FOI: Football Index 'Cash Policy' Was Unwritten
UKGC confirms collapsed operator Betindex had no formal, documented procedure for managing cash, referring to it as an 'unwritten practice'.
A UKGC Freedom of Information response reveals that collapsed operator Football Index had no written 'cash holding policy'. The regulator confirmed the term referred to an 'unwritten practice', highlighting a major governance failure that exposed consumers to risk.
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UKGC: Football Index 'Cash Policy' Was an Unwritten Practice
A Freedom of Information (FOI) disclosure from the UK Gambling Commission (UKGC) has revealed that collapsed operator Betindex Limited, which traded as Football Index, had no formal written "cash holding policy." The regulator confirmed the term referred to an "unwritten practice" rather than a documented procedure.
Context: The Importance of Documented Policies
The collapse of Football Index in March 2021 resulted in significant financial losses for thousands of consumers and triggered an independent review into the regulation of the firm. A cash holding policy is a critical consumer protection measure, outlining how an operator manages and segregates customer funds from its own operational capital. Such policies are designed to protect customer money in the event of a company's insolvency.
The absence of a formal, written policy means there was no clear, auditable standard for how the company managed its finances, increasing the risk for customers who had deposited funds with the platform.
Details of the Disclosure
The FOI request, dated 11 October 2023, asked the Gambling Commission for details and a copy of the Betindex "cash holding policy" covering the period from its licensing in 2015 until it entered administration in March 2021.
In its official response, the UKGC stated: "I can confirm that no recorded information falling within the scope of your request is held by the Gambling Commission."
Crucially, the Commission's response provided an explanation for this lack of documentation, noting:
In this instance, the term policy has been used to illustrate an unwritten practice rather than a physical document.
This information clarifies previous verbal statements from UKGC CEO Andrew Rhodes, who had confirmed a "policy" was in place but had not specified its format. This disclosure confirms it was never a formal, recorded procedure held by the regulator.
Significance: A Governance Failure
The revelation that a key financial process existed only as an "unwritten practice" demonstrates a significant gap in the governance and operational controls at Betindex.
For consumers, this disclosure provides important context to the wider failings that led to the company's collapse. Documented policies are a cornerstone of regulatory compliance, ensuring that procedures are clear, consistent, and can be scrutinised by the regulator. An informal practice for a function as critical as cash management highlights the risks customers were unknowingly exposed to.
The case has since prompted reviews into the UKGC's own processes and led to broader discussions about the regulation of novel gambling products and the protection of customer funds across the industry.