Next 12 Months for The UK's Online Bingo & Casino Industry?

**Strutt** · 23 November 2017, 6:52 am

Hey fellow iGaming marketers, good afternoon,

Recently we've seen a huge amount of turbulence in the UK casino business recently, with great uncertainty regarding marketing conditions, and a lot more negativity expected in the next few months.

Just like a lot of you guys reading this now, I run a small family business that relies a lot on UK NGR, with lots of other business partners; friends and their families also reliant on UK NGR. I thought it would be pertinent and valuable for those of us concerned; to open a transparent debate on the topic here. As it makes sense for both operators and affiliates to share our ideas in these great times of uncertainty, so we can best protect ourselves and our families' incomes against future moves from the UK regulatory authorities; and potentially shift our business models and practices accordingly.

So to kick this conversation off, my "Struttbet" predictions for the next 12 months in the UK market would be:

1. A few of the big operators get slapped with big fines over this gaming imagery business. This will set the legal precedent, for the smaller operators to follow suit. Fingers-crossed kharma dictates that Skybet are one of those hey. Hopefully they pull all of Sky's sports betting advertising in the daytime as well, like every ad break watching live football, as this is in the same ballpark in my opinion.

2. The license holders and games providers will rightly **** their pants, and clamp down hard on all operators using their games in the UK, specifically on pre-age-verification demo games. I expect about 30%-50% of the current slots games in the UK, to be banned as demo games by Christmas e.g. they have already flagged a bunch of specific games, some do not even look child-friendly to me and that sets a precedent that they are going to be ruthless and soon publish a list of banned slots games.

3. Once the FOBT max stake legislation has properly gone through and settled....it stands to reason, they will try and port this over to online. Cue max stakes in the UK for online casino gaming

4. UK affiliates will soon require licenses. Cue the biggest butt-**** in the history of the industry, by UK gaming operators, to UK-ONLY affiliates. Smaller UK-only affiliates might find their business wiped out overnight, unless they get a license (who knows how much that will cost, and what due diligence will be required to get one?). After all, why would big operators with shareholders and greedy owners to satisfy - bother honoring "lifetime" commission, if smaller UK-only affiliates can't legally send them players anymore? It may even become illegal, for a UK-licensed operator, to send funds to a non-licensed UK affiliate in 2018.

5. Having drummed up lots of anti-gambling sentiment from the UK public - the UK Government will raise the UK POCT from 15% to 20% or 25%; to pick up a few more votes from the public; and raise more revenue from our industry to feed back into the state.

6. Maybe some other EU states will start to follow suit.

It has always been widely known that Theresa May, the current UK Prime Minister, absolutely despises online gambling - she was after all the Home Secretary that introduced the UK POCT - and she really does hate it on a personal level. So expect her to continue to wield her power. The current UK conservative government is quite happy to pick the pockets of nurses, fireman and the disabled - so expect absolutely zero mercy from them in our line of business in 2018.

Any thoughts or further points to add anyone?

Best regards,
Chris Strutt, Lucky Media
Ace Lucky Casino, Summit Casino, Gravy Train Bingo, and Full Time Affiliates Since 2010

**Madz** · 23 November 2017, 11:05 am

I hope you are wrong on all points to be honest except for number 1.

That's a depressing read though... It's all negative predictions. Why don't you throw in your hand now and be done with it all?

**Strutt** · 23 November 2017, 11:18 am

Originally Posted by Madz

I hope you are wrong on all points to be honest except for number 1.

That's a depressing read though... It's all negative predictions. Why don't you throw in your hand now and be done with it all?

Sorry its not meant to be depressing - just being realistic about the way the UK market is moving, or may move, to make our business partners in the UK aware of what might happen. A bit like a weather alert, better to have your business prepared, then see it blown over in a storm because its totally unprepared hey?

Lucky Media began shifting our business model from being 100% reliant on UK business 12 months ago, to being a business that now relies on 20% of business being UK-based in preparation.

Hopefully I'm wrong and you're right I sincerely hope so

**Madz** · 23 November 2017, 11:24 am

I do appreciate your insight, as depressing as it is

I'm started to look into other countries to promote in at the moment. The thought of starting it all again though and trying to rank sites in other countries is daunting. I'm still doing my research at the moment but any advice you can share on which countries to possible start in would be more welcomed

**Strutt** · 23 November 2017, 11:50 am

Originally Posted by Madz

I do appreciate your insight, as depressing as it is

I'm started to look into other countries to promote in at the moment. The thought of starting it all again though and trying to rank sites in other countries is daunting. I'm still doing my research at the moment but any advice you can share on which countries to possible start in would be more welcomed

It's a case of cross referencing the following mostly:

1. Size of Population (the bigger the better)
2. Number of English speakers (the more the merrier)
3. GDP / Average Earning per Person or Player (the bigger the better)
4. Number of Competitors (the less the better)
5. Legal Constraints (the less the better, as otherwise you get pigeon-holed into working with the dodgy offshore/unlicensed mobs; who I hasten to add are not necessarily any less dodgy than some of the big licensed brands with shareholders and greedy owners/management to satisfy)

Leading to markets like...
Canada, New Zealand, Finland, Norway, Sweden, Ireland
And grey markets like...
US, Australia

Consider using Google Translate also for some shoestring budget quick-fix English>Spanish>German>French localisation into other big markets!

**casionmark** · 23 November 2017, 1:33 pm

Is it really likely that affiliates will need licenses? I don't think so - license to what? Advertise a product? Is there any precedent for that in the UK?

**Strutt** · 23 November 2017, 2:00 pm

Here is the information directly, from "the horses mouth" as we say in the UK...this announcement was made on November 14th publicly by The UK Gambling Commission.

https://www.gamblingcommission.gov.uk...-gambling.aspx
https://www.gamblingcommission.gov.uk...-2018-2021.pdf
https://www.youtube.com/watch?v=ykX33m-L-q4

I would not worry too much, as I reckon some of the bigger UK affiliates will get the licenses, if required, and then perhaps white-label/sub-license/franchise them out to us smaller affiliates.

Similarly to how the casino operators like Progress Play work now - they hold one license, yet have 50+ separate smaller white label casino owners promoting them on a kinda franchise/sub-licensee basis; via separate brands/companies such as Lucky Media's own AceLuckyCasino -https://secure.gamblingcommission.gov.uk/PublicRegister/Search/Detail/39335

I'm sure the big UK affiliates will help provide a solution to us smaller affiliates this way, whilst at the same time make themselves a bit of cash at the same time.

The UK Gambling Industry has after all always prided itself on being the most regulated in the world, so I can see this is the only way they will go personally.

**casionmark** · 23 November 2017, 2:17 pm

Originally Posted by luckymedia

Here is the information directly, from "the horses mouth" as we say in the UK...this announcement was made on November 14th publicly by The UK Gambling Commission.

https://www.gamblingcommission.gov.uk...-gambling.aspx
https://www.gamblingcommission.gov.uk...-2018-2021.pdf
https://www.youtube.com/watch?v=ykX33m-L-q4

I would not worry too much, as I reckon some of the bigger UK affiliates will get the licenses, if required, and then perhaps white-label/sub-license/franchise them out to us smaller affiliates.

Similarly to how the casino operators like Progress Play work now - they hold one license, yet have 50+ separate smaller white label casino owners promoting them on a kinda franchise/sub-licensee basis; via separate brands/companies such as Lucky Media's own AceLuckyCasino -https://secure.gamblingcommission.gov.uk/PublicRegister/Search/Detail/39335

I'm sure the big UK affiliates will help provide a solution to us smaller affiliates this way, whilst at the same time make themselves a bit of cash at the same time.

The UK Gambling Industry has after all always prided itself on being the most regulated in the world, so I can see this is the only way they will go personally.

Has anyone specifically mentioned licenses? I didnt watch the whole video

Sent from my SM-G950F using Tapatalk

**LukeC** · 23 November 2017, 6:44 pm

Originally Posted by luckymedia

And grey markets like...
US, Australia

Consider using Google Translate also for some shoestring budget quick-fix English>Spanish>German>French localisation into other big markets!

USA & Australia aren't grey, lol.

**GlitzyBingo** · 24 November 2017, 2:21 am

I think its all still a very grey area at the moment but I shall watch this space....

If they did bring in licencing then this rule would surely have to apply to all independent marketing sources where gambling advertising can be seen including Bill boards, Facebook, Google, Other Search Engines, Link Directories, Television, Newspapers etc. And I can't see TV, Radio or a Newspaper brands paying a licence fee to advertise a gambling product, they will just throw on a few more Clothing and Food adverts instead. And if its to protect people from addictition then this would surely have to apply to other advertising areas such as Alcohol.. otherwise it becomes an unfair practice.

Apart from protecting minors, ensuring advertising is not misleading and capping the wagering on machines I don't think they will do anything too drastic yet (except fine those that continue to mislead consumers) plus the gambling industry brings in a lot of UK Tax especially from affiliates (well from those that pay it!) this is needed in the economy at the moment.

I do agree there needs to be some sort of regulation in the market as there have been some individuals in the past that have abused the industry by misleading consumers with fake news and offers and sending out unsolicited marketing spam which has resulted in affiliate programs to be shut down and operators to been fined.

Perhaps a licence per site would be a good idea just like a personal functional licence for croupiers and security staff in a casino, this way affiliates can work with operators more closely and the market can easily be regulated. It might even help to combat some of those blackhat seo websites I see in google quite frequently.

I still think they are scratching their heads on how to regulate the market at the moment. As I say I will still watch this space..

**casionmark** · 24 November 2017, 2:55 am

I agree - I think licensing might be tricky to implement.

Really it will come down to economics - if you can provide good quality traffic - i.e. good player values - and in volume - operators will still want to work with you. And the affiliate industry isn't going to disappear. But actions like Bet365 are taking aren't surprising really when you consider its their license and revenues at risk - and the tons of sites out there all promoting their brand without any content control to date.

Most likely will be operators will be much more selective about who they work with. The days of bedroom affiliates might be numbered, but there will still be money to be made.

**Madz** · 24 November 2017, 3:07 am

I agree with the points you both make, I still think there is still plenty more life in the industry, at the moment it's been a bit of knee **** reaction with many companies interpreting the new regulations different from the next. Hopefully it will all settle down again in the coming months and we will have a clearer idea of what the future holds.

With regards to the "bedroom affiliate" that's me at the moment. Its an office now but was originally designed to be a bedroom but I think we all have to start somewhere. As long as you abide by all the rules, pay your taxes and put in the effort in offering a good service and something of value to your visitors then it should not matter where you conduct your business.

It's still a fairly new journey all of this for me and in the last 14 months I have seen huge changes from Google, an increase in earnings and rankings, then a decrease in both, new rules and regulations from the UKGC, I have been ripped off by Sky by about 40% of my earnings, shafted by Gala Bingo, Ladbrokes, Bet Victor and Bet Fred and I'm still here and believe there is still a great future to be had from this industry, and I still love the job I do

**GlitzyBingo** · 24 November 2017, 3:24 am

I have been a bedroom affiliate (well living room affiliate) and occassional sitting on the beach affiliate for over 10 years. The only office you need is your computer.

**casionmark** · 24 November 2017, 3:30 am

Sorry, 'bedroom affiliate' is more a figure of speech

. Like you say its about the service you provide, as it always should be.

**Madz** · 24 November 2017, 3:40 am

The "beach affiliate" sounds like the best office ever

**Scampi** · 24 November 2017, 3:43 am

shafted by Gala Bingo, Ladbrokes, Bet Victor and Bet Fred

What happened with Betfred?

**LukeC** · 24 November 2017, 4:44 am

Originally Posted by GlitzyBingo

If they did bring in licencing then this rule would surely have to apply to all independent marketing sources where gambling advertising can be seen including Bill boards, Facebook, Google, Other Search Engines, Link Directories, Television, Newspapers etc. And I can't see TV, Radio or a Newspaper brands paying a licence fee to advertise a gambling product, they will just throw on a few more Clothing and Food adverts instead. And if its to protect people from addictition then this would surely have to apply to other advertising areas such as Alcohol.. otherwise it becomes an unfair practice.

I don't think licensing will happen (it is too much work for the UKGC and they have more important priorities) but this isn't the case and almost certainly won't be if it is introduced for affiliates. In New Jersey you have to have a license to be paid on a performance basis. If you are just selling media on a fixed rate you don't need a license. That's what would happen here.

**Webzcas** · 24 November 2017, 4:53 am

I am in agreement with Luke here. I will be very surprised if anyone affiliating in iGaming either based in the UK or targeting the UK will need a license. However, if it did happen, this should not be an insurmountable hurdle to overcome, even if you are a small affiliate.

On the whole, at least the actions of the UKGC so far are ensuring operators get their houses in order and actually start policing their affiliates. How mny threads have there been here on the GPWA and other forums about hacked wordpress sites and programs working hand in hand with these hackers?

Hopefully, we shall see the death of these asshole affiliates working in the UK market space. Here's hoping anyhow

**Miles_Videoslots** · 27 November 2017, 2:24 am

The UKGC was introduced to Police and Market the UK Gaming space more over it was created to protect the public against bad practice its a good thing and shouldn't be feared they are showing there teeth and putting companies in the spotlight . Its affiliate and casino companies that should be worried not affiliates in my opinion its up to us to keep your house in order and those affiliates that dont abide by the changes and reform needed are hurting their business .

**Triple7** · 27 November 2017, 3:21 am

I think the first storm is a bit over. Until the moment the fine another one. If you read the rules very carefully, almost no website is compliant. I think they will just continue with fining parties.

On the other hand, I am afraid they remain toothless against parties that are really a problem (dubious marketing tactics, crappy white label operators, etc).

For a new project, we've asked ASA to audit it. It means we're having to make some changes to the design to be compliant. Meanwhile, a lot of other websites aren't compliant at all. We choose to comply. I really think they're exaggerating in the UK, but it's a market plenty of fish and my idea is that the number of fishermen will decrease. Maybe not within 12 months, but in the long run for sure.

Affiliates need to be worried too, but more for reckless programs than for UKGC, I think. We've chosen for an audit to show to programs we're compliant. That is better than have to discuss everything again and again with every affiliate manager, legal office or compliance hero.

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