Licensed to thrill: Who regulates your online bingo site?

Online bingo is tightly regulated, and only licensed operators are able to provide real-money online bingo games to the UK market – right? Most of us would probably say so without really thinking too much about it; but delve into the licensing structures of some bingo sites, and things begin to get very complex, very quickly.

The reason why this is the case is also potentially one of the biggest changes that will take place in the industry in the next year or two: the Gambling Commission currently does not have to regulate sites in order for them to be allowed to provide online bingo games to British players.

British-Based Bingo Sites

Bingo sites that are based in the UK – which is to say, the servers on which they are hosted and the software that runs the games are all physically within British borders – must be licensed and regulated by the Gambling Commission.

This is about more than just directly protecting website members against fraud, identity theft and other activities that might be carried out on less scrupulous overseas sites, however; the UK gambling industry also supports research into problem gambling through the Responsible Gambling Trust, an independent national charity.

In certain circumstances, enforcement action is resolved through a donation to the Trust. This occurred in February 2013, when William Hill and gaming machine supplier Inspired Gaming Group self-reported an error in the game Reel King, which had led to players being given the wrong expected return percentage for their stakes.

But just how many online bingo sites are licensed by the Gambling Commission? It’s a matter of public record, but it’s still not especially easy to find out.

Looking for Licensees

The Gambling Commission website lists all organisations that hold a Gambling Commission licence to carry out physical or remote gaming in the United Kingdom, across all of the main disciplines: arcades, betting, bingo, casino, gambling software, gambling machines, lotteries and remote gaming.

However, it’s not immediately clear which category a given operator might fall into – the bingo listings include licences for ‘ancillary remote’ gaming, but that only refers to handheld wireless gaming units for use in bricks-and-mortar bingo halls. It seems that online operators either fall under ‘gambling software’ if they are providers of, for example, random number generating programs, or ‘remote gaming’ if they are an actual bingo site that runs the games themselves.

Of 83 active licensees in the ‘gambling software’ subdivision, only one – World Bingo Tech Limited – appears in the results if you filter them for the word ‘bingo’. Of 838 remote licensees, only six are listed if, again, you filter for the word ‘bingo’. This is only a name filter – so other bingo operators may be omitted if they do not have the word ‘bingo’ in their name, and there’s seemingly no way of telling which licensees operate bingo, and which operate other remote games.

Cross-Border Bingo

This already-messy picture gets even blurrier when you start looking at websites that are not based within the UK – and, therefore, do not need to be licensed by the Gambling Commission. According to the Commission itself, this constitutes the larger share of all online gambling sites accessed by the British public:

“We do not regulate all gambling websites accessible to the public in Great Britain; the majority are based and regulated overseas.”
– Gambling Commission, Who we are and what we do, April 2011
In fact, some brands you might think of as British – such as William Hill – are licensed and regulated elsewhere for their online bingo games. William Hill holds a remote gambling licence for the supply of software in the UK, yet William Hill Bingo is based in Gibraltar, and licensed and regulated there.

Being based overseas is often seen as a ‘soft touch’ approach in regulatory terms, and certain jurisdictions – notably Gibraltar – have established themselves as leading locations for cross-border gambling sites to be based. In Gibraltar’s case, gambling duty is set at just 1% of profits, compared with 15% for remote gaming sites in the UK, and 20% for UK land-based bingo. It’s not hard to see why operators would choose to be based in Gibraltar, in those terms.

There are also benefits for players, though, as Gibraltar’s licensed remote gaming operators – unlike those hidden away within the Gambling Commission’s database – are clearly and succinctly listed on the Government of Gibraltar Information Services website, including their name, former names, licensed activities and individual licence numbers.

Policing Inbound Bingo

It may come as no surprise to learn that the Gambling Commission want to change UK law to allow them to regulate not only websites that are based within Britain, but also those based overseas who provide remote gambling services to British citizens.

There are a few arguments in favour of this, but perhaps the most persuasive one – and the one that is put forwards by the Gambling Commission itself – goes as follows:

“This would mean, among other things, that all licensed operators would be required to contribute to research, education and treatment of British problem gambling and to comply with licence conditions that protect children and vulnerable adults.”
– Gambling Commission, Proposing to license remote gambling, February 2013

No date has been set yet for the Gambling (Licensing & Advertising) Bill to come into force. It is currently in draft form, and could still be subject to change, but if it is passed, it will require overseas operators to be licensed by the Gambling Commission in order to run a bingo site with access for British members, and would also be likely to see operators asked to contribute to the Responsible Gambling Trust either on an ongoing basis, or in the case of any breaches of the regulations.

The Social Factor

Clearly, online bingo is built around a complex structure – software developers provide random number generators to websites, who in turn use them to power bingo games, which in turn can be accessed by players all over the world, who may be members of a network such as Dragonfish, and may have been referred there in the first place by an affiliate or advertiser.

Bingo comparison sites and Google’s AdWords and AdSense advertising programmes mean you can find bingo promotions popping up all over the web and beyond (who could forget Jackpotjoy’s giant rubber duck?) – and yet, that still does not account for the full complexity of the online bingo universe.

That is because of the rapidly growing social gaming market, best known to many people in the form of Facebook bingo games. These may not be played for real money, but to their developers they represent a significant source of user data and advertising revenue, so they are, by no means, any less of an ‘industry’ than real-money online bingo.

Because they are not played for real money, though, these games can often get away without being regulated at all – and that raises the question of who’s policing them. If the Gambling Commission and its overseas equivalents are not involved, and the game’s developers (and Facebook as its host) have commercial interests to serve, where’s the independent oversight in the process?

Just because no money is at risk, it does not mean that ‘risk’ has been removed from the equation in all its forms – and the Gambling Commission, again, is concerned about the potential impact on Britons of play-for-free or play-for-tokens social gaming apps.

‘Self-Regulation Supports Sustainability’

At the start of 2013, Gambling Commission chairman Philip Graf expressed concern about social gaming, and particularly about whether or not it is being policed, and by whom.

“A lot depends on whether those who provide gambling-like social games consider the potential risks to players and implement the necessary responsible gambling consumer protection measures.”
– Philip Graf, January 17th 2013

He went on to say that self-regulation is actually in the best interests of the social gambling industry itself, as it lends sustainability to the business models of those operating within the sector; however, with almost anyone able to hire a software studio to develop a simple Facebook bingo app quite cheaply, many of those launching games on the site probably have little to no experience in the area of problem gaming.

Facebook’s own policies include just one short provision that specifically refers to gambling within Facebook games and applications:

“Permission from Facebook: You must not promote, or provide content referencing, facilitating, or containing online gambling, online real money games of skill or online lotteries without our written permission.”
– Rule III.A.5, Facebook Platform Policies, February 27th 2013

Facebook also only allows real-money transactions to be made via its own Facebook Payments platform, bringing at least a little confidence to the process for players, and indicating that the banking side of the social gaming arena – on Facebook, if not elsewhere – is subject to scrutiny.

Undermining Responsible Gambling

The real problem with trust in the online bingo industry – and in online gambling as a whole – is that the sheer size, scale and complexity of the sector means there will always be some untrustworthy elements at work. Any industry with so many operators, all vying for custom in a competitive market, inevitably leads some to act in ways that we might not approve of, if we were to become aware of it.

For instance, a Google search for ‘help with gambling’ on March 4th 2013 yielded the following results (click to enlarge):

The right kinds of results are there – and it’s no surprise to see Gamblers Anonymous at the top of the organic listings – but the very first result in the sponsored links is a bit of a concern. MoneyGaming have clearly bid to have their online slots site act as the landing page for an ad associated with the phrase ‘help with gambling’.

To be clear, their site is not a gambling guide; their pages are not ‘tips and tricks’ or how-to guides. MoneyGaming is an online casino. It is hard to imagine a legitimate link between that and the specific search term for which it is the top sponsored result.

That being said, Money Gaming at least has a Responsible Gaming policy of its own, which in turn links to the kinds of sites that top the organic results on Google, but any addict would have to scroll past the animated slots logos on the homepage in order to find the Responsible Gaming link in the website’s footer.

Restoring Regulatory Oversight

Trust is essential for the future success of online gambling in all its forms, but the irony is, when one website acts in an unscrupulous manner, it is the legitimate operators who suffer as a result. By addressing concerns like cross-border operations, and social and problem gambling, the Gambling Commission is helping to crack down on those who would seek to undermine the industry’s stability.

Some operators may see a Responsible Gambling policy as a marketing tool, but that doesn’t make them any less valuable to members who begin to feel a compulsion to wager beyond what they can actually afford; and those links to support services put the necessary advice at the very heart of the online gaming process.

Ultimately, effective self-regulation of as much of the industry as possible is a sensible platform for building trust, with external regulation where required by the Gambling Commission and its international counterparts. Beyond that, players must bear some of the burden themselves, and commit to recognising when their hobby is becoming a habit – and to seeking assistance from the appropriate places if and when this occurs.

Remote Gambling Operators Licensed in Gibraltar