In this article, Andy Woods looks at the new version of the Licence Conditions and Codes of Practice (“LCCP”) and, in particular, highlights some of the key changes.
In many ways the LCCP should be the heartbeat of any gambling business and should form the basis of policies and procedures implemented by all gambling operators. The Gambling Commission (“GC”) defines the LCCP as setting out “the requirements you must meet in order to hold your operating licence and your personal licence. It is a very important part of running your business…”
It is a general requirement of the LCCP that all operators keep themselves up to date with any changes to legislation and to the LCCP and it is extremely important that operators understand that the LCCP is a changing document and updates and that amendments are made regularly, to take into account developments and innovations in the industry and to set out the most effective way of promoting the licensing objectives, in particular, promoting social responsible gambling.
The LCCP is not a “one size fits all” document, as there are sector specific sections and, if at all possible, the GC will make it clear what it expects operators to achieve in certain policies and procedures but allows them to write their own policies and procedures to deal with its requirements. What is relevant to a Mayfair Casino dealing with high stake customers may not be relevant to an operator who only trades one betting shop. However, the general principles that both will have to abide by remain the same.
The latest LCCP came into effect on 4 April 2018 and there are particular changes relating to Society Lotteries and the regulatory data that is to be provided to the Gambling Commission. These were the two matters that the Gambling Commission consulted on in 2017. There have also been minor changes to the social responsibility code provisions 3.5.3 and 3.5.4 and an update to the reference for the online portal for information at 15.3.1.
- The requirement to report the number of Suspicious Activity Reports (“SARs”) on regulatory returns has been removed and the information on discounted relationships will be collected through the key events reporting mechanism (via the eService Portal on the GC website). This change to the LCCP requires discounted relationships to be reported alongside information on SARs as key events.
- Information about game faults which result in over- or under-payment to customers needs to be reported as a key event.
- The existing requirement to report group advertising to a new jurisdiction has been widened to include a new requirement to report where there has been sustained/meaningful generation of the 3%/10% threshold being passed for the wider group.
- The definition of “low frequency lottery” has been updated to include those lotteries offered by local authorities.
- A new social responsibility code provision has been added to require operators to publish the proportion of lottery proceeds returned to the purposes of the society or local authority.
I am sure that some of the above points will come up at our seminar at The Hippodrome Casino on 8 May 2018. There are still a few places available and if you would like to come please contact firstname.lastname@example.org.
If you have any questions in the meantime on the above, please do not hesitate to contact me.