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Compliance Updates

Seven Commissioners Appointed to the UK Gambling Commission



Over half of UK gamblers view betting funds differently to money in their bank accounts, new research reveals
Reading Time: 4 minutes


The Secretary of State has appointed seven Commissioners to the UK Gambling Commission (UKGC).

Charles Counsell, Helen Dodds, Sheree Howard and Claudia Mortimore have been appointed for terms of five years. Lloydette Bai-Marrow, Helen Philips and David Rossington have been appointed for terms of four years.

Lloydette Bai-Marrow

Lloydette is an anti-corruption expert and economic crime lawyer. She is the Founding Partner of Parametric Global Consulting, an economic crime investigations consultancy.

Lloydette is the Chair of the Board of Spotlight on Corruption, a UK based anti-corruption charity, she sits on the Legal Panel for WhistleblowersUK and is a trustee for the Unite Foundation. She is a Member of the Conduct Committee of the Institute of Chartered Accountants in England & Wales.

Lloydette is a Senior Visiting Lecturer at the International Anti-Corruption Academy in Vienna, Austria. She is a Co-Founder and Director of the Black Women in Leadership Network (BWIL), a non-profit network committed to increasing the representation of black women in leadership and decision-making positions.

Charles Counsell OBE

Charles was Chief Executive Officer of The Pensions Regulator from April 2019 to March 2023. Prior to this he was CEO of the Money Advice Service and Executive Director of Automatic Enrolment at The Pensions Regulator.

As CEO of The Pensions Regulator, Charles developed the new corporate strategy to put the pension saver at the heart of the Regulator. He delivered their first Equality, Diversity and Inclusion Strategy and Climate Change strategies – both focused on driving change in the regulator and across the Pensions Sector.

Throughout his career, his roles have focused on setting up and delivering large change programmes requiring significant stakeholder relationship engagement: initially in the private sector and latterly in senior public sector appointments.

Helen Dodds OStJ

Helen Dodds is an international lawyer, consultant and board member. She is currently a board member of the Human Tissue Authority, a director and trustee of the St John’s Eye Hospital Group, a director of LegalUK, and an Honorary Senior Fellow of the British Institute of International and Comparative Law. Prior to this, she was a board member of the London Court of International Arbitration.

She is a qualified (now non-practising) solicitor and in her executive career she was Global Head of Legal, Dispute Resolution at Standard Chartered Bank. She has a degree in Modern History from Oxford University.

Sheree Howard

Sheree has over 25 years’ experience in the UK financial services industry with knowledge of the process of regulation and a key focus on risk management, audit and controls. Sheree is currently the Executive Director of Risk and Compliance Oversight at the Financial Conduct Authority. She is a Fellow of the Institute and Faculty of Actuaries.

Sheree has held roles in banking in areas of risk and compliance including Director of Advisory (Compliance), Commercial and Private Banking for the Royal Bank of Scotland; and Chief Risk Officer at Direct Line Group.

Sheree has been a Governor, including Chair, for more than 10 years of a maintained Special Needs School and has provided pro bono advice to a number of other charities.

Claudia Mortimore

Claudia has over 25 years’ experience of criminal law and regulation. She spent the first 10 years of her career working as a barrister then, after a career break to raise three children, prosecuted drugs, tax and money-laundering offences for the Revenue and Customs Prosecutions Office and fraudulent trading offences for the Department for Business.

Since 2013 Claudia has worked in senior positions in the Enforcement Division of the Financial Reporting Council, the body which regulates accountants, auditors and actuaries in the public interest and which sets the UK Corporate Governance and Stewardship Codes. Claudia has led major investigations into serious and complex audit and accountancy failures.

Claudia has a particular interest in Diversity and Inclusion, she has also played a key role in promoting the importance of mental health and well-being at the Financial Reporting Council.

Helen Phillips

Dr Helen Phillips is an experienced executive and non-executive, with a career spanning the public, private and not for profit sectors. Helen’s current non-executive appointments include Chair of NHS Professionals Ltd and Chair of the Chartered Insurance Institute. Helen is concluding a nine year term as Chair of Chesterfield Royal Hospital NHS Foundation Trust.

In 2015 she was appointed as a lay member of the Legal Services Board (LSB), she was appointed independent Chair in 2017, and served a six year term to 31 March 2023. She served as a non-executive director of Social Work England from 2018 to 2021. Helen has also held non-executive director roles in Higher Education and the schools sector. Previously Helen was Board Director of Yorkshire Water and Chair of Loop Customer Management Ltd, a Kelda Group subsidiary. Prior to that, her career as a regulator was as founding Chief Executive of Natural England and a Director of the Environment Agency.

Helen has a BSc in Zoology and a PhD in Environmental Science from University College Dublin. She is a Fellow of the Royal Society of Biology and a Liveryman of the Worshipful Company of Insurers.

David Rossington CB

David is a former senior civil servant. He has worked for the Department for Culture, Media and Sport (DCMS), including as Finance Director and acting Director General, and other Government departments including what is now the Department for Levelling Up, Housing and Communities.

Since stopping full time work, he has been a member of the Advisory Committee on National Records and Archives and currently serves as its Deputy Chair. He is Treasurer and Deputy Chair of Stoll, a charity for veterans and Treasurer of Arts at the Old Fire Station, an Oxford community arts charity.

David holds a degree in History and French from Oxford, a Masters in Public Policy from the Kennedy School, Harvard University, and an economics MSc from Birkbeck College, London. David took an accountancy qualification while a civil servant, although is no longer in practice.

Compliance Updates

Gammix Limited slams “outrageous and unsubstantiated” €19.7m KSA penalty



Reading Time: 2 minutes


The operator vows to fight on all fronts against the Dutch regulator’s ‘unjust’ ruling.

Gammix Limited has announced its intention to contest the “outrageous and unsubstantiated” penalty handed to them by the Netherlands Gaming Authority (KSA).

In response, Gammix stated that the record €19.7m penalty imposed is based on “falsified data, extreme inaccuracy and highly suspect mathematics”.

In the ruling the regulator said that Gammix was adjudged to have allowed online gambling access for Dutch consumers, as well as not requiring age verification upon sign-up – something the company wholeheartedly disputes.

Gammix reports that accounts used to access its sites during the investigation were created in Luxembourg, with deposits made via credit card. Gammix added that such action violates the sites’ terms and conditions, specifically the provision of false information upon sign-up.

The operator asserts that the penalty, totalling €19,679,000, has been calculated using figures from a proprietary web-traffic aggregation service and a multiplier of 240 Euros per click. Gammix believes this would show turnover that doesn’t exist.

Furthermore, Gammix strongly condemns the KSA’s “mystery shopper” style of investigation, which, the operator states, is an unjust basis for this record-breaking penalty.

Phil Pearson, Director of Gammix Limited, has vowed to “fight on all fronts until it receives an apology and retraction!.

He said: “The KSA has imposed upon our company a penalty that is both outrageous and unsubstantiated. Now that we are able to talk openly about the case, we can confirm that we are fighting on all fronts as, to us, this is an extraordinary and unnecessarily heavy-handed action from a regulator that many already regarded as unapproachable.

“When we received the first notice of a possible penalty, we reached out to them to say we have blocks in place. We also asked for any information they had that was material to the investigation, to ensure we remained in compliance with all guidelines  – a request they appeared to ignore. Our lawyers also approached the regulator, in writing, to gain more information, but again no response was forthcoming.

“We had enabled a block on Cloudflare for any Dutch IP, we have no Dutch language or direct Dutch payment methods, and categorically do not target Dutch traffic. If affiliates list any of our brands on Dutch-facing sites, we cannot be held responsible for those promotions. However, once players reached the end site, they would not be able to register an account.”

Pearson concluded: “This fine is an absolute joke, and we will contest this in every possible way, at every possible turn. We will only rest once this outrageous penalty has been rescinded and we have received the apology we deserve.”



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Compliance Updates

BHA Chief Executive Julie Harrington Statement Following Parliamentary Debate on Affordability Checks



Reading Time: < 1 minute


BHA Chief Executive Julie Harrington has issued the following statement after MPs debated the impact of affordability checks.

“Yesterday’s debate on the impact of affordability checks on British racing has shone a light on a hugely important issue for our sport.

“It was vital that MPs were given proper parliamentary time to thoroughly interrogate the Government’s proposals and we were encouraged by the high turnout for a Westminster Hall debate.

“Many MPs made valuable contributions to the debate, and we are sure that Sports Minister Stuart Andrew will have listened with interest to the views expressed.

“From MPs of all parties and all sides of the debate, there was a clear recognition of the need for the Government to protect and support British racing when reviewing gambling legislation.

“If our sport is to remain a healthy industry, supporting jobs in the rural economy and remaining competitive with our international rivals, we hope that Government will heed this advice.

“We were encouraged by Minister Andrew ruling out the use of job titles and postcodes in the implementation of enhanced spending checks and confirming that these changes will at least be subject to a genuine pilot.

“We will continue to make the case into the heart of Government that the impact of these checks both on our industry and racing bettors needs to be carefully considered and look forward to further discussions on this important issue for British racing with the Gambling Commission and DCMS.”

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Compliance Updates

Ensuring Integrity: The Role of Assurance in the Gambling Industry



Ensuring Integrity: The Role of Assurance in the Gambling Industry
Reading Time: 2 minutes


By Salvador Garcia-Noblejas, Senior Regulatory Assurance Services at ComplianceOne Group

The gambling industry has its origins in the ancient period, and different types of games are found in almost every culture and civilization.

Over the last few years, we have witnessed an immense transformation, clearly boosted by technological developments. Among these changes, online gambling has grown rapidly, and with this new non-face-to-face reality, regulation and regulators have also embraced new ways to protect players, businesses, and the overall economy. Regulators have the responsibility to set the framework of common rules that define what is right and wrong, the means to protect all parties, and the tools that must be used when anyone does not behave as expected.

Assurance in a world of global risks

It would be inaccurate to assume that regulatory assurance’s only goal is to ensure that operators operate in a fair and transparent manner and meet their legal obligations. On the contrary, assurance also includes helping businesses understand the risks involved in the industry where they operate, analysing their strengths and weaknesses, and setting measures to mitigate those risks.

Assurance’s starting point consists of an interview phase where tailor-made questionnaires serve better understanding the reality to each operator and its actual circumstances. Once the assurance assessment is complete, a detailed action plan assists the operator in fixing any identified gaps, improving policies and procedures, and obtaining the maximum financial gain from refining their processes, products, and operations.

As part of the fast transformation of the gambling industry, with competitive new products, platforms, advertisements, and market expansion, we must not forget that bad actors and illegal practices also develop. This is the moment to ask ourselves if we are ready to face whatever can harm our operations. The most efficient way to know is carrying out a thorough audit of policies, procedures, and processes. This approach will certainly save operators from potential harm to their clients, products, brands, and finances.

Audit readiness

Regulators focus on legislation, supervision, and enforcement. All stakeholders must comply with gambling regulations if they want to offer products and services or provide a safe environment to their clients. An important part of the gambling legal system is the fact that the industry is continuously overseen to ensure that all actors adhere to the established rules. At this point, operators need to ask themselves how ready they are to show sufficient evidence that their operations adhere to the law.

Smart operators will choose to comply with as many rules and regulations as their business is capable of, and they will ensure that records are properly kept. Company leadership is essential in ensuring compliance as it contributes to collaboration between departments and having policies and procedures that make the business run within the parameters of the legislation.

Lessons learned

In recent years, some highly publicized enforcement actions, including fines and penalties, license suspension, and revocation, have alerted the whole gambling industry. From such cases, there have been increasing efforts in reviewing processes, improving systems, and growing compliance departments.

Experience in the gambling industry has taught us that it is crucial to have a detailed understanding of the regulations that govern the relationship between operators and players. Where knowledge has been insufficient, inaccurate, or out of date, some business decisions have led to unwanted consequences, sometimes catastrophic ones.

Knowledge, a solid compliance culture, strong procedures, and willingness are the formula to be ready for a regulatory audit.

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