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May 2022 - UKGC Abrogates its duty and needs to be Privatised

Today I want to introduce you to my favourite word of the moment Abrogation


And my next is Privatisation


I believe both can be used in a sentence which includes the words Gambling and Commission



Let me start with Abrogation


The word has a few meanings but the one I’m focussing on is given by the Cambridge Dictionary that defines Abrogation as ‘the act of avoiding something that you should do’


I wish to make it public that I hereby accuse the Gambling Commission of abrogating their duty as a regulator by refusing to regulate novel products


As you will be undoubtedly aware


The Gambling Commission got shown up as the incompetent bunch of arseholes that they are in the Football Index scandal


And please Gambling Commission, do sue me on this


Take me to Court and let me prove to the world what incompetent arseholes you really are


Everyday I hear a new story about how rubbish you are as a regulator


You only have to read the brilliantly written report by the Parliamentary All Part Betting & Gaming Group on the Competence and Efficiency of the Commission to see incontrovertible proof of why they are not fit for purpose


But back to the rant


As an outcome of the Gambling Commission’s abject failure on Football Index where it was obvious that their collective IQ of a pot plant meant that they couldn’t even understand the basics of a stock market


Which lets be honest anyone with an A level in Business Studies can


But obviously the only pre-requisite for joining the Commission, as per their website, is hating the gambling industry


But more galling is the fact that because Football Index used financial terminology this gave them an excuse to palm off its regulation to the Financial Conduct Authority


Even when it was blatantly clear to everyone that it was a gambling product


Just they weren’t smart enough to understand it or regulate it


And the FCA, which has people who have more than 2 GCSEs working for them were not convinced that they should regulate it – and both of them, being bureaucracies with no accountability to anyone took years over the turf war


The outcome of this has been that in the power grab and removal of checks and balances that turns the Commission into basically a regulatory junta also known as the  Consultation on changes and updates to our Licensing, Compliance, and Enforcement Policy which was opened on the 17th November 2021 and closed on 9th Feb 2022 the Commission has stated that


Products whose name, branding, marketing or game rules contains languages associated with financial products will not get licensed until legislation changes to allow them to become part regulated by the FCA


This basically means that any kind of innovation in the gambling world that uses financial terminology cannot get licensed


The Gambling Commission’s reasoning is a prime example of psychological projection. They think customers will think that a blatantly gambling product – its about football for fucks sake – is actually an investment product they should make as part of their pension plan


Because they are morons they think the world is morons


The reason that people lost their money in the Football Index scandal was not because they were investing as part of mixed portfolio strategy it was because the product was bent. Which they were too fucking stupid to realise when they licensed it.


So what we have now


And I know this as fact as I know someone in this unfortunate position


Is the inability to have a game that uses the stock market  as a framework  licensed as a gambling game


And the FCA wont licence it either


This poor sod is in regulatory limbo because the Commission is too fucking stupid and/or too fucking lazy to regulate a new, innovative gambling game


May I remind people that in 2002 the BBC launched Celebdaq – a stockmarket of showbiz


In 2004 Celebdaq was chosen as the best entertainment site on the internet at the Interactive Bafta awards


Thousands of people were clever enough to realise this was not an investment tool


But the Gambling Commission


Rather than doing their job


Is banning games like this


It would also seem by the Speeches given by the Grand Inquisitor and his Deputy Inquisitor

of the Society for the Reformation of Manners (Google it) gave at ICE that they are banning any new innovation


Torquemada, Andrew Rhodes, said


In terms of the unregulated space, however, what I’m talking about are the spate of novel products we now see coming to market, often in the unregulated spaces between established markets.


These products often have many of the hallmarks of gambling, but may not meet the definition. Some deliberately stress they are not regulated as gambling.


Products such as non-fungible tokens (or NFTs), ‘synthetic shares’, crypto currency are becoming increasingly widespread and the boundaries between products which can be defined and regulated as gambling are becoming increasingly blurred.


Language has changed in these products, with talk of ‘investment’ and trading, yet with none of the safeguards or standards those terms should bring with them.


These products have many of the hallmarks of gambling as we know it, but the pattern of harm is different. We are accustomed to thinking about a pattern of deposit and losses. Chasing losses, escalating deposits, and deepening financial problems in the worst cases. Remember – this is an industry yielding £450 a second – the money is only moving one way.


he can’t help make the suggestion that all people do is lose money when gambling. He must have read that report by Naomi Muggleton of Oxford University that analyses banking data and ignores gambling winnings and thinks gambling makes you die early based on bugger all evidence.


He finishes:


We are in the process of changing how we regulate and deal with novel products. Many of these products are not gambling as defined by law, and I am not suggesting we should be regulating them, but I am suggesting we will see this pattern continue and we are likely to see more and more tests of what is and is not gambling, in a way we have not faced before.


Then Torquemada’s deputy and Queen of Woke, Sarah Gardner says the next day:


In a different category of threat is something that we have seen emerging in the last few years in terms of new, novel products which have hit the market. I’m thinking, for example of products that do not fit wholly or neatly within definitions of gambling products, products which don’t use language that make it clear whether something is an investment or a bet. And often products that don’t fall in our remit and should not.


Our concern is that this all adds up to a risk of harm.


What they are basically saying is that its taken us years to even understand basic gambling, and we haven’t really grasped that yet, and now these evil people are innovating in the industry we are trying to shut down


You can hear them crying over their Guardian newspaper


It is eye opening that they throw NFTs, synthetic shares and Crypto into the same category as gambling products as NFTs, synthetic shares  and Crypto are basically just scamming


Even if you give them some creditability, most of the world know that they are not in any way gambling products. With the biggest stretch of the imagination they are forms of investment – this is why the FCA  is considering how to regulate them


They have fuck all to do with Gambling Commission


Unless you consider Crypto as a form of payment for gambling


And the Gambling Commission while stating that they will treat Crypto like any other currency have basically almost made it impossible to offer crypto payments and we await the scandal when the few licensed to do so fuck up


What the Commission is actually saying, or rather admitting is that they are too incompetent to regulate anything that doesn’t appear in the Ladybird Book of Gambling Games


They are happy to use another regulator, the Information Commissioners Office, to force the industry to develop the Single Customer View in its Regulatory Sandbox. A Sandbox is where novel products are tried out but the Gambling Commission will not do the same for innovation in this industry.


Regulating new products in this market isn’t really that difficult


Is the game fair is basically the number one issue


Having the brains to do this was not a problem for the previous regulator, the Gaming Board nor any other regulator in the whole world


It is the job of a regulator to regulate innovative products


Its how the market develops and customers get new things to play with


To not regulate new products is to actively prevent market growth


And that’s why they are doing it


Because they are acolytes to the ideology of the Public Health approach to gambling


Which, as I have written about many times


The public health approach to gambling is just a woke political ideology that is basically grifting by Lefty academics and has nothing to do with preventing or reducing problem gambling


Its about reducing the overall amount of gambling and massively increasing the amount of grant money that these activist academics can access to carry on producing methodologically bullshit research that is just basically anti-gambling propaganda and should make their sponsoring universities and the rest of the academic community utterly ashamed


To not regulate or even attempt to regulate innovation in the gambling industry is a blatant abrogation of their duty as a regulator and a massive restraint on trade


I call on the industry to fund a Judicial Review


This leads me to my second favourite word




One cant help but have noticed in the press this week that Boris Johnson, our supremely lucky yet utterly flawed Prime Minister was so upset about two government agencies abjectly failing at their jobs, the Passport Office and the DVLA, that he raised the idea of having them privatised.


The Passport Office has such a backlog of passport applications that it highly likely that many British tourists going on their summer holidays will not be able to


The DVLA, it appears, went home for Covid and didn’t do anything. This now means that there is an enormous backlog of driving licence applications. How can we solve the shortage of lorry drivers when their licence applications are in a pile of unopened letters somewhere in Swansea?


I think this also gives us ample reason for the Gambling Commission to be privatised


I posted on LinkedIn just the other day how one of my client’s licence application – and it’s the most basic and simple application ever – was in its 30th week of processing, far beyond the 16 week time frame given by the Commission


I was contacted by a mate who had sold his chain of betting shops to a family, who were already licensed by the Commission, - it took over 5 months for the Change of Control to happen


You only have to read the brilliantly written report by the Parliamentary All Part Betting & Gaming Group on the Competence and Efficiency of the Commission to find the example of an operator who applied for a Change of Control because he was getting in two investors from Asia. Both part of listed companies and above board. Two years later the application is still not finished and the investors have pulled. In an example of pure Kafkaesque-ness, the Commission has refused to stop the application so now they continue on a Change of Control where there is no Change of Control


The report by the Parliamentary All Part Betting & Gaming Group on the Competence and Efficiency of the Commission provides lots of evidence of how the Gambling Commission is just not performing its basic functions of licensing within an acceptable timeframe


They are just not fit for purpose


They are abrogating their responsibilities as a regulator because they look on themselves as an anti-gambling pressure group


They need Privatising




Because they’re shit

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