In this second article I’m going to offer up what I believe is the best solution for all involved. The first article can be read here
Before we get into the nitty gritty it’s important to identify WHY punters feel the need to offer up anything at all. In a perfect world all that most of us want, is to have a bet and not have any Government/Regulatory interference into what we do with our own money.
But this isn’t a perfect world and having taken the time to talk and get opinion from all sides (betting professionals, recreational, industry and individuals harmed by gambling) are that systems and regulations both current and proposed – WILL NOT achieve what they set out to.
Single Customer View (SCV) is supposed to mitigate gambling harm but will end up creating a lot of friction in the ability to have a bet/deposit/withdraw funds, that we run the risk of losing many bettors to the industry, who have up to now gambled without harm. Some of these innocent souls caught up in this ‘mess of a solution’ will likely decide that it’s all too much bother and end up packing it in, or worse see that the black market will be a viable alternative.
Should SCV be the permanent and preferred method, then how does this play out for the HMRC Treasury? The protection of millions of responsible citizens wanting to place a bet and the knock-on effect on the horse-racing industry with the levy funding, not forgetting the substantial tax receipts the industry provides for the economy.
It’s time we got real about what logic determines is needed to do the things many (Gambling Commission, Campaigners and Operators) say we need to do without ending up creating a total mess, a mess that has already started to manifest itself, with many stories of accounts restricted, withdrawals restricted after winning bets. As highlighted below.
The only relationship I believe should exist between a punter and a gambling company is, “Here is my money, this is the bet I wish to place. If you’re happy to accept my stake at the price you are offering then pay me immediately if I win and if I lose keep the funds, you’re fully entitled to them”
I don’t want a Gambling Company prying into my finances, sitting on mountains of data to be shared with all and sundry (check their privacy policies, they can basically do what they like with your information) then voiding my winning bet because of some unfair term buried on page 214 of their terms and conditions, or refusing/stalling my withdrawal under the guise of Anti-Money-Laundering/Responsible Gambling protocols.
The solution that blows away the SCV is a system that works better on most counts for all parties. The ‘BET WALLET’
The ‘BET WALLET’ I would see as working as follows:
In order to be able to fund any ‘online’ gambling activity you would need to be signed up with ‘BETWALLET’. ‘BETWALLET’ could be run and integrated by anyone that wants to bid for the tender, i.e Skrill, Paypal etc They would perform basic KYC (Know Your Customer) electronically just as basic KYC is performed by many institutions (including Gambling Companies) up to now – frictionless and unintrusive. Basic KYC in most cases requires little from the customer, usually no more than a proof of identity (passport/driving licence) and proof of address (utility bill etc). This system will NOT require you to supply three months banks statements or your tax returns, savings, business banking etc – that is not its purpose. After passing KYC you would be given a maximum limit that you can deposit monthly WITHOUT providing any further information.
I would like to see the wallet consider the differences between skill betting and games of chance with different maximum thresholds for each. My own view would be £100.00 a month for games of chance e.g., casinos and £1000.00 a month for skill based e.g. sports betting (Both the wallet and operators can easily segregate funds on this basis and ensure that funds are only used for the correct products). Of course, some will get as far as that last sentence and immediately take to twitter to pour disdain on a professional punter advocating potential losses of 12k a year without checks. The limits are part of a wider discussion. However, I have arrived at that amount as that is half the average person’s yearly income in the UK today. I am simply stating my opinion here and where the limits end up should not be the focus at this stage, the focus should be on a working system and as a professional punter a £1000.00 a month limit is certainly going to cause problems for me, so I’ll immediately fall into the category of further checks anyway.
For those of us who need/require higher limits for whatever reason they will be required to submit further information. This would vary in intrusiveness depending how far up the scale they want to go. Those wanting £300.00 a month for chance or £2000.00 a month skill betting, may well find providing bank statements or accepting open banking, will be enough to prove income/wealth. On the other end of the scale a punter like myself would have to accept that my finances would be looked at in quite some detail by a senior member of staff in ‘BETWALLET’ – someone who fully understands what I am doing and sets my limits accordingly.
Once you have your wallet set up and funded you just use it the same as PayPal/Skrill etc have functioned for years. You visit your Gambling Company of choice, deposit from the ‘BET WALLET’ and hopefully withdraw to it.
The ‘BET WALLET’ is the only way of funding your activity, so when your wallet runs dry that is you done until the next deposit monthly time frame. The only thing any Gambling Company should ever require from you is basic KYC to double check the details match your “BET WALLET’ and they should have this carried out immediately on opening your account so the “We need more documents from you before processing your withdrawal” excuse goes straight out the window.
There are many advantages over and above affordability checks and invasive ‘SCV’ for you as a customer –
- You can remove and safeguard winnings by taking them out of the gambling eco-system. The funding of the wallet should be on total deposits not net deposits – therefore if your limit on sports betting is £1000.00 and you deposit £500.00 in on the 1st of the month and £500.00 on the 14th that limit has been reached. If you’ve made money that you still want “in play” you leave it in the wallet, win £5000.00 and that stays in your ‘BET WALLET’ and you have that amount fully disposable to bet with across different operators.
- Should you decide to take a break from gambling for a while you can do it through the wallet. Specify that you want your wallet locked for 24hours, one week or a month – with the wallet locked you can’t deposit so you can’t play.
- Should you decide self-exclusion is the route for you, do it via the wallet. Once you don’t have access to the wallet you’re out of the game.
- If you want to set lower deposit limits you do so via the wallet. No need to do it via every individual gambling company you deal with, just set your limit to £200.00 instead of £1000.00 for skill and that’s your global (regulated sites) limit effective immediately. Increases (up to your wallet determined maximum) are effective after 24hrs with a confirmation required by you at that time that you still wish to proceed.
- You can decide at any point to exclude across the board from certain products e.g., if you’re a sports bettor and you feel you never want to fall into the trap of casino games there is no reason within that wallet system you can’t exclude the games of chance section of the wallet whilst operating the skill side normally.
- Your sensitive financial data should you want to go above the predetermined basic KYC limits is held by one company and not many.
There will be other advantages in a system like this but I’m conscious of not letting this “article” turn into a novel, hopefully you get the idea
There ‘shouldn’t’ be resistance by Operators but their most probably will to a system like this.
In effect what they gain is knowing money entering their online business has been validated by ‘BET WALLET’ as being clean and affordable. For that portion of their business (as some have high street presence etc as well) there should not be a need for:
- AML (Anti Money Laundering) – Why would there be it’s a closed loop system money can only flow in and back through the one vehicle?
- GAMBLING COMMISSION OVERSIGHT/INTERFERENCE – certainly in respect of social responsibility/AML failures which make up the majority of fines against operators, what exactly would the Gambling Commission ever be investigating?
- SAFER GAMBLING MEASURES/SYSTEMS – Why would these be needed? The ‘safety’ has been taken care of by ‘BETWALLET’ in that you can only lose a predetermined (accepted by you the customer in advance) amount of money across all regulated sites. You know the risks when you enter the gambling arena, as are many things in life, protections have been put in place to ensure if you develop an issue with online gambling/the use of the products, that the financial damage has been limited. I’m not sure what else could be done?
I would have thought the ‘BET WALLET’ have also provided a fairly robust defence to any claim made against an operator by customers claiming they were let/coerced into spending more than they could afford?
BUT all the above is contingent on Operators not ACTUALLY wanting:
- Big Data
- To take unaffordable or ‘Bad Money’
The Gambling Commission
That’s sort of covered above. What would they be regulating? They say they are under resourced so why not streamline this whole process into one that actually works instead of headline grabbing initiatives that do nothing for anyone?
There will be pushback against an idea like this but there are logical ways of dealing with those such as:
- ‘You’re creating a payment cartel with one wallet being the only mechanism to fund a massive industry.’ There is nothing to stop the wallet being funded by debit card/PayPal/vouchers/Neteller/Skrill/Trustly etc. Nor is there anything wrong with having ten different operators running wallets if no customer can have more than one wallet, with only one provider at any given time. So, if Skrill had a wallet (they do already obviously but it needs to be Skrill2 with the extra safety features) and you want to move to PayPal’s offering, the Skrill one must be shut before PayPal can have you onboard.
- “Who will run this”? It is a business, which the powers that be can decide whether they want one or many operators, but it runs on normal commercial terms charging a fee to Gambling Companies on every transaction. There are the advantages in staffing/admin costs reductions with operators taking money from the wallet as well as mitigating social responsibility claims and dealing with the Gambling Commission. Of course, someone needs to pay for that service but as you have centralised checks within the wallet that now don’t need to be carried out by each operator, logic determines you should still be able to run the wallet, make a profit and save the operators money
- ‘Surely the fee will have to be extortionate for the wallet operator to take on the liability of people claiming they have spent too much’ – Why? Every limit set within the wallet is agreed to by the customer, the wallet operator is only providing a gateway they are not coercing or enticing you to bet?
- ‘What about all these other companies that are springing up that say they can provide services that can protect people with affordability/safer gambling and could be integrated into operator systems and/or an ombudsman’ – This might be one of the biggest problems (when it shouldn’t be) in that everyone wants more tech involved as there’s money in providing tech. We’ll touch on that more and some other things in article three, as there are certain vested interests seeming to take centre stage, despite not providing a suitable solution.
Thank you for taking the time to read.