A tonic for the black market.

Few states consider a self exclusion scheme for gamblers. Most are simply ineffective. We are planning to migrate the current exclusion scheme into a multi operator arrangement. In simple terms-exclude with one – exclude with all..

Operator after operator facing stiff fines for breaches of the current arrangements. Most people take the view these companies are wholly responsible for their actions.That problem gamblers need protection (from themselves). Whilst all operators understand the new regulations I wonder at the level of regulatory action when the scheme is being so routinely abused by punters, as it is today. That’s a factor not fully appreciated.

Why? Because the current scheme was poorly constructed, allowing customers to self exclude with operators and continue to bet elsewhere. That’s a thorough nonsense, really it is, and we as operators have been left dealing with it for far too long. The new scheme is a simple hybrid of the old. And in a further un-recognised twist, we live in a world of professional bit traders and match bettors, who would think nothing of subverting bookmaker systems to cleverly exploit ‘breaches,’ – place wagers, and if lose, run to the Regulator, who very often panders to that complaint. Operators are regularly beseiged by traders, operating multiple ‘friends’ accounts, pretending to be general recreational punters, when they are in fact business users. Opening ghost accounts thereby breaching the agreement they entered into with the operator in the first place. When they are eventually caught, and restricted, they try to revenge by causing an operator issues with the Gambling Commission.

I’m no fan of any of these large betting companies. They have found themselves in breach of self exclusion schemes they took part in and helped develop. Sic.. Equally I believe the people at the Gambling Commission believe they’re doing the right thing here in editing the existing scheme. They’re not villians. But where I disagree with policy, I’m going to highlight those inconsistencies

I welcomed Sarah Harrison announcing just a year ago that the Commission would start utilising license review as opposed to the series of fines they had previously favoured. I welcomed stiffer regulation. Shortly after that?  The announcement that Ms Harrison had resigned. Most people took no interest. Not me, I was always of the opinion she was respectfully removed because her ambitions for license review didn’t sit well with Ministers, bent on business – whatever the cost in social terms. We’ll never know will we?

What’s clear is the Commission has absolutely zero appetite for license review. The Birmingham Regulator has shopped its hand on that. Pay your fine and carry on.

The latest to feel the Regulator’s intervention – Skybet. I’m no particular fan of this Alderney based company, worth 3.6 billion, who cannot seem to guarantee to lay a bet to lose £100. According to the numbers they had 50,000 self-excluded customers. 800 so called duplicated accounts were opened by those who excluded. Marketing wasn’t turned off and monies were not returned.  We are told they ‘fell on their swords’ and shopped the breaches themselves to the Commission. That is simply untrue.  If the level of unreturned funds and duplicated accounts is accurate, the Gambling Commission would have been made fully aware, by many of the customers affected, of what was going on, for many months, as they were for 888Sport. The fine though, one million to a business worth 3.5 billion betrays the Regulator’s discomfiture.

Personally I don’t view Skybet as arch criminals, I think the current SE scheme is a nonsense. The impression I get, probably driven by their Chairman, (heftily involved in several major charities) is of a company moving in the right direction socially. We need at least one major operator to break ranks from their chums and start to engage on their duties in laying bets and trying to act in a responsible manner.

But what of the 800? Were they all ‘children’ really needing protection from themselves, or just more individuals seeing an opportunity for some non risk wagering? I question whose responsibility it is in life when so many abuse a poorly framed scheme.

self 2
I’ve had many conversations with sensible folk at the Commission on Self Exclusion.  They have to be seen doing their best to assist problem gambling. They favour operators establishing air tight exclusion controls, and paying for the treatment of the same, and they have moved to a position where the operators are now responsible for people breaching exclusion orders. Ehm, when did we become the scapegoat for people’s abuse of a well-intentioned scheme?

What the Regulator does not favour, is required controls on the volume of marketing UK consumers face daily. This puts the cart before the horse on the creation of problem gamblers,  and betrays their number one mandate.

  • To create a favourable environment to keep operators operating legally in the UK.

I’ve spoken to many customers who have self excluded personally. That’s unusual insofar as most companies let them go without discussion. Most exclusion requests are grey, more often than not they’re not related to genuine problem gambling issues.

For me it’s totally necessary to engage personally with my customers. We literally have to fight for every client, because the current scheme is so widely misunderstood. It’s doubtful Skybet’s CEO has spoken to a single excluded customer. In said regard I have a somewhat unique perspective. We get people self excluding because they don’t like the colour of my website, or because I don’t offer cash out. There are as many ridiculous reasons for exclusion, as there appear to be genuine. If we engage with a customer and he says he’s self excluding for reasonings not related to problem gambling, we gently steer them towards closure, or deactivation. It’s the right thing to do. If they discuss gambling issues, any stress, we agree to discuss that instead.

What is a problem gambler? Gamble Aware say:

Problem gambling is behaviour related to gambling which causes harm to the gambler and those around them. This may include family, friends and others who know them or care for them

So the 50,000 Skybet self excluded customers fell under that description? Of course not. Most would very simply have done their money, and like everyone else in life called a temporary pause. Unfortunately the minimum period of ‘pause’ is an incredible six months long!

self 3
Two statements are absolutely true
1. There are not 50,000 problem gamblers with Skybet
2. The majority ( I estimate 80%) of those who do self exclude either return to gambling shortly after their exclusion with a company, or who never actually stop gambling at all.


This is primarily because the scheme created for operators, as well as problem gamblers is flawed to its core.


Most ‘excluded’ customers simply bet elsewhere almost immediately. In that regard it’s impossible to argue they are true problem gamblers. They are most certainly addicts.  Some will leap on that word, surely an ‘addict’ has to be stopped from gambling? Hell no!! Almost 100% of the adult population are addicted in one form or another to alcohol, smoking, shopping, drugs or gambling. Are we to intervene and attempt to control everyone’s lives? Many are quite happy to be addicts! Ever seen an alcoholic enter a bar and be refused his first drink of the night??

Do we see the regulator that makes claim to assist problem gamblers take reasonable steps to control the volume of advertising on all media platforms? No, they don’t see that as a necessary step. They’re simply NOT commited to controlling problem gambling where it could impact their unspoken mandate – to create an open gambling environment gambling operations want to perform business in. Lord Chadlington takes up my concerns below..


What the Gambling Commission gets right is in stating that an individual ‘has to take responsibility for his own actions.’ It doesn’t seem to stop them, it seems, from assuming every breach is the fault of the companies.

This leads me increasingly to the view the focus on Operators to ‘manage’ people’s problems, other than by the removal of marketing at sourse, as a deeply flawed approach. I wonder if anyone understands the variance in exclusion requests, and how difficult it is to train staff to deal with each case? The regulator now expects us to routinely lose our customers, without complaint. Further to give responsibility to ordinary folk who can never be expected to understand complex exclusion schemes the red button. With the real likelihood their next wager is with an operator in Russia.

The regulator says it will protect us from unregulated operators doing business with us right now, by taking firm legal action, against those doing business with our citizens. That’s a fiction. Bet365 have been able to operate into China for many years, and there’s apparently nothing that government can do about it. Governments in states licensing operators like Bet365 would have to agree with the Chinese to take action. Practically it doesn’t happen.



I object to the ‘nanny state’ where Governments and its regulators assume everyone to be a dribbling fool, incapable of avoiding Ray Winstone. Most of us are not that way, indeed we are grown adults in a free society and to gamble or drink is our choice. I wonder if the Commission is fully aware how may actively abuse the current scheme, because they know they can wager elsewhere? How many of the 800 or so who signed up with Skybet to gamble with them, when they previously and knowingly self excluded with the same company, were doing it to deliberately subvert the operator from its money? Open a ghost account and if lose, scream the place down. Ah, you say, does that really go on? In a world of matched bettors, who act like their above humanity, indeed- it frequently does.
And should operators be held responsible for those who intentionally breach the rules to return to gambling? I see no reason why we should. .

The Commission, for its part, does have to demonstrate a commitment to the protection of vulnerable folk. I get it. They’re moving forward with Gamstop with the multi operator scheme. What this means, for all of you out there who treat self-exclusion as a knee jerk reaction to losses and who do not see themselves as having a true gambling issue, is that if you self-exclude with Gamstop, the new body, that has a finality you’re not going to understand.

Unquestionably the black market is going to be the joyful recipient of thousands of the UK’s gamblers, who self exclude and think they can still bet a week later when Cheltenham is on. This seems to be a gamble the Commission is prepared to take. For me, it’s the number one concern, we have to keep people in a well regulated environment.

I argue the new scheme has to soften on current arrangements, if we are to bolt on the required Multi Operator element. With take a break options as a first measure for all, to give proper pause. And educational options, paid for by operators, to allow earnest gamblers who have changed their mind on exclusion to be able to return to gambling with a regulated operator. We should all share that ideal. I envisage a type of motorists penalty points course, designed to offer a managed return for gamblers, who have recovered from their ills, or just having changed their minds. We simply have to offer a managed loop hole for those who reconsider their actions.

Most certainly the terms of self exclusion cannot be so lengthy. Quite why 6 months was floated, and accepted as a minimum term is beyond me. Once again people who do not deal with gamblers coming up with arrangements affecting so many, but targeted at protection of so few. They’re addicts and they have to be seen that way. They WILL circumvent the scheme.They’re addicts and they have to be seen that way. They WILL circumvent the scheme. The minimum self-exclusion scheme should in fact be one month- to encourage people to use the arrangement and most certainly no longer than one year. A lot can happen in a year in people’s lives. It’s a lot like the Racing Post bigging up their gambling friends and then turning to the whip debate to appear socially responsible. In the same vein the Gambling Commission permits an assault of advertising, encourages offshore giants to prosper at the expense of UK operators, but thinks if it invents a draconian scheme for self-exclusion, that that makes them socially responsible.

People’s circumstances change, they should be able to change their own minds without an official telling them they cannot do so. If there is to be any gambling going on, let it be in the regulated market. Let’s understand there’s actually only a tiny element of true problem gamblers (less than 0.5%) for which we’re busy creating a scheme based on absolutism.

Neither Gamstop, nor the Commission itself has conducted surveys to ascertain how many of those who do self exclude, actually return to gambling. I feel before you make such decisions, its fairly critical to find out why people are excluding right now.
We are entering into a period, fellow gamblers, where the Regulator has decided, for better, for worse, to cast a wide net over anyone who chooses self exclusion. If you’re not seriously committed to calling a total halt to all gambling activity, best look at take a break options very seriously. As for the Commission, you’re a real tonic to the black market. It’s the UK Gambling Commission that needs to re-assess its approach.

Author: Geoff Banks Racing

UK's Leading Independent Bookmaker. We pay our tax and Levy to British Racing as an Approved Betting Partner. And no begging a proper bet here, large or small stakers welcome! Text, phone, APP or website. Private Client Wagering at its best. :)

2 thoughts on “A tonic for the black market.”

  1. The gambling commission,now where do I start,I agree with most of the above but the fact of the matter is the useless gambling commission can’t see the wood for the trees or just choose to turn a blind eye.Since its inception this useless jobs for the boys organisation helped in the near extinction of independent betting shops,by unfair policies and fee structures that favour big operators who just happen to be the worse abusers of all that’s wrong with the current state of the British betting industry,Hills get find £5million for money laundering,a drop in the ocean out of approx 300 million profits.The gambling commissions outrageous fees should be turnover based but that wouldn’t suit the high street big boys and online bluffers(try getting a license to open an online betting operation,you would have to be a multi millionaire).Everyone except the gambling commission knows that overwhelming majority of problem gamblers are online or bet in the shops on the dreaded FOBT,yet the useless gambling commission seem to be obsessed by underage gambling and money laundering on racecourses were it’s almost if not entirely non existent,ignore the REAL problem and try to find ones that don’t exsist via entrapment.Punters routinely having to take big betting operators to court to get paid out,exchanges refusing to pay out on MATCHED inrunning bets,all under the watchful eye of an organisation who’s motto believe it or not is or was keeping gambling FAIR AND OPEN,the gambling commission are not fit for purpose and need themselfs to be investigated.


    1. I do tend to agree the Gambling Commission are a rather perverse outfit, instructed by corrupt MP’s. Corrupt in that the environment they create favours offshore business and penalised UK firms.


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