Free to play games - the pressure is on

**Online-casinos.co.uk** · 3 July 2019, 12:10 pm

Originally Posted by casinoportal

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.

I've seen a couple of sites doing this already and it's something we considered but in the end thought that it would probably not satisfy the gambling commission and/or most of the affiliate programs so wasn't worth the effort of setting it up, games removed.

**Sherlock** · 3 July 2019, 12:17 pm

Of course it is not enough.
If this useless measures were enough, they would not force affiliates to do this stupidity.
It will not stop anybody at porn sites and it will not stop anybody to fill in fake age twice. I am not sure if the level of stupidity reached the peak or something else is around the corner.

The only thing that would stop minors to play even free games would be mandatory verification of identity immediately after signup. But it is obvious that nobody wants that because:
1. It would harm greatly signup/rmp ratio, because gamblers want to gamble and NOT do paperwork before
2. It would harm revenues also because casinos more and more are reluctant to pay out winnings, even in the UK, I was absolutely shocked by behavior of WH, Unibet and others when I tested them few months ago as mystery shopper

So it is obvious what is this all about. They want to do million of stupid things that will in the end not do anything for real for minor protection, but they are hoping that this will be good enough as excuse against the leftist propaganda.

**universal4** · 3 July 2019, 8:12 pm

No it's obvious that a form to enter a D.O.B. alone is not gonna be anywhere near what is required. If so most operators would recommend that and those that offer the canned game code would add it as quick as they could.

I wonder if this will clean up some of the payment delays to winners, since more verification checks might be performed at signup. At least until they design new ways and excuses to delay why payouts are not being done since verification documents will be accepted well in advance.

Over the long term I would think this will reduce the glut of sites carrying unauthorized and stolen games, but over the short term it may increase this.

Rick
Universal4

**hazartnata** · 4 July 2019, 2:32 am

It seems like UK Gambling Commission has issued a reminder to all licensees regarding age verification of customers accessing free-to-play titles, warning that they are ultimately responsible for ensuring affiliates apply such checks:

As a result, licensees must ensure the new LCCP provisions on free-to-play games are applied to gambling affiliates they employ, meaning advertising methods may need to be amended.

So we receive the warnings to remove the free play games from our Casino partners every day

**Swedenbetting** · 4 July 2019, 2:36 pm

Complicated matter this. In Sweden, the gambling commission gave hefty fines to Bethard for allowing bets on an event where players were under the age of 18. Would complicate things when you are offering bets on lower divisions, like how do keep track there, what if a sub comes on who is like twelve, "oh ****, close the live bets".
To add to this, the state-owned casino was offering bets on tennis where one of the player were 16, Im still waiting to get some tax back for that!

**universal4** · 4 July 2019, 8:59 pm

Good point swedenbetting,

Add to this the proliferation of esports where many many participants can be kids, not sure how the industry is going to react to handling betting on that either.

Rick
Universal4

**Former Member 14** · 6 July 2019, 1:32 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.

Totally agree Renee.
Adding, the UKGC has a horrible way of conveying their "rules/laws".

There's a similar thread raging over at AGD. I've just come from posting to that. So thought I'd come over here and do likewise.

Here's the UKGC demo-game laws in Black and White:
https://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2019/Free-to-play-games-being-available-through-gambling-affiliates.aspx

"LCCP Social responsibility code provision 1.1.2 states, ‘’Licensees are responsible for the actions of third parties with whom they contract for the provision of any aspect of the licensee’s business related to the licensed activities.’’ Also that licensees must “require the third party to conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same licence conditions and subject to the same codes of practice as the licensee”.

Licensees should therefore ensure the new LCCP provisions on free-to-play games are applied to gambling affiliates they employ. This may require advertising methods to be amended.

The new requirements do not apply to other forms of advertising such as screenshots or videos of games which might be available on gambling affiliate websites, as these do not allow interaction by the customer. In these cases, there is existing marketing and advertising rules as well as the Remote Technical Standards (RTS), 6A paragraph d.

The requirements do not apply to B2B suppliers who are offering demo versions of their games in order to sell them to commercial third parties, rather than consumers. Existing regulation is detailed in RTS, 6A paragraph d.

You should take steps immediately to ensure that your free-to-play games cannot be accessed by children and young people via affiliate’s websites."

The UKGC has given exemption to B2B (Business to Business) software providers. Allowing them to use an Age click-wrap nag screen, where, a person enters their Date of Birth.
If an affiliate is B2C (Business to Consumer) and promoting to the UK, even with an Age click-wrap, they are not exempted, and going on the following statement, may leave themselves open to be fined or worse, their aff account(s) terminated.

The above UKGC URL continues with this:

"If the site is targeted at consumers, we would expect free to play games to be available for play only by consumers who have been age verified. This is consistent with social responsibility code 3.2.11."

Age verified meaning: they have submitted ID docs to prove their age etc.

As The Gooner pointed out above:

Originally Posted by TheGooner

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?

EG - A child can simply enter a bogus Date-of-Birth, to access demo games on an affiliate's site promoting to the UK.

While I'm not a lawyer, I'd say these rules are pretty clear.
Unless your a B2B, then having free-demo-games on your UK facing affiliate site is a BIG NO NO, with or without an Age click-wrap.

I think where some affiliates are being mislead, pertains directly the B2B exemptions.

"The requirements do not apply to B2B suppliers who are offering demo versions of their games in order to sell them to commercial third parties, rather than consumers. Existing regulation is detailed in RTS, 6A paragraph d."

Reiterating... Unless your a B2B (Business to Business), adding an Age click-wrap to your free-demo-games is a moot point. Affiliates (B2C - Business to Consumer) are NOT exempted from these rules, even if they have an Age click wrap nag screen.

It's about your site visitors (consumers) proving they are 18+ etc., etc. Fact is... An Age Click-Wrap doesn't prove anything!

Edit:

If like myself, you don't promote to the UK, and no UK consumer can access your site from a UK IP, then these laws don't apply. And, you can continue to use demo-games on your site. Simple solution... GEOIP target, and don't allow any UK IP's to access your demo-games. Though, also using UA browser sniffer to block GB might be a good idea too

**Nenad** · 6 July 2019, 3:42 pm

We are planning to block games for UK players since getting too many emails and talking with some affiliate managers. We cannot do age verification beyond just a popup asking if they are over 18.

**casinoportal** · 7 July 2019, 9:09 am

Yeah your right a check box or where you enter your D.O.B will not be enough, however using geotargeting to block UK traffic from demo games will satisfy most affiliate programs. This is what some of the big affiliate networks are doing now, just a simple message on the demo games page with access to play the game blocked.

**Sherlock** · 7 July 2019, 3:14 pm

I repeat, this is not enough to be 100% sure. They are checking those blocks from public VPNs and those VPNs have wrong country code of IP assigned or the VPNs simply provide you false info.
So they think they are testing something from UK for example, but in fact they are connected to Germany, and you have a problem.

Indeed this satisfies the affiliate manager, but he is not doing compliance. Compliance is done by other guys, often by third parties. But they do not do it properly, like physically testing from each country.

**universal4** · 7 July 2019, 4:38 pm

I agree with Sherlock, while goip blocking may work for a while, I think it is only a matter of time where that will "not be enough".

Sure many operators may look the other way for a while, but eventually they will most likely want to curtail all demo games on all sites.

Rick
Universal4

**Sherlock** · 7 July 2019, 4:53 pm

I am doing the geoblocks, not for free games, but there are other crazy regulations (like I can not promote 5dimes in NJ, because bwin would close my account in europe and such absurd demands).

I am just saying nothing is 100% "safe". It is absurd demand to play something same. Everything is just minefield. It is important to have an AM who is not complete idiot and who understands things at least a bit. So when problem occurs, you are able to communicate with him without having account closed, adjust to what they want a bit more and move on and wait until they will demand something else (something that maybe will not be a problem at all, but they will think it is a problem).

Do not forget that for example in the UK it is not just the compliance of the sportsbook (that is outsourced) that is going after you. It is various robots and people from the ad-regulatory bodies, gambling-regulatory bodies, journalists and even police I believe. As time will go there will be just more of those ******* trying to make big issue from nothing.

**Online-casinos.co.uk** · 8 July 2019, 4:59 am

There was a nationwide age verification system for porn that was due to be introduced next week in the UK - it's been delayed for 6 months but it means there will be a new range of options for free age verification in the UK that can be easily adopted by gambling companies and even affiliates to allow access to free games:

https://www.wired.co.uk/article/uk-p...e-verification

If this kind of age verfication becomes normal in the UK for all kinds of adult content then I don't see it being a big issue for players who want to play for free, they may even prefer verifying themselves at an affiliate site so that they don't have to register with a real casino.

**Maxfalcon** · 25 July 2019, 1:21 am

Originally Posted by Online-casinos.co.uk

There was a nationwide age verification system for porn that was due to be introduced next week in the UK - it's been delayed for 6 months but it means there will be a new range of options for free age verification in the UK that can be easily adopted by gambling companies and even affiliates to allow access to free games:

https://www.wired.co.uk/article/uk-p...e-verification

If this kind of age verfication becomes normal in the UK for all kinds of adult content then I don't see it being a big issue for players who want to play for free, they may even prefer verifying themselves at an affiliate site so that they don't have to register with a real casino.

Yes, age verification in UK is now a law for porn sites since July 15th. They are also targeting this sector. Basically, you must be 100% compliant and use a robust verification system that is really tied to the user (a simple dialog box will not suffice). As a result, it now exists robust age verification system as SaaS services or website plugins that have been developped (but now they bring privacy issues with these systems, so they also must be compliant...). You can read more about the law at https://www.xbiz.com/news/243473/its...begins-july-15 (NSFW).

It is to note that other countries are monitoring the success of this in UK and are planning to implement this, for example in Spain (Prime Minister) and within South Africa (South African Law Reform Commission - SALRC). A convergence with online gambling is occuring fast.

**Former Member 14** · 25 July 2019, 2:36 am

Originally Posted by Sherlock

I am just saying nothing is 100% "safe".

I'm taking this sentence totally out of the context...

When I was a young boy and beyond:

We rode bicycles without helmets;
Built cubby-houses in trees;
Rode skateboards without protective gear;
Explored the local storm-water drain system (sometimes for miles);
Rode cardboard boxes down muddy hill sides;

The list of not safe activities my mates and I did goes on and on....

This wrapping everything in cotton-wool that's "not safe", or isn't Politically Correct, is getting to a point where, pretty soon, you wont be able to scratch yourself. The novel 1984 by George Orwell is starting to seem less fictional year by year.

**universal4** · 25 July 2019, 2:57 am

Thanks Max,

I agree that I also think many more countries will move in the same direction, and most likely only a matter of time.

Whether the age verification service will be acceptable for some of the licensing jurisdictions may or may not be ok.

In the end it may eventually mean more sign ups at the operators since potential players will have less opportunity to play without signing up even if they never planned it.

Rick
Universal4

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