success.

 

 

Offsite Article: Breaking the bank...


Link Here25th February 2019
Norway falls back on control of bank accounts for online gambling companies so as to maintain its monopoly on gambling

See article from cryptodisrupt.com

 

 

I bet you the Gambling Commission's identity verification requirements will do more to reduce ads...

ASA publishes new requirements for gambling adverts to be restricted from being seen by under 18s


Link Here13th February 2019
ASA's rule writing arm CAP has published new standards to restrict gambling ads from being seen by under 18s.

This follows a review of the evidence on advertising's impact on under-18s and rulings by the Advertising Standards Authority. The last review was carried out in 2014.

The evidence suggests that exposure to gambling ads that comply with the UK's Advertising Codes is, of itself, unlikely to harm under-18s. Targeted restrictions are still required, however, to address the potential risks associated with irresponsible advertising. While the advertising rules don't need to change, we have introduced new standards to strengthen how they apply in practice.

The new standards:

  • prohibit online ads for gambling products being targeted at groups of individuals who are likely to be under 18 based on data about their online interests and browsing behaviour;

  • extensively list unacceptable types of content, including certain types of animated characters, licensed characters from movies or TV and sportspeople and celebrities that are likely to be of particular appeal to children, and references to youth culture; and

  • prohibit the use in gambling ads of sportspersons, celebrities or other characters who are or appear to be under 25; and

  • adds to existing guidance on the responsible targeting of ads, covering all media (including social networks and other online platforms)

In particular, the standards provide examples of scenarios to help advertisers understand what they need to do to target ads away from under-18s. For example:

Social media -- gambling operators must use all the tools available to them on a social network platform to prevent targeting their ads at under-18s. This includes both ad targeting facilities provided directly by the platform based, on their platform users' interests and browsing behaviour, and tools that restrict under-18s' access to marketers' own social media content.

Parts of websites for under-18s -- gambling operators should take particular care to avoid placing their ads on parts of websites of particular appeal to under-18s. For example, a football club's website might have a strongly adult audience in general, but it would be inappropriate to place gambling ads in pages dedicated to younger supporters.

Social and online gaming -- gambling-like games or games that feature elements of simulated gambling activity are often popular with children and young people. Such games should not be used to promote real-money gambling products. Where social and online games feature marketing communications for gambling games, they should not be directed at under-18s.

Influencers -- gambling operators should take particular care when identifying influencers to promote their products or brands. They should take into account the influencer's likely appeal and obtain audience data (for instance, the age-breakdown of a follower or subscriber-base) to ensure that under-18s are not likely to comprise more than 25% of the audience.

Affiliates -- responsibility lies with gambling operators to ensure that affiliates or other third parties acting on their behalf to publish or disseminate ads that comply with the advertising rules.

The new standards will come into force on 1 April 2019.

 

 

Next they will want to check your bank account and assess your wealth...

Gambling Commission now requires that gambling sites verify identity before allowing people to bet


Link Here 10th February 2019
The Gambling Commission (UKGC) has released a new set of rules, ensuring that operators implement a new wave of identity checks to make gambling safer and fairer.

Following an open consultation, and to further guard against the risk of children gambling, new rules mean operators must verify customer identity and age before they can either deposit funds into an account or gamble with the licensee, with either their own money or a free bet or bonus.

Furthermore, the UKGC has clamped down on free-to-play games, stressing that customer must now be age verified to access such versions gambling games on licensees' websites, emphasising that there is no legitimate reason why they should be available to children.

Changes are also designed to aid with the detection of criminal activity, whilst operators are reminded that they cannot demand that ID be submitted as a condition of cashing out, if they could have asked for that information earlier.

Finally, an increase in identifying self-excluded players was stressed, because effective verification by operators will mean that a customer will not be verified, and therefore unable to gamble, until they provide correct details. These details will then be checked against both the operator's own self-exclusion database and the verified data held by Gamstop.

Set to come into force on Tuesday 7 May, further new rules come as a result of a number of complaints to contact centre staff, regarding licensees not allowing a customer to withdraw funds until they submit certain forms of ID.

The new rules require remote licensees to:

  • Verify, as a minimum, the name, address and date of birth of a customer before allowing them to gamble
  • Ask for any additional verification information promptly
  • Inform customers, before they can deposit funds, of the types of identity documents or other information that might be required, the circumstances in which the information might be required, and how it should be supplied to the licensee
  • Take reasonable steps to ensure that information on their customers' identities remains accurate.

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