Affordability, Thresholds & Customer Interaction. Are we prepared for 31st October?


Adam Doyle is TruNarrative’s Head of Gaming and a 10 year veteran of Identity and Financial Crime Management in the Gaming industry.

Here Adam outlines his thoughts on the Gambling Commission rules which online operators must follow to make gambling safer and fairer.  




Affordability, Thresholds & Customer Interaction. Are we prepared for 31st October?


It’s almost a year ago since Neil McArthur, the Chief Executive of the UK Gambling Commission, addressed the Gaming industry at the Raising Standards Conference


“I want the Gambling Commission to be the most respected gambling regulator in the world.

To achieve my aims I need your support, I need you to work together to make sure you are the best – the fairest, safest – gambling operators in the world.   I need you to work with us to put your customers, their enjoyment and their safety, at the top of your agenda.”



Prior to Neil McArthur’s speech, the new LCCP (Licence conditions and codes of practice) were implemented in October 2018. The key point for me, highlighted operators need to consider affordability in their operational risk profile.


Whilst every operator has its own risk profile, the new regulations, I believe, call for the increased use of third-party data sources including paid for and open source.



More Data, More Problems

Bringing more data into your onboarding and monitoring decisions requires alterations to Operator’s tech stack.


TruNarrative Behavioural Monitoring

 Key points that operators are now expected to carry out;


–  Have financial triggers when threshold or events occur or are met.

–  Take into account, the difference between ‘disposable income’ and ‘discretionary income’. Just knowing their salary is not enough.

–  Have tailored interactions with customers, the message being delivered and the extent of the potential harm.

–  Document ALL interactions with customers. Have detailed records showing why a particular customer decision was made and what steps were taken.

  Train and support their staff in order to assist them in carrying out effective customer interactions.


There are a lot of challenges operators face when ensuring they meet the above changes. Longer standing operators may rely on legacy platforms, meaning any changes require a significant amount of technical resources, resulting in a costly and complex implementation.

Leaving some operators in the position where the only way forward is to increase the amount of manual intervention, which of course comes at a huge operational cost.

As we know, some operators are seeing 100,000’s of deposits and withdrawals each month. Monitoring every customer’s transaction can be virtually impossible or, would take a significant amount of employee time and resources to process.

I believe the reason behind a number of documented fines, to be human error. Customers are slipping through the gaps, coupled with increasing volumes, it becomes difficult to track and score effectively with legacy systems.

There are some easy steps that can be implemented to help operators align with the UKGC and document their businesses’ policies and procedures.


TruNarrative KYC

Onboarding a Customer


Full 2+2 KYC and  PEPs & Sanctions

First Deposit

Ensure depositing cards/payment methods match up with the persons named account

Build a risk based profile or risk matrix of your customer (Low, Medium & High). Understand where they are based, how they are depositing, what are they betting on. As and when transactions occur with the player, amend and update the customer’s risk throughout their lifecycle.




Ongoing Monitoring of a Player

Transactional Monitoring & Behaviour – Interactions with a player when the following occurs.

  Have fixed thresholds. Once the thresholds have been met, interaction must happen with the player. Some examples below

TruNarrative Machine Learning

–  Have a single player view across all operator’s different brands so you know their total spends

–  Interact with the player if their typical behaviour changes

(ability to automatically detect and flag this is key)

–  Have they spent more in the latest deposit than they normally would?

–  Whilst a player is online and depositing, interact with them to ensure their understanding and gambling awareness.

–  Collect payslips and current account statements, check the business paying the player is a genuine business.

–  Once an operator understands a player’s earnings, ensure they don’t spend more than their means. Spending Cap % per month, for example. The system enables you to impose player limits and not rely on the player doing so.

–  Interact with players, to determine any additional sources of wealth or income.

–  Consistently monitor and update a player’s risk level.

Nb – what if we can’t interact with the player (non-responsive) do you then block or impose limits?


What people do with their own money is to some extent their own business. But as an industry, we have a regulatory requirement and a moral responsibility to ensure the safety of our customers.


There is some really interesting technology & data emerging in this space, but I believe that a true affordability check will always require some aspect of manual intervention.

However, having the ability to monitor every single deposit, withdrawal, bet or transaction a customer makes is key to any Operator’s understanding.

Without this in place, human error and incorrect decisions made with limited information becomes more likely, and problem gamblers will slip through the cracks.

A risk based approach is no longer about just monitoring the top end of the funnel. Each customer instance needs to be tracked, documented and followed by a trigger for automated or manual intervention once a threshold has been met.

Automated system checks can generate alerts and flag players automatically without relying upon a significant number of people to monitor this second by second.

Some of these checks are a soft approach and have no impact on the customer journey or experience, keeping friction to a minimum.  It is when the deposit, bets, withdrawal amounts increase or we see a change in betting behaviour that a more sophisticated interaction between the operator and player has to take place.

TruNarrative Logo

–  Geo Affordability Checks – Looking at the location the player plays from. A light touch which gives an operator a better understanding of the lifestyle of people who live in that area. UKGC suggest using Office for National Statistics data.

–  Collecting Payslips (UKGC have mentioned 3 months banks stats) – Although people believe this is a bit invasive this is necessary when ensuing affordability.

–  Source of Wealth Checks – This check is the last step prior to contacting the customer and asking them where they get their funds from. With all things GDPR, all players must be made aware of any of these checks that you are carrying out on them. Again, if this is positioned correctly, this is an easy process.

–  Open Banking – In Sweden players are actually worried if they haven’t had to login into their bank account during their gambling sessions. Although BAU in Sweden, this is going to be a HUGE educational process with British players. With stories of scams seemingly in the news every day, players will be wary of logging into their bank during a gambling interaction. If this is embraced by ALL operators, before we know it, this will become 2nd nature for UK players.

–  Open source risk checks – Any 3rd party services that can help with this and perform these checks in real time are key to the future of this industry.


For me, the best steps for an operator are;


–  Agreeing the thresholds that will trigger interaction with players

  Integrated the relevant 3rd party suppliers to support your business

–  Document ALL deposits, withdrawals and customer interactions

–  Interact with the customer during play

–  Have an agreed company policy and procedure that is documented and adhered to.

–  Staff are trained and fully understand their company’s policy & procedure and why these measures are put in place


The old compliance days of basic KYC checks have gone.  It’s now about being collaborative, using multiple 3rd party data sources and embracing the right technology in the right place and/or replacing legacy systems.

I truly believe this part of the gambling industry is changing and for the better!

The way to stay ahead of the curve is to have the ability to monitor and make automated decisions against every single transaction a player makes, providing the ability to respond instantly and automatically. 

When it comes to identity and meeting the changing regulation, being agnostic and accessing as many providers as possible in an automated, low friction process is critical.

Using a platform where you can plug into all the relevant suppliers will help take operators to the next level.