Consultation on High Value Customers

Overview

Individuals whose gambling custom is of exceptional commercial value to licensees are often labelled as ‘VIPs’, ‘high value customers (HVC’s)’ or equivalent. That status often means those customers enjoy tailored bonuses, gifts, hospitality and preferential service from the licensee designed to maintain or increase their custom.

The management and incentivisation of these customers (referred to as ‘HVCs’ in this consultation) poses two key regulatory challenges:

1. HVCs are more heavily engaged gamblers in terms of their gambling spend, the frequency with which they gamble, or both. Heavily engaged gamblers are at greater risk of gambling-related harm.
2. The disproportionate financial value of HVCs to licensees means regulatory compliance can conflict with short-term commercial objectives.

We are concerned that these regulatory challenges have not been consistently met by licensees. This has resulted in repeated instances of gambling-related harm and in some cases, failure to prevent criminal proceeds being spent on gambling.

Evidence from our compliance and enforcement work and the feedback we have collected from consumers suggests that existing regulatory requirements that cover all customers are not being tailored and applied effectively to HVCs.

We have considered the voluntary safeguards proposed by an industry working group in April 2020. We are now proposing mandatory requirements for the management and incentivisation of HVCs.

This consultation will be of interest to licensees, consumers and consumer interest groups, charities, academics and organisations with an interest in gambling regulation.