Free to play games - the pressure is on

**Online-casinos.co.uk** · 27 June 2019, 11:30 am

Had a couple of these emails now from different programs about demo games and age verification.

"Dear Partner,

We are sending this update to emphasise our expectations of affiliates operating in the UK market.

LeoVegas has received an informational letter from the UK Gambling Commission with additional clarifications on the recent LCCP changes on age verification:

"[...] remote licensees must now ensure that they have verified the age of any customer before the customer can access the licensee's free-to-play (F2P) games."

This means that the Commission prohibits operators benefiting from affiliates offering free-to-play games on their websites without verifying user age. By the term "free-to-play games", the Commission refers to demo versions of online slots and/or any other games in the LeoVegas UK offering. Kindly note that the above cited requirement does not apply to screenshots or videos of games as long as these do not allow interaction by the customer.

In accordance with LCCP Social responsibility code provision 1.1.2, you must conduct your operations in so far as you carry out activities on behalf of LeoVegas as if you were bound by the same license conditions and subject to the same codes of practice as LeoVegas.

To this end, in order to fully comply with our license requirements, we need Your immediate attention and assistance to provide us with a list of the sites and apps where you offer free-to-play games. Should you offer such free-to-play games, you must also provide us with a summary of the age-verification processes that are in place to prevent under age persons from accessing these free to play games.

In the event where free-to-play games are displayed on apps, you must provide more information on what age targeting is selected on Apple Store and Google Play.
If you do not display any F2P products, please do send us over such confirmation in writing."

How are people interpreting this? Is it ok to feature demo games on the site as long as the actual game doesn't link to a casino? So, ok to feature links below the game? Or should we now not have any casino links at all on demo game pages? Or even on the entire site?

Perhaps it would be best if someone came up with a quick age verification system that affiliates could use for situations like this.

**MJM** · 27 June 2019, 1:19 pm

TBH this makes sense to me. Stuff like this should be age locked at a minimum, it's too easy for minors to access. It shouldn't be that big of a challenge to age lock a page, I'm sure there is a plugin available that at least takes care of the basics.

Operators are facing serious pressure right now and as affiliates we want to make sure we aren't a "thorn" in their compliance departments. THAT is what leads the most to operators only wanting to work with big affiliates.

**universal4** · 27 June 2019, 5:52 pm

I think in the long term we will end up having to remove all free games on our sites, unless the affiliate programs offer them in a manner where they link to the operators where players can sign up immediately and play with an age verified account. The onus of correct age verification is then placed in their hands.

Sites that are nothing more then pages and pages of free games, whether stolen or originally authorized will come under serious fire and will be targeted by both operators, licensing agencies and most likely eventually software providers.

Rick
Universal4

**TheGooner** · 27 June 2019, 7:18 pm

Originally Posted by MJM

TBH this makes sense to me. Stuff like this should be age locked at a minimum, it's too easy for minors to access. It shouldn't be that big of a challenge to age lock a page, I'm sure there is a plugin available that at least takes care of the basics.

Sure if you want to just signal a basic attempt at compliance. In fact I'm sure it takes 2-3 lines of code to javascript an "are you 18?" popup box.

But I don't expect that to cut it going forward - a check in a box proves nothing unless you verify it - and are you really going to age verify visitors with documents as an affiliate?

**Renee** · 27 June 2019, 8:11 pm

I think the easiest way for affiliates to be compliant in this case is that if the player is from the UK, either show a screenshot of the game instead of the demo game, or simply don't show it at all. The UK rules for advertising can be somewhat confusing so prob better to be on the side of caution. Soon you won't be able to mention a casino name or anything about the casino. You'll see a banner farm of buttons that say "Click for a surprise" and nothing else.

**yeahfree** · 27 June 2019, 9:04 pm

if online casinos want their affiliates to age lock free to play games, they should implement that their selves in their games in my opinion. why move the implementation to all of their affiliates, while they control the source.
at this stage they are choosing the lazy route by bothering their affiliates with it (then again, not a big surprise of course)

**yeahfree** · 27 June 2019, 9:05 pm

Originally Posted by Renee

I think the easiest way for affiliates to be compliant in this case is that if the player is from the UK, either show a screenshot of the game instead of the demo game, or simply don't show it at all. The UK rules for advertising can be somewhat confusing so prob better to be on the side of caution. Soon you won't be able to mention a casino name or anything about the casino. You'll see a banner farm of buttons that say "Click for a surprise" and nothing else.

"Click for a surprise" T&Cs apply, 18+ only, fill in your date of birth to be able to continue!

**Renee** · 27 June 2019, 9:15 pm

Originally Posted by yeahfree

if online casinos want their affiliates to age lock free to play games, they should implement that their selves in their games in my opinion. why move the implementation to all of their affiliates, while they control the source.
at this stage they are choosing the lazy route by bothering their affiliates with it (then again, not a big surprise of course)

If I look at our demo games, the link is basically just serving the raw lobby of the casino in demo mode, so unless we can get MGS to impliment something inside the client (which I can tell you now is not going to happen) there's not really an option for us to do that. An affiliate could put something into their iframe/div code, but tbh I wouldn't recommend it. If for some reason the UKGC decides they don't like the way you breathed that day, they could send a fine. You're better off not showing demo games to anyone in the UK.

**TheGooner** · 27 June 2019, 11:16 pm

Originally Posted by Renee

If for some reason the UKGC decides they don't like the way you breathed that day, they could send a fine. You're better off not showing demo games to anyone in the UK.

Except it's not just UK - although that would probably satisfy the UK Gambling Commission - it's the untrained affiliate program managers that you have to keep onside. And they're a very random bunch of people.

Given the undiscriminating approach that many programs have used in waving the big BAN stick around in recent months - it's also Malta, Gibraltar, or any potential country that the affiliate program choose to use a VPN from to check that you are not offering free-to-play on your site that you need to cater for.

We simply removed all free-to-play for all countries when we got this ... too many potential mines to skip over.
Left a page stub with links to a couple of casinos on site in case it still gets hits.
eg. https://www.goonersguide.com/play_fr...ino_games.html

**yeahfree** · 28 June 2019, 6:18 am

Originally Posted by Renee

If I look at our demo games, the link is basically just serving the raw lobby of the casino in demo mode, so unless we can get MGS to impliment something inside the client (which I can tell you now is not going to happen) there's not really an option for us to do that. An affiliate could put something into their iframe/div code, but tbh I wouldn't recommend it. If for some reason the UKGC decides they don't like the way you breathed that day, they could send a fine. You're better off not showing demo games to anyone in the UK.

Good point. So that basically means that operators should knock on the doors of the software providers to let this be implemented. if an operator would still provide free to play games without any age verification in the uk to their affiliates, i think you can't really blame smaller affiliates of implementing it just like that.

I also understand that an operator can not control all demo games that an affiliate is presenting on his site, as it could be from different software providers.

i agree with you it will be better to not show demo games at all in the UK.

**Pokerface** · 28 June 2019, 6:47 am

A lot of good discussion and debate here. Personally I feel the gaming provider should be building the age check into their free play rather than each parter or affiliate having to deal with the situation in so many different ways.

**Moonlight Cat** · 28 June 2019, 10:03 am

If underage don't have access to free-to-play game - this will reduce gambling addiction*.

So i think operator must setup very strong age check.
Step 1. ID/Passport Number
Step 2. Debit Card Number
Step 3. Manualy approve documents scans.
Step 4. Interview with UKGC representative via skype.

* I think UK Ministery of Defence must setup the same restrictions to free online games where one person kill or destroy another person. By analogy this must reduce wars and violence on our planet.

**Renee** · 30 June 2019, 7:04 pm

Originally Posted by yeahfree

Good point. So that basically means that operators should knock on the doors of the software providers to let this be implemented. if an operator would still provide free to play games without any age verification in the uk to their affiliates, i think you can't really blame smaller affiliates of implementing it just like that.

I also understand that an operator can not control all demo games that an affiliate is presenting on his site, as it could be from different software providers.

i agree with you it will be better to not show demo games at all in the UK.

The problem is that everyone has to take responsibility for not abiding by the advertising standards set out by the UKGC. When affiliates stop caring about it, that's when the affiliate programs will have to start being tougher. We have already seen programs shut the door on UK affiliates because they don't want to risk being fined. Unless we want that to be the norm, it's not good enough to keep placing responsibility on the operator. If affiliates are working in the UK market, they have to take reponsibility for the content on their website.

**universal4** · 1 July 2019, 4:20 pm

Active Wins has just put out a mailing to remove all free to play games from their brands.

Hi,

As per a recent communication distributed by the Gambling Commission, we're contacting you today regarding any free-to-play games that you may host.

With immediate effect, and in order to comply with a change in the License Conditions and Code of Conduct (LCCP), please remove any free-to-play titles from your site.

Failure to comply with the LCCP, set by the Gambling Commission, is a material breach of ActiveWins programme terms and conditions, and may result in account closure if not rectified.

As ever, please don't hesitate to contact your account manager should you have any questions.

Thank you,

THE ACTIVEWINS TEAM

Rick
Universal4

**The Buzz** · 2 July 2019, 7:56 am

From a post on the U.K. Gambling Commission website yesterday:

We would like to clarify the matter of free-to-play games being available through gambling affiliates.

The LCCP changes on age verification on 7 May mean that remote licensees must now ensure that they have verified the age of any customer before the customer can access the licensee’s free-to-play games.

The Commission has been made aware that licensees may be benefitting from affiliate advertising models which offer free-to-play versions of real money games on their websites without the necessary accompanying age verification of users.

Read more here: https://www.gamblingcommission.gov.u...ffiliates.aspx

**Online-casinos.co.uk** · 2 July 2019, 10:50 am

After receiving the Active Wins notification we've reluctantly decided that there's no way around this and are going through the tedious process of removing all free to play demos from our sites.

**ivan** · 2 July 2019, 11:45 am

That's a trick to show UK customers only screenshot but the intention of the customers that landed on these pages is to play free games not contemplating the screenshot : )

**casinoportal** · 2 July 2019, 2:06 pm

I suppose if you have a UK focused site then it is a lot more difficult to try and implement something. Affiliates targeting other markets could just use geotargeting to block UK traffic from any game demo pages, not very difficult to do and will keep the UKGC happy. I'm surprised at the amount of affiliates who are still not even complying with the basic requirements, like having any sig terms displayed on their UK pages.

**Sherlock** · 2 July 2019, 2:28 pm

not very difficult to do and will keep the UKGC happy

It is good until it is not.

1st the compliance idiots can not use VPN properly if they are out of country (and even UK is outsourcing compliance to companies outside of UK and all of them use some datacenters IPs that are in geo flagged sometimes like from different country);

2nd the compliance idiots use obsolete data; just now I had a problem with one UK company that is constantly reporting something that was taken down 1+ year ago after their first request. The AM just keeps repeating he can not do anything, because the lawyers tell him we must take something non-existing down. And to the lawyers some nerd startup is reporting a problem that does not exist and no one can prove the opposite, because ... because they startup is an expert on the field. They do not provide IPs, they do not provide screenshots with timestamps... No one cares there are tons of false positive.

This is absolute nightmare.

The only solution is to divide traffic for 2 or more domains. Each one just for certain country but even after that there will be problems not to mention a lot of traffic from google will be lost.

**casinoportal** · 3 July 2019, 12:02 pm

Surely just having a form where a visitor enters their D.O.B would be enough? it's exactly the same process when a player registers at a casino, I don't think any additional verification is carried out. Obviously it can be bypassed by a visitor entering a false D.O.B, if someone wants to play and they are underage they will find a way.

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