Should UK Operators Police Suppliers’ Black Market Links?

UK gambling operators are being urged to perform due diligence on their third-party suppliers to prevent involvement in illegal or black market activity. Gambling Commission CEO Andrew Rhodes highlighted this concern during a November address to industry leaders, emphasizing the need for upstream disruption in areas such as ISPs, payment providers, search engines, and software suppliers.

Rhodes stated, “The Commission’s strategy on combatting illegal gambling is to cause as much up-stream disruption as we can,” adding that operators should leverage their influence to ensure suppliers adhere to legal standards.

This directive aligns with broader regulatory efforts to curb black market activity. A report by the Betting and Gaming Council (BGC) in September revealed that up to £2.7 billion is staked annually with unregulated operators in the UK. The study also explored consumer familiarity with illegal sites and the use of VPNs to access them.

Industry Response

Rhodes’ comments sparked debate among stakeholders. Legal experts and trade bodies raised concerns about the feasibility of operators independently enforcing supplier compliance. Richard Williams of Keystone Law noted the challenges, stating, “It’s incredibly difficult for licensed operators to bring that pressure to bear on the suppliers, other than just asking a simple question.”

Similarly, Swedish trade body BOS secretary general Gustaf Hoffstedt argued that regulatory compliance is a governmental responsibility. He emphasized that the high taxes paid by the gambling sector warrant strong regulatory oversight, rather than reliance on operators to enforce due diligence.

Simon Priglinger-Simader of Germany’s DOCV trade body echoed this sentiment, stressing that regulatory bodies, not operators, should bear the responsibility of monitoring supplier activity.

A Push for B2B Licensing

One proposed solution to address the issue is the adoption of B2B licensing systems, which have been implemented in Sweden and are planned for Finland. Sweden’s licensing system, launched in 2023, aims to ensure only compliant suppliers operate in the market. Finland’s forthcoming system, set to take effect in 2026, will require suppliers to be licensed and certified, with full compliance enforced by 2028.

Priglinger-Simader expressed support for this approach, suggesting it could place greater accountability on suppliers. He remarked, “That would definitely put more pressure on them to be more compliant.”

As regulatory frameworks evolve, the question remains: should UK operators take a more active role in ensuring supplier compliance, or does this duty rest solely with the regulator?

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