Following on the Gambling Commission’s publication of its LCCP and customer funds consultations, on 26 September a third consultation was published, which seeks the industry’s views on the changes proposed to operational licence application procedure in anticipation of the point of consumption regime being implemented in early 2014.
The Commission intends to adopt what is known as a Multi-Jurisdictional Business Form (“MJBF”), which has been created by the International Association of Gaming Regulators. Its purpose is to help streamline the licensing process for applicants by providing a “portable” form that can be when applying for licences in a number of jurisdictions. Accordingly, the MJBF form requires applicants to provide information which is generic and commonly required by regulators across a number of territories, such as details of directors / shareholders, financial robustness and previous compliance history. Although there will be common information requirements among regulators, clearly, jurisdiction-specific obligations will apply. To deal with this, a Jurisdiction Rider will be used.
The Jurisdictional Rider contains more disclosure requirements that existing licensees have been subject to. It is proposed that new applicants will have to provide:
Information about the provision of poker (which is obviously linked to the proposals in the LCCP consultation);
Full name of the nominated officer for anti-money laundering;
Details of any relevant person (being an individual that has made some form of investment or has an interest in the applicant (excluding equity));
Name of the applicant’s dispute resolution entity;
Information about the payment methods accepted by the applicant;
Evidence of information security controls; and
Authorisation to release information to enable the Commission to obtain further information from third parties.
To assist with streamlining the process, the Commission is revamping its online portal (sServices) so that the entire process is conducted online. Where a MJBF form has previously been submitted as part of a licence application in another jurisdiction, the information and supporting documents will be available to the Commission so the applicant would only need to complete the Jurisdiction Rider.
The consultation opens on 26 September 2013 and closes on 28 October 2013. The response document will be published in November 2013.
What is unclear from the consultation is the extent that existing licensees will need to provide the additional information required by new applicants. We understand that this is not a priority for the Commission but it may request such information at a further date.
The full consultation can be found here.