Legal Updates

Betting & Gaming sector update November 2018

Written by Andrew Cotton, Andrew Tait

Malta Update

Like many other EU jurisdictions, Malta was late in updating its AML regulations in line with the 4th Money Laundering Directive, only doing so on the 21 December 2017, well past the 26 June 2017 deadline. However it’s not alone with countries such as Ireland still without updated regulations.

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British Gambling Commission AML Enforcement

Over the past year, since the announcement by the Gambling Commission that it was starting an AML thematic review in June 2017, with follow up announcements that 17 investigations were ongoing and 5 possible licence reviews, we have waited with baited breathe. In the meantime there have been AML regulatory settlements for William Hill (Feb 18: £6.2M), 32 Red (June 18: £2.2M) and PaddyPower/Betfair (Oct 18: £2.2M), however these all related to older failures with some stemming back to 2014.

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Changes to open and fair provisions of LCCP

Although they may appear relatively minor, significant changes have been made to several licence conditions and codes of practice (“LCCP”) Following the CMA investigation into the industry. These took effect on 31 October 2018.

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Significant changes to age verification and customer identification requirements for remote operators

In its review of online gambling paper published in March 2018 the Gambling Commission set out details of two specific policy reviews and consultations on significant proposed revisions to the licence conditions and codes of practice (“LCCP”) for remote operators. Both are linked to a combination of data provided in regulatory returns and the string of enforcement casework over the past 3 years.

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Upcoming Events

AML Event, Malta, 15 January 2019
We are hosting our own AML event in Malta on 15 January 2019. If you would like to be invited, please email

ICE Totally Gaming 2019, London, 6-8 February 2019
We will be attending the show each day. If you would like to arrange a meeting or meet colleagues from other departments, please email,,,

If you need any assistance please do not hesitate to contact Andrew Tait or Andrew Cotton.

Contact the Author

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Andrew Cotton

My key specialisms are in betting & gaming, liquor licensing and regulatory law. In addition to the licensing of premises I advise clients on the UK’s remote gaming licensing regime and assist them with their applications to the UK Gambling Commission. I assist clients with a variety of regulatory compliance issues and apply my operational experience, gained in-house at the Rank Group, advising on all aspects of gambling regulation, including anti money laundering and social responsibility policies. I am a member of the International Masters of Gaming Law and the Society for the Study of Gambling.

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Andrew Tait

I have over 20 years of experience in betting & gaming, regulation & compliance, intellectual property and commercial contracts. Prior to joining Gordon Dadds regulatory solutions team in 2017, I was General Counsel & Chief Compliance Officer at Mansion Group for 10 years. My key specialisms are gambling law and regulation, compliance, governance and risk management, AML policies and procedures, IT contracts and technology licensing, entertainment and media contracts and copyright licensing, sports sponsorship agreements, ecommerce and internet law. I am a member of IMGL (International Masters of Gaming Law), GBGA (Gibraltar Betting & Gaming Association) and ICA (International Compliance Association).

Gordon Dadds