Casino Guru’s Fair Gambling Codex
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Common problematic areas in online gambling and how casinos should handle them

We believe online gambling should be fair. While that also requires players to act fairly and without malicious intent, it’s mostly the casinos’ responsibility to make sure gambling remains fair and safe for players.

We’ve witnessed pretty much all types of conflicts between casinos and players when dealing with casino reviews and player complaints, and this experience helped us form a strong opinion about what casinos should and shouldn’t do in situations that arise frequently.

We will deal with the specific situations and our recommendations for each of them later on in this article, but it’s important to define two terms – ‘fair casino’ and ‘fair and safe casino’ – first.

Note: These terms might mean something else in a different context, but the definitions below apply for the purpose of this article.

Definition of fair casinos

A 'fair casino' is an online casino which:

  • pays out all legitimate winnings;
  • doesn’t have any unfair clauses in T&Cs (more on that later in this article);
  • doesn’t use any deceitful practices to trick players;
  • enforces restricted countries (doesn’t allow players from them to create an account).

Even casinos with fair rules and good approach to gambling can sometimes be tricky for players. In some cases, players might not be aware of certain rules and break them accidentally, despite the rules themselves being fair in our opinion. That’s why we believe all rules should be technologically enforced by the casinos to stop players getting into trouble on accident.

EXAMPLE

What does the term "technologically enforced rules" mean? It means that if a casino has, for example, a maximum bet limitation of $5 when playing with bonus money, it shouldn’t allow players to place bets higher than $5. The casino’s system shouldn’t accept any bets higher than that, which would mean that the players wouldn’t be able to accidentally break a rule they might not even be aware of.

As one of our goals is to actively contribute to the improvement of the overall quality of online casinos, we’ve decided to start using the term ‘fair and safe casino’ to describe online casinos that go further than those that are "just" fair. This can be done mostly by enforcing their rules, as we mentioned above.

Not many casinos can be called ‘fair and safe’ according to our criteria at the moment, but we are hoping their number will increase in the future, and that one day, this might become the standard for all high-quality online casinos.

Definition of fair and safe casinos

‘Fair and safe casinos’ are those that meet all criteria for 'fair casinos' and have also implemented measures which prevent players from accidentally doing something against the rules or their own best interests.


‘Fair and safe casinos’ should therefore prevent players from accidentally breaking the T&Cs, Bonus T&Cs, or doing anything else that might jeopardize the money they have in their player accounts. Specifically, safe casinos should:

  • enforce maximum bet sizes, restricted games, and other bonus conditions;
  • warn players when they are about to do something against their own interest (for example taking another bonus which would void winnings from the previous one);
  • check for multiple accounts at account creation (we suggest checking the combination of new player’s name and birth date in the database and displaying a warning if a match is found, more on this below).

It’s also important to keep in mind that this doesn’t mean casinos which we consider to be "just" fair are not good. There are many fair casinos which offer great services and are honest towards players. The casinos we consider 'fair and safe' are just taking an extra step towards protection of players.

Note: The term ‘safe casinos’ is often used also in relation to responsible gambling and problem gamblers. Certain things in this article are also related to those areas, but the term ‘safe’ in our fair gambling codex might mean something else than when talking strictly about responsible gambling.

What casinos should and shouldn’t do

Let’s take a look at what casinos should and shouldn’t do. This is a complex topic, as we believe most of the responsibilities should be on the side of the casinos in online gambling, and players shouldn’t have to painstakingly watch everything they do just so that they don’t make a mistake on accident.

Below, you can find multiple problematic areas we’ve decided to include in this article. Based on our experience in dealing with player complaints, these are the areas that cause most of the friction between casinos and their players:

  1. Hidden and predatory rules
  2. Win limits
  3. Maximum bet rules
  4. Withdrawal limits
  5. Restricted countries
  6. Restricted bonuses
  7. Dormant accounts
  8. Betting patterns
  9. Bonus hunting
  10. Self-exclusions
  11. Player verification and duplicate accounts
  12. Enforcing rules

Note: If everything in this section was handled perfectly by the casinos, we believe there would be no more justified gambling-related complaints on the internet, perhaps apart from a very small number of them related to more marginal issues.

1. Hidden and predatory rules

Each casino has its own Terms and Conditions (T&Cs) which specify the relationship between a player and the casino, as well as rights and responsibilities of both parties. However, some casinos also apply rules that are not listed in their T&Cs (hidden rules) or include rules that go against the idea of fair gambling and are used to exploit players (predatory rules).

Casino's point of view

There are couple of possible reasons for the existence of hidden and predatory rules:

  • Some casinos apply predatory rules or make some of their rules hidden by accident. This is not very common, but some gambling sites might do something like this without even knowing about it, not realizing that their rules are unfair towards players or that they are hiding something which should be made public.
  • Some casinos apply hidden rules or create predatory rules to protect themselves against certain situations and players. They care about their own protection and don’t care too much about how their rules influence players.
  • Some casinos purposefully hide rules and/or include predatory rules in their T&Cs to rip off players and increase their profits.

Player's point of view

There are few players that read the T&Cs before creating a casino account, but the vast majority of them doesn’t. And even players which pay attention to the T&Cs mostly check only certain parts of the conditions, for example restricted countries.

Players expect that the casino follows certain best practices and therefore don’t find it necessary to read everything. They don’t expect to find predatory rules in the T&Cs. And because some players might not be experienced in online gambling, they may not notice that some rules are predatory even if they fully read the T&Cs.

Note: Not many players read T&Cs in full, apart from bonus hunters, who usually read everything to check whether they can abuse the casino’s bonuses or not.

Additionally, if a casino tries to enforce a rule which is not stated in their T&Cs (hidden rule), there is obviously no way a player could have known about the rule beforehand. Players can’t be expected to follow rules which they don’t know about because they are hidden.

Our position

We don’t tolerate any hidden or predatory rules, as they are unfair towards players and put them at a disadvantage. If we notice them during our review process or if they are brought to our attention through a player complaint, we decrease the reputation rating and also try to get the casino to start behaving fairly, if it’s within our capabilities.

When it comes to deciding whether some clauses are predatory or not, we rely on our judgement and experience, as well online gambling best practices we are very familiar with.

The T&Cs should be written clearly, so that they are easily and exactly understood by players. The entire system should be set up in a way which doesn’t allow players to break the T&Cs unknowingly. All rules should be listed at one place (the T&Cs), and they shouldn’t be unfair and/or predatory (see examples of hidden and predatory rules below).

Our recommendations for casinos

Every single rule you require players to follow should be stated either in your general T&Cs, or in the Bonus T&Cs of each bonus. You should never try to apply rules which are not stated publicly, as players simply can’t know about them.

What’s more, all rules should be in line with fair play. Most players don’t read the Terms and Conditions before creating an account, so they will not notice a predatory rule by themselves. Help them gamble safely by only implementing fair rules. Make your T&Cs simple and easy to follow, and don’t try to make up rules which you can misuse against players who haven’t done anything wrong.

Remember that a fair environment is good for your business, too. It should be in your own interest to retain your players and keep them active. If your players experience your unfair approach towards them, they will not continue to play at your website. And if the word about bad player experience spreads out, players will prefer to register in other casinos instead of yours.

Examples of hidden and predatory rules

To better illustrate hidden and predatory rules and to help you understand them, you can find some examples of these unfair practices below, together with our comments about them.

Example #1: Max win based on deposited amount

"If a player's accumulated deposit amount does not exceed €200, player will be entitled only up to X10 last deposit. This maximum payout will be enforced also in cases where the player made additional deposits which were deemed at the sole discretion of the Casino to have been made in order to exceed the €200 accumulated deposit amount."

Example #2: Max win based on deposited amount

„In case where the Withdrawal exceeds 10 x the amount of the initial Deposit, the rest of the amount will be canceled and the balance will drop to 0."

These two examples are clearly unfair towards players. It just doesn’t make sense to limit the amount players can withdraw if they aren’t playing with a bonus. We accept Bonus T&Cs which restrict the maximum cash out from a bonus play, but since the examples above are not related to bonuses, they are clearly unfair and predatory.

Example #3: Hiding rules in FAQ or other places

"By using and/or visiting any section of the website (casino hidden); or by opening an account on the website You agree to be bound by: Terms and Conditions; Privacy Policy; Responsible Gaming, FAQ, Any game rules; Bonus Terms and Conditions, special campaigns and tournaments ran on the website."

As already mentioned, all rules which players need to follow should be grouped together in the T&Cs. Some exceptions are understandable (such as Bonus T&Cs, Privacy Policy, etc.), but hiding rules in FAQs (where nobody expects to find them) is clearly unfair and deceptive, for example.

Example #4: Canceling winnings exceeding the withdrawal limit

"Maximum Withdrawal Approved per Month: 3000€/£
In the event that the withdrawal exceeds this amount, the rest of the amount will be canceled, and the balance will drop to 0."

Ignoring the fact that the withdrawal limit in this example is too low, the second statement is much more outraging. It’s one thing to only pay out a certain amount to the player per month, but it’s something completely different (and extremely predatory) to withhold all money over this limit if a player asks for a higher withdrawal.

Requirements for both ‘fair casinos’ and ‘fair and safe’ casinos

For a casino to be classified as ‘fair’ or ‘fair and safe’ casino by our review team, it can’t have any predatory rules in its T&Cs, and all of its rules must be clearly listed in the T&Cs (or in Bonus T&Cs for rules related to specific bonuses).

2. Win limits

Some casinos enforce win limits, which only allow players to win a limited amount of money in one game round or within a predefined period of time. Win limits can be calculated and applied in various ways:

  • Win in a game round – Limited win in a game round allows players to only win a certain amount in one slot machine spin, one roulette spin, or in one game round on any other game.
  • Total sum of wins within a time period – This type of win limits is applied to the total sum of individual wins in a certain period of time (most commonly one day). Losses are not taken into account.
  • Net win within a time period – These limit the total amount players can win in a certain period of time (most commonly one day). Loses are also considered.

Apart from the various types of win limits, each casino approaches the entire issue differently. Some casinos might apply a win limit right after a win, other might start dealing with the issue only after a player asks for a withdrawal.

Example

A casino has a win limit of €100,000 in a single game round. If a player manages to win €150,000 in a very successful slot machine bonus round, they are entitled to keep only €100,000, and the rest (€50,000) will be kept by the casino.

Note: In some jurisdictions, win limits are required by the local laws and regulations. In these cases, casinos can’t do anything about it if they want to keep their license and operate legally.

Win limits and progressive jackpots

The connection between win limits and progressive jackpots needs to be brought up, too. Progressive jackpots work differently than regular casino wins. They are generally paid out by the game provider who has created the game on which the jackpot has been won, not by the casino in which a player has managed to win it.

After a progressive win, the game provider transfers the money to the lucky player, with the casino functioning as an intermediary. Therefore, it makes no sense (in most cases) for the casino to apply the win limit to these winnings. If they do this, they only send a portion of the money to the winner and basically keep the rest.

Note: There are some exceptions, in which large groups of casinos have their own progressive jackpots. These cases are different, of course.

Casino's point of view

If casinos apply win limits because of laws and regulations which require it, there is nothing they can do against it, so we can’t hold it against these casinos. However, many casinos limit the wins of their players at their own discretion, without being told to do so by a regulator.

Casinos use win limits to protect themselves against big wins that could pose a danger for their cashflow and profitability. An unexpectedly big win could be an existential threat for smaller casinos with limited cashflow, so win limits make sense in this context if they are big enough. That said, we still don’t approve of them as they disadvantage players.

Very small win limits (let’s say smaller than €10,000) are quite clearly designed specifically to cheat players and increase the casino’s profits.

Player's point of view

Most players don’t know about win limits. They expect to be able to keep their winnings in full, regardless of their size. It’s devastating when a casino wants to take a big part of their winnings because of some win limit they might have not even be aware of.

It’s true that most players won’t be affected by win limits if they aren’t too low. That’s why even some players who know about win limits might not care about them, provided that they are much higher than the amounts they are used to winning. That said, their stance will obviously change very quickly if they manage to win an amount higher than the limit.

However, the indifference of some players doesn’t change the fact that win limits are restrictive for players and effectively decrease the RTP of some games (at least for some bet sizes), as the highest of wins can’t be achieved because of them.

Our position

If win limits are required by laws or regulations, we tolerate them. We accept them as a necessary evil. We would like to see them gone, but we understand that casinos need to follow regulations.

If a casino applies a win limit which is not required by law, we approach it differently. If the casino’s voluntary (i.e. not required by law) win limit is very high (let’s say €500,000), we still don’t like it, but we’re able to tolerate it, as long as it doesn’t apply to progressive jackpot wins.

If a casino voluntarily applies a lower win limit, we decrease its reputation rating and warn players against the casino’s restrictive win limit.

Note: Applying win limits to progressive jackpots wins is never acceptable. If a casino does this, it’s basically stealing money from the player and/or the game provider that created the game on which the jackpot has been won. We take these very seriously when reviewing and evaluating casinos.

Our recommendations for casinos

Instead of implementing arbitrary win limits, we recommend decreasing the maximum allowed bets. This effectively decreases the amounts won by players (and therefore acts as a win limit), while also keeping the game mathematics intact, therefore not being unfair towards players. You shouldn’t let players place bets that can theoretically yield winnings which you can’t afford to pay out.

You shouldn’t limit wins from progressive jackpots at all. These are not paid out by the casino, so it doesn’t make sense for the casino to restrain their size, unless it’s required by the regulator.

3. Maximum bet rule for bonus play

Most casinos restrict the maximum bet size for players who play with bonus money. This rule was most likely introduced to make bonus abuse more difficult. Without the max bet rule, bonus abusers could get a bonus from a casino and try to quickly multiply it by placing big bets. If they succeeded, the multiplied balance allowed them to easily meet the original wagering requirements and cash out their earnings. The max bet rule is, therefore, a valid rule used to prevent most extreme cases of high-volatility bonus hunting.

Example

A player who is playing with a bonus with a maximum bet of €5 is not allowed to place a bet higher than that. If the player breaks this rule, their bonus and/or winnings may get taken away by the casino.

Casino's point of view

The maximum bet rule is an industry standard in online gambling used by casinos to protect themselves against bonus abusers. Therefore, casinos feel confident having this rule and checking the betting history of players who have played with a bonus and asked for a withdrawal.

Most casinos don’t technologically enforce their max bet rules. This means that the players are able to place bets higher than they are allowed to according to the Bonus T&Cs, so they have to carefully watch their bet sizes themselves.

Player's point of view

Many online casino players know about this rule and are careful not to break it when playing with bonus money.

However, there is still a lot of players who are not aware of the maximum bet rule. These players might unintentionally break it. This often happens after a big win, when a player might naturally increase the bet sizes because of the increased bankroll. In these situations, players feel cheated if their wins are taken from them later on, because they aren’t aware that they’ve done anything wrong.

Players don’t want to painstakingly read all T&Cs and watch their bet sizes in order not to mistakenly place a higher-than-allowed bet. Most of them will follow the rule if it is visibly stated to them in the casino lobby, in the game itself, or in a prominent part of the page or advertisement informing them about the bonus.

Our position

The max bet rule is, in fact, an industry standard, just as the fact that a casino has the right to seize the player’s winnings from bonus play after breaking this rule. We don’t want to go against the industry standards by penalizing casinos which use the maximum bet rule against players from time to time.

On the other hand, we think that this rule should be enforced on the software level, i.e. that the casino’s software or website shouldn’t let players place bets higher than the limit. This is one of our requirements for ‘fair and safe’ casinos.

If software enforcement is not possible, each case should be judged separately, so that only players who have broken the rule knowingly and systematically to gain an advantage are punished.

Additionally, the max bet sizes should be clearly displayed, ideally in the casino lobby or directly in the games if possible, or in a prominent part of the page or advertisement informing them about the bonus, not just "hidden" in the rules for bonus play. It’s a common practice to only list the max bet in Bonus T&Cs, but we appreciate when casinos make it more visible and easier to follow.

Our recommendations for casinos

In the ideal case scenario, casinos should enforce their maximum bet rules on the software level and, therefore, not allow players to place higher-than-allowed bets. This effectively removes all player complaints related to the max bet rule, as players simply can’t break the rule.

If enforcing the max bets is not possible because your casino runs on 3rd party software which doesn’t support it (or for any other reason), you should carefully judge each case separately. Some players may break the rule on accident, e.g. by clicking the ‘Max Bet’ button in a slot machine by mistake. It’s unfair to punish them for this, especially if they didn’t win anything in the game rounds with over-the-top bet sizes.

Requirements for ‘fair and safe’ casinos

For a casino to be classified ‘fair and safe’ by our review team, it must enforce the maximum bet rule for bonus play. That means that the casino’s system must prevent players from placing any bet higher than the limit.

4. Withdrawal limits

Withdrawal limits restrict how much players can withdraw in a certain period of time. They can be different for various payment methods, but there is always some limit on how much a player can withdraw in a certain time frame (e.g. 1 day, 1 week, or 1 month).

Withdrawal limits can create situations, in which a large win is paid out to a player not at once, but in a number of smaller payments across a longer period of time.

Note: Sometimes, low withdrawal limits (or slower withdrawals) are not present just because the casinos want to have them, but because of external factors, such as legislation, available payment methods, etc. We view these factors as extenuating circumstances when reviewing casinos’ withdrawal limits.

Casino's point of view

Casinos generally use withdrawal limits to protect their cashflow, i.e. to avoid having to pay out a big win at once and causing issues to the company’s financials.

Player's point of view

Players generally want to withdraw their winnings all at once, regardless of their size. Deposits are often unlimited and instant, so players don’t understand why they should wait for their winnings to be paid out to them, which can take months in case of a big win and low withdrawal limits.

Our position

In the best-case scenario, there shouldn’t be any withdrawal limits. However, we know that they are not going anywhere, and we accept them as a part of the online gambling ecosystem if they are big enough. If they are too limiting, we decrease our reputation rating of the casino in question.

Our recommendations for casinos

Players should be able to withdraw their winnings, even if big, in a reasonable amount of time. We tolerate withdrawal limits of at least $10,000 per month, but, of course, the higher the better. Anything lower than that can be very restrictive for players.

Withdrawal limits should not be applied to progressive jackpot wins, as they are not paid out by the casino.

Note: If a player can’t withdraw their winnings all at once because a limit related to the used payment method, we recommend discussing the issue with the player and trying to find another option which would allow for a faster withdrawal.

5. Restricted countries

All casinos accept players only from some countries, with the rest of countries being restricted. That means that players from those countries are not allowed to open an account and play in the casino. This is the same for all gambling sites, but what differs is how casinos deal with players from restricted countries.

Casino's point of view

Many casinos only state the restricted countries in their T&Cs, and it’s the responsibility of players to check whether they are allowed to play at them or not.

Whenever someone from a restricted country registers, these casinos allow them to create an account, and only let them know about the restriction when they want to make a withdrawal. As long as a player is losing, the casino is OK with it, but as soon as the player wins and wants to withdraw money, they use the ‘restricted countries’ rule to decline the withdrawal and block the player’s account.

This is, of course, extremely unfair, as players might register without knowing about the restrictions, and casinos are taking advantage of their mistake, often knowingly and intentionally.

Player's point of view

If a player is able to access the casino’s website, open the registration form, create an account, deposit, and play, it’s understandable that they assume that they are allowed to play at this casino.

Some experienced or careful players might read the T&Cs and find out that their country is restricted, but these are definitely just a minority.

Our position

It’s not acceptable to let players gamble if you know that they are from a restricted country, and you plan to refer to the rule about restricted countries whenever a player requests the first withdrawal. This is completely against the rules of fair play, as you are knowingly letting a player wager money without a chance to actually win something.

Many casinos claim that this is difficult or impossible to implement into their systems, but it’s just about comparing the player’s country of residence with the list of restricted or allowed countries, so we don’t consider it to be that difficult on the technological level.

Our recommendations for casinos

The right thing to do is to check for restricted countries during the account creation process, and to not allow players from restricted countries to register and play. If you know your restricted countries and know the player’s country of residence, it can’t be an issue to enforce this rule.

If you allow a player from a restricted country to play because you haven’t implemented this check, you should accept that it was your mistake and pay out any winnings to the player despite the fact that they shouldn’t have been allowed to play in the first place, provided that the player hasn’t done anything else that’s against the rules.

Requirements for both ‘fair casinos’ and ‘fair and safe’ casinos

For a casino to be classified as ‘fair’ or ‘fair and safe’ casino by our review team, it can’t allow players from a restricted country to create an account and play. The check for restricted countries must be done during the account-creation process.

6. Restricted bonuses

Casino bonuses are also generally offered only to players from certain countries. This means that only some players can get a certain bonus. However, the same issue as with restricted countries applies here as well.

Casino's point of view

Some casinos only list the restricted countries in Bonus T&Cs of each specific bonus and claim that their system is not able to make sure that only players from eligible countries actually get the bonus.

This is extremely unfair towards players for reasons similar to those listed in the previous situation (Restricted countries), as we’ll mention below.

Player's point of view

If these bonus restrictions are not technologically enforced by the casino, players can get a bonus which they shouldn’t have gotten, and only find out about the restrictions when the casino declines their subsequent withdrawal. This means that a player can play with bonus money, and only find out about the restriction if they win and want to withdraw their winnings. Just as before, players are essentially gambling without a chance to win.

If a player can claim a bonus in a casino, they assume it’s theirs to play with. They have no reason to think that they shouldn’t have gotten the bonus in the first place. This is why it’s often very startling when they run into withdrawal issues because of this rule and its improper implementation.

Our position and recommendations for casinos

We believe that casinos should be equipped to only give bonuses to eligible players. And if they aren’t, they should let players withdraw their winnings even if they are from a country which is restricted for bonuses. In other words, once a player gets a bonus, casino shouldn’t take it away from them nor confiscate any winnings that originated from that bonus.

This issue often starts with advertising communication. Casinos or their affiliates often send out e-mails about new bonus offers also to players who are not eligible to get them. Players then have every reason to believe that the bonuses are available to them, which might not be the case according to the Bonus T&Cs. Information about bonuses should only be sent to players who are eligible to get them.

To sum up: Only give bonuses to players who are allowed to get them according to the Bonus T&Cs. And if you make the mistake of granting a bonus to a player who shouldn’t have gotten it in the first place, don’t take it away from them. Accept that it was your mistake and pay out the winnings to the player.

Requirement for both ‘fair casinos’ and ‘fair and safe’ casinos

For a casino to be classified as ‘fair’ or ‘fair and safe’ casino by our review team, it can’t allow players to receive a bonus which is not meant to be received by them because of country restrictions.

7. Deducting money from dormant accounts

Dormant accounts are accounts which haven’t been used by players for a longer period of time. After a certain number of days (e.g. 180) of inactivity, some casinos gradually confiscate the money left in the accounts of inactive players.

Casino's point of view

Casinos are not banking institutions and have certain costs associated with keeping money in player accounts for prolonged periods of time. They deduct money from dormant accounts to cover these costs.

However, there are also casinos, which knowingly use the ‘dormant accounts’ clause to earn some extra money at the expense of players which might have forgotten they’ve left some money in their casino account.

Note: While most casinos have a ‘dormant accounts’ clause, not all of them actually act on it. Some casinos, which value their players and want to keep them happy, will return all money to players even after years of inactivity.

Player's point of view

While casino accounts are very different than bank accounts, some players may think of them similarly. If they leave some money in their player account, they expect to find it there later on, even if they haven’t played for a long period of time. This is why they may be very surprised and dissatisfied to hear that a casino wants to deduct money from their remaining balance or has already done so.

Our position

Deducting money from player accounts is a standard practice in online gambling. We understand that casinos are not obliged to hold account balances which are not being used to gamble on a long-term basis.

However, we think that casinos should wait for at least 360 days (180 is the bare minimum we tolerate without decreasing the casino’s reputation rating) before taking anything and use all possible ways and tools available to them to let the players know about this in advance. If they don’t, it’s simply unfair.

Of course, casinos usually claim to make a ‘reasonable effort’ to contact the inactive players and let them know before confiscating the money, trying to get them back to either play or withdraw their money from the casino.

The issue is defining what ‘reasonable effort’ means. When judging complaints, we have no way of knowing what types of communication a casino used trying to contact the player, and how much effort has been made in the process. Either way, we think that using just e-mails is not sufficient to be classified as ‘reasonable effort’, but it is the bare minimum the casinos should do.

The amount of money deducted from the player’s account should also be reasonable. Money should never be taken all at once, unless the player has only a couple of cents left in their accounts. We consider 5% of the remaining balance the maximum which should be taken each month, but we would like to see even lower percentages here. If the casinos deduct a fixed amount of money each month (instead of a percentage of the remaining balance), this amount should also be reasonably low, let’s say not higher than €/£/$20.

Our recommendations for casinos

Whenever a player has been inactive for a long period of time, the first thing to do is to contact them. Whenever possible, we suggest returning the remaining balance (minus the processing fees) to the player by a withdrawal. If the remaining balance is lower than the minimum withdrawal limit, it’s OK to confiscate it, but rules mentioned in the following paragraph should be applied to this amount, too.

If you still decide to deduct some money from the player’s account after a period of inactivity, we think these rules should be followed:

  • Wait for at least 180 days before you deduct anything.
  • Do everything you can to contact the player beforehand. Use methods like e-mail, text message, phone call and physical mail. Start from the "easiest" one (e-mail) and move to other methods if the previous ones were unsuccessful.
  • Never take more than 5% of the remaining balance or €/£/$20 per month from the player’s account (lower value applies).

Requirement for both ‘fair casinos’ and ‘fair and safe’ casinos

For a casino to be classified as ‘fair’ or ‘fair and safe’ casino by our review team, casinos must follow the recommendations listed above.

8. Betting patterns

Some casinos forbid using betting patterns in their T&Cs. Then, if a player is discovered to be using the forbidden betting patterns, the casinos often decline their withdrawals and confiscate their winnings.

Casino's point of view

Casinos use this rule to protect themselves against bonus abusers, which can often be identified using their betting patterns. However, some casinos also apply this rule to regular players and use it as an excuse to decline withdrawals of legitimate winnings.

Note: Bonus abusing can work even with a constant bet size, as we describe in our bonus hunting article. So, using betting patterns as a way to stop people from abusing bonuses doesn’t really hold up.

Player's point of view

Players want to play the way they prefer. Because all casino games have a certain house edge, they don’t see any reason why they should avoid certain types or sequences of bets.

Our position

We consider cases in which casinos use the ‘betting patterns’ rule to confiscate player’s winnings to be unfair.

Note: In some cases, betting patterns can theoretically be used to identify fraudulent behavior. We have nothing against this, if betting patterns are used to uncover which can really be considered as fraudulent and not just used as an excuse not to pay out winnings to players.

Our recommendations for casinos

Our recommendation is quite simple – don’t use betting patterns as an excuse not to pay out winnings to players. They can be a sign that will tell you that a player is doing something else that’s against the rules, but they shouldn’t be the sole reason to penalize players.

Another issue is the way betting patterns are defined. Theoretically, any sequence of bets can be called a betting pattern. If you wanted to go against our recommendation and forbid the use of some betting patterns, they should at least be specified in detail, so that players know what they can and cannot do. Otherwise, the ‘betting patterns’ rule could be used basically against everybody. We don’t like that, and neither will players if you use it against them.

That said, we still think forbidding betting patters is not acceptable.

9. Bonus hunting (bonus abusing)

Bonus hunting (or bonus abusing) is a term used to describe the activity of actively and systematically trying to use online casino bonuses to make money. Casinos often include clauses about bonus abusers in their T&Cs, which allow them to withhold the winnings of players suspected to be abuse bonuses.

Casino's point of view

Bonus abusers can be costly for online casinos. They try to use casino bonuses and play in specific ways to gain a statistical advantage over the casino. And because casinos base their entire business strategy on the advantage they have over players (the house edge), it’s understandable that they want to protect themselves.

Casinos often use anti-bonus abuse clauses in their T&Cs retroactively, confiscating winnings after the wagering requirements have been cleared and the player has asked for a withdrawal.

Player's point of view

If a player has gotten a bonus, they don’t expect that it will be taken away from them. They expect to be able to play with the bonus and withdraw money if they manage to win.

If a player is not a bonus abuser, they most likely don’t know that something like bonus abuse even exists. If a player is a bonus abuser, it’s a bit different, but still – if they get a bonus, they expect to be able to use it to play and possibly win money.

Our position

If a player uses their own personal information to create a casino account, doesn’t have duplicate accounts, and follows other rules in the T&Cs, we think that they should be able to use a casino bonus which has been given to them in any way they want.

Note: We don’t condone bonus hunting which involves using other people’s personal information to create more accounts in casinos, even if the people in question are fully aware of it.

We don’t support taking winnings from players after they’ve fully cleared the wagering requirements without breaking other rules for bonus play, even if the casino suspects that the player is a bonus abuser. If a player has gotten a bonus and played with it, they deserve to keep the winnings.

Our recommendations for casinos

To battle bonus abusers, we recommend using Bonus T&Cs to limit the players’ ability to abuse your bonuses. This way, you can make your bonuses basically unexploitable, which means you don’t have to worry about bonus abusers.

If you don’t want to do that, you can try to identify bonus hunters when they are creating their accounts. If some of them still gets through this procedure and you identify them as a bonus abuser based on their style of play, you can add an internal note and stop offering bonuses to these players.

10. Self-exclusions

Players have the ability to self-exclude themselves from playing at a certain casino, as a part of responsible gambling practices. By using this feature, the players let the casino know that they don’t want to be allowed to play during a certain period of time.

This generally can’t be cancelled; the player has to wait until the period is fully over before they can play again. Some casinos allow players to cancel their self-exclusion after a cooling off period which gives them time to think whether they really want to do it or not. Some casinos also let players cancel their self-exclusion instantly, but that’s strictly against responsible gambling principles.

Self-exclusions and related casinos

Some casinos that operate as a part of a bigger group state in their T&Cs that after self-excluding in one casino, players shouldn’t play in other casinos in that group either.

This is understandable, but enforcing this rule is problematic. We’ve seen cases in which a player which has self-excluded from one casino started playing in another casino from the same group. The casino didn’t stop this player from playing; however, when the player later requested a withdrawal, it was declined because the player wasn’t supposed to be allowed to play in the first place.

There is an issue with this, because it’s very likely that the casino would have kept the player’s money if they didn’t manage to win. But the player won, so the casino took advantage of the self-exclusion clause in their T&Cs and declined the player’s withdrawal.

This is clearly unfair towards players. Rules like these should be enforced proactively. If players are not supposed to play at a casino, they simply shouldn’t be allowed to. This might not be the easiest thing to implement, but casinos should have their own software under control and be able to protect players this way.

Casino's point of view

Casinos generally want to make sure their players can gamble safely, which also includes giving them an opportunity to fully exclude themselves from playing. They don’t want to make money off problem gamblers, which is exactly who the self-exclusion feature is made for.

However, some casinos claim that they can’t fully implement self-exclusion, and there are still some gambling sites which don’t have this option.

Player's point of view

Players who are experiencing problem gambling issues need the option to self-exclude, because their gambling habit has gotten out of control. If a player wants to gamble during the self-exclusion period, it’s likely that it would actually be against their own interests to let them do it, because of the lack of control their might have.

Our position

All casinos should have well-executed responsible gambling options, which involves self-exclusion. Whenever a player self-excludes, they shouldn’t be allowed to play until the predefined period of time is over.

Although there may be cases in which the casino really wants to implement self-exclusion but can’t, we believe that most of casinos without self-exclusion (or with poorly implemented self-exclusion functionality) deliberately exploit addicted players, which we are strictly against.

Our recommendations for casinos

The self-exclusion process should be as user-friendly as possible. The tools designed to help players experiencing gambling problems should be easy to use, so that players are not discouraged from using them when needed.

The self-exclusion policy should be strict. If a player asks to be excluded, don’t let them play until the predetermined period is over. Under no circumstances should they be allowed to cancel their self-exclusion without a cooling-off period. Ideally, they shouldn’t be able to cancel it at all.

If your casino belongs to a bigger group of casinos, players should be made aware of this when self-excluding. The ideal thing to do is to give them the option to self-exclude only from one casino or self-exclude from all of them. All casinos should be listed, because players will not know which casinos are related otherwise.

Regardless of what they do, if you let them play despite a self-exclusion in a related casino, the fact that they were not supposed to play can’t be used as a reason to withhold their winnings.

Requirement for both ‘fair casinos’ and ‘fair and safe’ casinos

For a casino to be classified as ‘fair’ or ‘fair and safe’ casino by our review team, it must allow players to self-exclude from playing. If casinos allow players to cancel their self-exclusions, they need to be required to first wait through a cooling-off period of at least 7 days.

11. Player verification and duplicate accounts

In a vast majority of casinos, players are only allowed to have one player account per casino. Opening more than one account is against the T&Cs, and duplicate accounts are generally closed after being discovered.

Most casinos only check for duplicate accounts as a part of the verification process which is generally done when a player asks for a withdrawal. If a player wins something on one of the duplicate accounts, the winnings are generally annulled. In some cases, the initial deposits might be returned to the player, if the casino believes the duplicate account was created on accident.

Casino's point of view

Casinos only allow players to create one account to protect themselves against bonus abusers. Opening multiple accounts and trying to claim the welcome bonus more than once is one of the small number of ways players can use to gain an advantage over the casino, or at least make the casino’s advantage smaller. That’s why it makes sense that casinos protect themselves by closing duplicate accounts.

Player's point of view

Some players create multiple accounts on purpose (to abuse the welcome bonus), but it’s often the case that players simply forget that they have already registered at a casino some time ago and unknowingly create a new account.

Sometimes, players want to log in to their old account and don’t remember their own password. Instead of going through the ‘forgotten password’ procedure, they create a new account, perhaps not knowing that they are doing something that’s against the rules.

Either way, we think that players shouldn’t have to worry about accidentally creating duplicate accounts at the same casino.

Our position

We accept that it’s the responsibility of players to make sure they don’t create multiple accounts at the same casino. Not because we think it’s the right way to do it, but because it’s the industry standard and we can’t penalize all casinos that don’t enforce the ‘one account per player’ rule the way we consider best. However, we believe and hope that checking for duplicate accounts during account creation will become the industry standard in the future and players will be more protected.

In the meantime, we believe that each case should be considered separately. If you find out that a player has created 5 separate accounts and claimed the full bonus amount on each of them, it’s likely that it’s a bonus abuser and you have every right to penalize them. On the other hand, if a casual player mistakenly creates two accounts and doesn’t even claim the bonus, you shouldn’t penalize them just because you have a rule you can use against them.

Our recommendations for casinos

To prevent duplicate accounts, we think it’s feasible and effective to check for duplicate accounts during the account creation process. By this, we don’t mean a full KYC procedure that would involve ID verification; we suggest just a quick check of a combination of personal details which will be shared by two people only in very rare exceptions, such as first name, surname, and date of birth. If you don’t require this information during the registration process, you should start doing so to be able to do this.

In most cases, you will not get a match, and you can let the player play, only triggering a full KYC procedure when the player submits their withdrawal request. However, if you get a match, it’s likely that the player already has an account. In these cases, you can notify the player and/or ask them to complete a KYC procedure, making sure that they don’t already have an account.

If this is not technologically feasible, you still shouldn’t punish players who created a second account unknowingly and didn’t intend to abuse your welcome bonus. If the player hasn’t caused you any harm, it’s best to close all of their accounts but one and move funds from other accounts into it.

Requirements for ‘fair and safe’ casinos

For a casino to be classified ‘fair and safe’ by our review team, it needs to check for duplicate accounts during the account-creation process, not when the player asks for a withdrawal. This doesn’t mean doing a full KYC procedure; just a quick check of personal details sufficient to detect duplicate accounts is sufficient.

12. Enforcing rules

Whenever a casino finds out that a player has broken some rules described in the T&Cs, there are different approaches which can be used to handle the situation.

We’ve witnessed many cases of casinos informing players that they’ve breached the T&Cs, their account will be closed, and winnings voided, without providing any further information about what the players have actually done. At this point, the casinos often stop communicating with the players, leaving them clueless, confused and angry.

Casino's point of view

When casinos find out that a player has done something against the rules, they generally don’t care about how they deliver this information. They just want to make sure that the player knows that they’ve done something wrong, informing the player about any losses (in the form of withheld winnings, canceled bonuses, etc.) they are about to suffer.

Player's point of view

Whenever a player is accused of doing something against the rules, chances are that they have no idea what the casino is talking about. If they are not given a definitive answer, it’s understandable that they will want to investigate the issue further and get more specific reasons.

Our position and recommendations for casinos

If you decide to punish a player for doing something wrong, the least you can do is to let them know how specifically they’ve broken the rules and which rules they’ve broken. You should include at least this information in the message informing the player about the issue:

  • which rules they’ve specifically broken (don’t just quote the entire T&Cs),
  • when and how the player has broken the rules,
  • how the player will be penalized and whether there is something they can do.

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