Since the COVID exposed the failure of online gambling operators to protect customers, the UK Gambling Commission has been storming the industry with several new regulations and conquering what many thoughts were undisputable strongholds.
Advertisement, banking options, VIP programs, even the mechanics of slots, all have been collateral in the restless need to freeze the alarming numbers of problem gamblers that can be paired with the current epidemics.
The next target under the Commission scope is gambling affiliates, a sector responsible for driving 30% to 50% of the UK gambling revenues and for which the ethics of its practice are now in dispute.
A win-win-lose program?
Affiliate programs from the gambling industry are one of the most profitable marketing companies can access. For every new customer funneled through the marketing efforts from iGaming affiliates to the operators sign up page, they both will earn a commission and a new client.
Social media Influencers, witty content, and the best optimization practices to draw attention to the desired land page. Thousands of pounds are invested to this a dedicated effort, making the symbiotic relationship has proved to be a lucrative one. Perhaps too much for some.
In this regard, some greedy content creators have learned to manipulate algorithms to get on top of the search list even if not related to the gambling topic. The most unscrupulous ones have to go far enough to provide backlinks to address the unaware customer to seedy operators.
Another gap in regulations
Although iGaming affiliates must abide by the Advertising Standard Authority there is nothing written to define how gambling( in the same way tobacco and alcohol) should be addressed and promoted to the public through the internet.
The proposal to license specifically iGaming affiliates is not a new one. But with COVID blocking every doorstep, and gambling operators having incredible spikes in revenues in such a short span, the proposal was resurfaced.
Supportive agreement from the RAiG
RAiG Chairman Clive Hawkswood manifested the organisation’s decision to support gambling-specific affiliate regulation with the following:
“The decision to support the principle of a licensing or registration system was not taken lightly and we have been assessing the pros and cons for many months. This issue will achieve greater prominence as the Government’s review of the Gambling Act 2005 picks up the pace and it is vital that we play a constructive role as policies evolve rather than waiting on the side-lines for measures to be imposed.
“It is appreciated that this is an issue where opinion across the sector is divided and RAiG will make clear that, as with any trade body, it can only speak on behalf of its members. Despite that, we hope everyone in the affiliate marketing world and beyond will keep an open mind about any proposals which would serve to create a safer gambling environment.”
“As with all forms of licensing and regulation, the devil is usually in the detail and the aim must be to work with all stakeholders to ensure that any provisions are proportionate and, most important of all, effective in improving safeguards for consumers.”
Weighing the evils
With such a positive response a question comes to the air.
What are those pros and cons that Responsible Affiliates in Gambling have wagered to consider supporting a licensing or registration regime for gambling affiliates?
PROS
It will ensure compliance with existing marketing rules and regulations
Under the UKGC regime, iGaming affiliates will be passing a third-party audit that will evaluate their compliance to raise social awareness associated with the marketing of gambling products such as available credit card online casino sites, new online casinos and much more.
This will make affiliates will be more self-aware of their published content’s impact during their campaigns and will create a precedent to apply over the diverse sector in the advertisement industry.
It will incentivize Specialist training for affiliate staff
In the same fashion that looking for a gun permit, iGaming affiliate marketing companies must fully understand with greater awareness and responsibility how to promote gambling products because of their addictive nature, before applying for a licensing permit
Educating affiliates should be the first step to denormalize how gambling has been perceived over the past two decades while minimizing changes and necessary efforts to correct the wrongdoing many affiliates will incur not comply the new rulings since day one.
Minimizing gambling advertisement, especially for the self-excluded.
Those that undergo a self-exclusion program, have the common complaint that is completely at bay to an unwanted advertisement that still fills their social media and spams their emails.
The RAiG considers that partial access to the Gamstop database will provide the necessary blacklist to prevent this complex situation occurring. At the same time, limiting the exposure and overwhelming presence gambling adverts will reduce the enticing power that once possessed.
Social responsibility content
Through their platforms, affiliates can become an advocate for social responsibility, problem gambling and sources of help in a similar way they had worked to operators.
This innovative approach will increase accessibility by funneling people at risk/or interested in problem gambling behaviour to the needed resources and helping to normalize social awareness of gambling overall users.
Data sharing with operators
While customer data sharing between operators and affiliates is limited thanks to the GDPR and Data Protection laws, it also prevents them from protecting vulnerable groups.
By introducing a framework to track customers with harmful behavior between operators and affiliates it will reduce the presence and persistence of the underage and vulnerable only if they meet the necessary criteria before breaching their privacy rights.
CONS
The problem for smaller affiliates such as so-called influencers
Affiliate marketing is envisioned as a greatly profitable marketing strategy. The crude reality is that revenues are only sizable to the efforts and investment dedicated to the niche.
To produce quality content, paying for host servers, and not only complying with the UK rules but also google’s capricious listing algorithms, is an expensive effort that only a few with a current (large) established audience will be able to keep.
This will draw away smaller affiliates from the UK market but also attract them to less regulated jurisdictions.
Improved monitoring of social media vs freedom of speech debate
Social media has taken significant relevance as a tool for marketing, and gambling is not an exception. Despite the Commission having provided certain limitations and guidelines to operators, influencers and tipsters have a large audience that might escape these regulations.
There is an opportunity to promote more awareness through these audiences but imposing regulation over individuals' right to express themselves and their contents is a subject of a very grey matter.
Illegal/ unregulated markets will always attract customers
Attracting people to illegal gambling activities is a criminal offence. Considering that licensing affiliates will make people seek other seedy venues but sadly is already happening. Criminals simply don't care how many regulations and prohibitions will be imposed as they clearly are going to break them.
Added pressure for the Gambling Commission
With all the current changes and future revisions over the industry, accusations of the Commission is overextending its reach and falling to its purpose are dropping.
Regulating the most strict gambling jurisdiction, and providing resources for the vulnerable to overcome gambling addiction is a huge task that has become overwhelming
Final words
Monitoring what is said on the internet is a task too large to be accomplished even for the most control freak nations. the most extreme way to prevent it is by literally disconnecting the whole UK, something that not even the most radical anti-gambling lobbies will propose.
Providing an ethical framework in order to address the marketing of gambling products through the lens of social responsibility and counting with the sincere support from the iGaming affiliate representatives, licensing the sector can be a feasible reality to protect the most vulnerable groups without the expense of restraining expression and personal liberties in the process.