The Department for Culture Media and Sport (DCMS) recently published the
Evaluation of Gaming Machine (Circumstances of Use) (Amendment) Regulations 2015. The declared policy objective was to assist gamblers using FOBTs to "stay in control" by having to use account based play or load cash via staff interaction at the counter if wanting to bet more than £50 per spin.
The most important effect anticipated by DCMS was that this would allow for "increased opportunities for interaction and intervention with appropriately trained staff". However, nowhere in the Evaluation is there any insight into how many interventions have been instigated, whether or not betting shop staff have been appropriately trained, whether or not that training is actually being put into practice, nor the effectiveness of those interactions.
Furthermore, as the Evaluation explains: "Unfortunately the amount of RGIs (responsible gambling interventions) linked to £50 stakes specifically was not available for this evaluation". The Evaluation does not even explain what an RGI looks or sounds like. Would any of the following qualify as an RGI?
Is everything alright?
Would you like a cup of tea?
Please don't swear so much!
Please stop hitting the machine!
The DCMS academics who crafted this evaluation sum up “this would suggest the reach of the regulation in terms of simulating customer interaction may have been limited”. Yes! Of course a useless measure will have useless results,
as the Campaign has been explainingsince the £50 measure was first mis-conceived.
Most embarrassingly, this DCMS Evaluation suggests "considerations for future research". Well the excuse a DCMS mandarin gave in 2013 for ignoring the British Gambling Prevalence Survey 2007 secondary research, which substantiated that
FOBTs were the most addictive form of gamblingwas that the researchers suggested doing more research! How can such double standards ever be acceptable?
DCMS, with the benefit of "insight" from its Evaluation, is now in the process of preparing the 2016 Triennial Review of Stakes and Prizes. The 2013 Review did not consider FOBT crime as part of the consultation as the Gambling Commission advised DCMS not to do so. The commission considers
violence on premises,
FOBTs being smashed up,
Police call outs to betting shopsand anti-social behaviour around them to be “low level disorder”!
Let’s not forget the evidence of
money laundering on FOBTs. The Campaign has
responded to a Commission consultationon this and blames the executives previously in charge at the Commission for ignoring betting shop crime and running a not-fit-for-purpose quango.
If DCMS wants to know if FOBT players are staying in control then it should want to know how many FOBTs are damaged, but the Gambling Commission refuses to say. Local authorities, who also have a duty to enforce the licensing objectives, are unable to prove the level of FOBT crime because the Commission allows it to go unreported.
Is it any wonder that the 93 Councils the government said no to last year in their call for a £2 cap, have stuck two fingers up to that decision and resubmitted their call for action? This time the government can’t just say "No" – it has to negotiate under the terms of the Sustainable Communities Act (SCA).
The DCMS Evaluation clearly shows that betting shop customers do not want to sign up for account based play and so they are opting to stake under £50, with stakes in the £40 to £50 range trebling since the measures were introduced. You would be forgiven for feeling some sympathy with the bookmakers for this upset to their business model, but the reality is that FOBT stakes and profits in Q3 2015 (the second quarter of the £50 measure)
were actually higher than FOBT stakes and profits in Q3 2014!
Damningly the Evaluation does not even consider the reasons why FOBT gamblers might want to be anonymous. One obvious answer would be because they are engaged in money laundering. With a demographic that is accented towards male, young, unemployed or low income and located in deprived communities, there is more than ample support for the view that cash crime has been a good source of FOBT profits for the bookies.
The Campaign will diligently analyse the Evaluation and expose the failings. The Association of British Bookmakers (ABB) was tweeting the Evaluation as soon as it came out. But their record of trumpeting flawed reports has been exposed by the Campaign before.
A KPMG report commissioned by the ABB has been presented to government, but is not being disclosed even under Freedom of Information requests. It would be very foolish of DCMS to take this KPMG report into account, without making it public, in the coming Triennial Review consultation and in the SCA negotiations.