HBF was a counter-signatory to the following letter from Brian Chappell, representing a group called Justice For Punters, sent to the CEO of the UK Gambling Commission on 1 July 2016, regarding account verification. At the time of writing, HBF understands that Brian has had acknowledgement of receipt of his letter but no other reply.

Dear Ms Harrison


Customer account verification


In November 2014 the Gambling Commission (GC) introduced a new customer account verification process, with excellent objectives, namely the prevention of underage gambling, money laundering and other crime.


As signatories to this letter we are not certain how successful this initiative has been, because to our knowledge no data is in the public domain.  There does, however, seem to be some confusion in the gambling community as to how it is being implemented 18-20 months on.  Our concerns are based on feedback from customers, bettors, punters, gamblers, whatever term you wish to choose.


In early 2015 it soon became apparent that bookmakers were interpreting the new guidelines in differing ways.  Some would verify accounts covertly with no documents asked for; some would ask for additional documents, e.g. a utility bill, copies of both sides of debit cards and a driving licence photograph or similar, with all documents requested early after registration; and others would ask for the same additional documents before withdrawing money.  Unfortunately, there is one more category. Some bookmakers without providing a good reason are:


1.       rejecting scans of documents and photographs, again and again

2.       requesting  that ‘selfies’ are taken whilst holding the said documents

3.       requesting  that ‘selfies’ taken whilst holding the said documents are signed by a lawyer

4.       asking for full bank statement records 

5.       asking for full bank statement records to be signed by a bank manager


Irrespective of the money-laundering regulations, this is completely unacceptable practice, where no good reason is given and/or evidence provided that the police have been informed of suspicious customer behaviour.


Even worse, when customers have taken their cases to alternative dispute resolution they have lost due to the application of unfair terms and conditions, meaning these intrusive requests to withdraw their own money or to obtain a promised free bet of say £25.00 have had to be carried out. 


In our experience, these additional requests rarely, if ever, happen when customers lose, meaning they are not completed for social responsibility reasons concerning problem gambling (see your recent fines). They appear to happen only when someone is trying to withdraw winnings or obtain promised promotions. 


Obviously, these requests cause delays which can be very significant, sometimes lasting for weeks or months, and are verging on defamation of character, because no good reason has been given for these privacy intrusions.


There are also cases, where customers are able to afford it, of legal action progressing against bookmakers for the recovery of funds being withheld because of these processes.  It is our prediction that none of these cases will enter a court room due to the bookmakers knowing a truly independent person (a judge) will not find for them. 


Whilst we fully support the original concept, we also have to say that some bookmakers are abusing a good initiative for their own ends.  Due to the latter observation, we feel it is only fair that the GC urgently reviews this process, including consultation with consumers who bet on a very regular basis, not just internal committees and bookmakers.  The GC’s recent bookmaker fines concerning social responsibility would also support our observations.


We do hope you can appreciate why this issue is very important to consumers.  Some certainly feel it is verging on defamation of character, primarily due to bookmakers commonly refusing to enter into any form of sensible customer service dialogue.  This would not be acceptable in any other industry.


A standard procedure agreed and monitored by the GC is urgently required. 


Yours sincerely, 


Brian Chappell                                                                   Simon Rowlands

Founder, Justice for Punters                                      Chair, on behalf of Horseracing Bettors Forum 


NB: Signed on behalf of both organisations and other individuals who wish to remain anonymous.


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