The Gambling Commission has been homing in on AGCs and the high street, lately. Here’s what operators need to be aware of, according to Richard Bradley, lead solicitor for licensing law firm Poppleston Allen.

We are starting to see a greater focus by the Commission on the land-based sector and last year it completed assessment work looking at the arcade industry as a whole. The Commission wrote to many licensees in November regarding its findings, highlighting priority issues aimed at raising standards. Areas for improvement included customer interaction and internal evaluation of such interactions to assess their effectiveness.

The Commission also recommended improvements in anti-money laundering risk assessments and the implementation of effective policies and procedures designed to address those risks. The Commission held several national workshops at the beginning of 2025, which aimed to provide operators with further clarity regarding its expectations. We understand that many operators were not overly impressed by those workshops, but it does identify the direction of travel.

On 20th March this year, the Gambling Commission announced that Corbett Bookmakers Limited was to pay a £686,070 penalty for social responsibility and anti-money laundering failings.

Following a two-day compliance assessment, the Commission identified that the social responsibility failures which had taken place between 2022 and 2024 included:

(i) failure to identify that a customer who had staked £23,674 in a 13-day period may be at risk of harms associated with gambling

(ii) failure to adequately interact with a customer during a four-hour session during which 56 bets were placed and a total loss of £3,523 incurred; and

(iii) failure to adequately interact with an individual who staked £47,416 and lost £6,741 over a 10-week period.

The Commission also identified that the operator’s money laundering and terrorist financing risk assessment failed to consider the full scope of risks to the business including an evaluation of customer profile, products, geographic and payment risks and that some customers were able to stake and lose significant sums without sufficient Know Your Customer evidence being obtained to verify source and legitimacy of funds due to high financial thresholds being in place.

Due diligence on customer interactions

Social responsibility code provision 3.4.1 requires that licensees interact with customers and, as a minimum, this must include identifying customers that may be at risk of, or are experiencing, harms, interacting with such customers and understanding the impact of the interaction on the customer and the effectiveness of the licensee’s actions and approach.

Most operators will have detailed policies and procedures in place, but it is often the implementation of those policies and customer controls and their internal evaluation that are criticised.

The industry has called for improved guidance on customer interaction from the Commission with the current edition not being revised since 2022. As a minimum, it would be beneficial for the Commission to provide case studies identifying best practice, as this would provide some practical clarity regarding the preferred approach in particular circumstances.

The sector is wide and varied and a standard set of criteria is unlikely to be provided to allow operational flexibility both for operators and the regulator, but the granular detail is key.

Whilst the Gambling Commission takes a risk-based approach when identifying which licenses are to undergo compliance assessments, we will start to see more compliance inspections for the sector moving forward with a possible focus on smaller operations.

Licensees should consider their procedures not only from a social responsibility perspective (customer interaction) but also the identification and evaluation of anti-money laundering risks and controls.

Key elements should include:

Setting of appropriate and effective thresholds for interaction and assessment.

Effective training of staff to ensure that interactions are made and sufficient evidence is obtained to seaport evaluations and decisions made.

Effective evaluation and assessment of interactions and potential improvements and additional mitigations.

Effective governance and oversight by key stake holders and management.

Commission compliance inspections will always seek evidence to support the whole process and decisions made and even where a risk was deemed to be low with effective mitigation implemented, detailed records must be maintained.