UKGC: No List of Banned Gambling Markets
Regulator confirms operators are responsible for their own global legal compliance, assessing 'grey market' revenue as a risk factor.
The UK Gambling Commission does not maintain a list of restricted countries for its licensees, a Freedom of Information response confirms. Instead, the regulator expects operators to conduct their own legal due diligence for international markets, assessing revenue from 'grey markets' as a key indicator of financial risk and probity.
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The UK Gambling Commission (UKGC) does not maintain or provide a list of restricted countries where its licensed online operators are forbidden to operate. The responsibility for ensuring compliance with local laws in foreign jurisdictions rests entirely with the gambling operators themselves.
This was confirmed in a Freedom of Information (FOI) response dated 28 February 2023, in which the regulator stated it holds no recorded information on this matter. The disclosure clarifies a key aspect of the UK's regulatory framework, confirming the UKGC's focus remains on the British market.
Why This Matters
For UK consumers, this information highlights that a UKGC licence is primarily a guarantee of an operator's adherence to standards for the Great Britain market. While the Commission assesses an operator's international activities, it does not explicitly approve or prohibit operations in any specific country outside of GB.
This means an operator holding a UK licence could simultaneously be active in so-called 'grey markets'—jurisdictions where the legal status of online gambling is ambiguous or not actively enforced. The UKGC's interest in these activities is focused on the potential risk they pose to the operator's business and integrity.
Details of the Disclosure
In its response, the UKGC explained its position, stating it "does not provide a list of jurisdictions outside Great Britain that licensed operators can or cannot provide gambling services to."
Instead, the Commission expects operators to conduct their own "due diligence and put controls in place to ensure they meet legal requirements in other jurisdictions." The UKGC assesses an operator's international business model during the licensing process, focusing on two key areas:
- Financial Risk: The Commission examines the financial stability of an applicant. If a significant portion of revenue comes from grey markets that could suddenly change their laws or enforcement, it could pose a financial risk to the operator and its ability to meet its obligations in the UK.
- Operator Probity: The UKGC considers it a reflection on an operator's integrity and likelihood of responsible behaviour if they are found to be "knowingly or recklessly flouting the laws of another jurisdiction."
To facilitate this assessment, applicants for a UKGC licence must provide a detailed breakdown of the markets they serve, any licences they hold in those markets, and the percentage of total revenue generated from each one.
Industry Implications
This policy places a significant compliance burden on gambling operators, who must navigate a complex and varied patchwork of international laws. It also reveals that the UKGC's approach is not to create a simple blacklist, but to perform a more nuanced risk assessment of an operator's entire business model.
For consumers, it serves as a reminder that an operator's financial health and ethical standing can be influenced by its activities abroad. The UKGC uses the data on international revenue streams as a critical tool to evaluate whether an operator is suitable to hold a UK licence and offer services to players in Great Britain.