Fair Gambling Codex: Our Views on Problematic Areas

last updated 

13 Aug 2025

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by 

We believe online gambling should be fair. While this requires players to act fairly and without malicious intent, it is mostly the casino's responsibility to make sure gambling remains fair and safe for players.

We have witnessed pretty much all types of conflicts between casinos and players when dealing with casino reviews and player complaints, and this experience has helped us form strong views and policies regarding 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 first it's important to define two terms – 'fair casino' and 'fair and safe casino'.

Even casinos with fair rules and good approaches 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. This is why we believe all rules should be technologically enforced by the casinos to stop players getting into trouble by accident.

As one of our goals is to actively contribute to the improvement of the overall quality of online casinos, we have 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 mentioned above.

Not many casinos can be called 'fair and safe casinos' according to our criteria at present, 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.

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

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 casinos in online gambling, and players shouldn't have to painstakingly watch everything they do just so that they don't accidentally make a mistake.

Below, you can find multiple problematic areas we have 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

Each casino has its own terms and conditions (T&Cs) that specify the relationship between a player and the casino, as well as the 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).

The 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 accidentally. 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 that 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 perhaps do not consider how their rules influence players.
• Some casinos hide rules on purpose and/or include predatory rules in their T&Cs to rip off players and increase their profits.

The player's point of view

There are a few players who read the T&Cs before creating a casino account, but the majority of them do not. Even if players do pay attention to the T&Cs, most only check certain parts of the conditions, such as restricted countries.

Players expect casinos to follow certain best practices and therefore do not consider it necessary to read everything. They don't expect to find predatory rules in the T&Cs. Also, some players might not be experienced in online gambling. They may not notice that some rules are predatory, even if they do read the T&Cs fully.

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

Our position

We do not tolerate any hidden or predatory rules because 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 Safety Index of the casino and also try to convince them 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 fully understood by players. The entire system should be set up in a way that doesn't allow players to break the T&Cs unknowingly. All rules should be listed in one place (in the T&Cs), and they should not be unfair and/or predatory (see examples of hidden and predatory rules below).

Our recommendations for casinos

Every single rule that players are required to follow should be stated in the casino's general T&Cs or in the Bonus T&Cs of each bonus. The casino should never try to apply rules that are not stated publicly, as players have no way of knowing 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 sure the T&Cs are simple and easy to follow, and don't try to make up rules that can be misused against players who haven't done anything wrong.

Remember that a fair environment is good for casino business too. It is in the casino's interests to retain players and keep them active. If players experience an unfair approach towards them, they will no longer play on the casino website. And if the word about bad player experiences spreads, players could register in other casinos instead.

Examples of hidden and predatory rules

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

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

As already mentioned, all rules that players need to follow should be grouped together in the T&Cs. Some exceptions are understandable, such as bonus T&Cs, the privacy policy, etc. but hiding rules in FAQs where nobody expects to find them is clearly unfair and deceptive.

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.

2. Win limits

Some casinos enforce win limits that 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 – A 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 type of game.
• Total sum of wins within a time period – This type of win limit is applied to the total sum of individual wins over 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). Losses 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, while others might start dealing with the issue only after a player asks for a withdrawal.

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. That's why some game providers sign agreements with casinos, based on which the casino cannot withhold legitimate progressive winnings from the player but have to pay them out in full.

The casino's point of view

If casinos apply win limits because of laws and regulations that require them, there is nothing they can do about this, so we can't hold this against them. However, many casinos limit player wins 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 to 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. This being said, we still don't approve of them because they disadvantage players.

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

The 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 is devastating when a casino wants to take a big part of a player's winnings because of a win limit that they might not be aware of.

It is true that most players won't be affected by win limits if they aren't too low. This is why some players who know about win limits might not even care about them, provided that they are much higher than the amounts they are used to winning. This being said, their stance will obviously change very quickly if they manage to win a higher amount 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 cannot 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 that 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 (€500,000 for example), we still don't approve of it, but we are able to tolerate it in most cases (depending on the specifics of the limit), as long as it doesn't apply to progressive jackpot wins.

If a casino voluntarily applies a lower win limit, we decrease its Safety Index and warn players against the casino's restrictive win limit.

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. The casino shouldn't let players place bets that can theoretically yield winnings that the casino can't afford to pay out.

The casino 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 restrict their size unless it is required by the regulator.

3. Maximum bet rules

Many casinos limit the amount that players are allowed to stake on each bet, usually concerning the use of a bonus. Maximum bet rules regarding real money play are not as common, but unfortunately, they do exist.

Sometimes this kind of rule is put in place in accordance with local laws or regulations, so we can accept it as a necessary evil. Otherwise, if a player is only risking their own funds, we do not believe it is fair to confiscate a player's winnings because of such a rule.

The situation is a bit different where bonuses are concerned.

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

The casino's point of view

The bonus maximum bet rule is an industry standard in online gambling used by casinos to protect themselves against bonus hunters. Casinos feel confident about using this rule, and players who have played with a bonus will have their betting history checked thoroughly before any withdrawal is granted.

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.

The 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 are still a lot of players who are not aware of the maximum bet rule and might break it unintentionally. This could happen after a big win, when a player might naturally increase the bet sizes because of the increased bankroll. Additionally, players may not consider that the use of gamble buttons, feature drops, or bonus buys could also be viewed as making larger bets by the casino. Players feel cheated if their winnings are later taken from them in these situations because they weren't aware that they were doing something wrong.

Players don't want to painstakingly read all T&Cs or watch their bet sizes in case they accidentally bet too much. 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 bonus max bet rule is an industry standard, as is the fact that a casino has the right to seize the player's winnings from bonus play after breaking this rule. We prefer not to go against industry standards by penalizing casinos that use the maximum bet rule against players from time to time.

Nevertheless, we think that this rule should be enforced at the software level, i.e. the casino's software or website shouldn't let players place higher bets 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 on a prominent part of the page or advertisement informing them about the bonus, and not just "hidden" in the rules for bonus play. It is a common practice to only list the max bet in Bonus T&Cs, but we appreciate it when casinos make them more visible and easier to follow.

Our recommendations for casinos

In an ideal scenario, casinos should enforce their bonus maximum bet rules at the software level and therefore prevent players from placing higher bets than allowed. Also, if bonus features should not be used, they should be turned off, or access to those games should be blocked completely. This effectively removes all chances of player complaints related to the max bet rule, as players simply can't break it.

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

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. one day, one week or one 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.

The 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 all at once and to avoid causing issues to the company's finances.

The 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 away, so we accept them as a part of the online gambling ecosystem if they are big enough. If they are too limiting, we decrease the Safety Index 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. In our opinion, withdrawal limits should be at least $10,000 per month, but the higher the better. Anything lower than that can be very restrictive for players.

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

5. Restricted countries

All casinos accept players from certain countries only, with the rest of the countries being 'restricted'. This means that players from these restricted 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.

The casino's point of view

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

Whenever someone registers from a restricted country, these casinos allow them to create an account. Some casinos do not ask for country information at all when registering, and others have a list of many countries to choose from, including those that are meant to be restricted.

Many casinos only let the player know about the restriction after they have won and 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 these restrictions. Casinos are taking advantage of their mistake, often knowingly and intentionally.

The 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, especially when they can select their country in the registration form.

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

Our position

It is not acceptable to knowingly let players register an account from a restricted country only to later confiscate the player's winnings for doing so. This is completely against the rules of fair play, as the casino is knowingly letting a player wager money without a chance to actually win something in return.

Many casinos claim that this is difficult or impossible to implement into their systems, but it is simply about comparing the player's country of residence with the list of restricted or allowed countries; therefore, we do not consider it to be that difficult on a 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 the casino knows about restricted countries and also knows the player's country of residence, it's not a big issue to enforce this rule. It might also be a possibility to prevent players from restricted countries from accessing the website at all, and ideally only allowed countries should be listed in the registration form.

If the casino allows a player from a restricted country to play because it hasn't implemented these measures, it should accept that it was the casino's mistake and pay out all 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.

If a player's citizenship is also a factor, it should be clearly mentioned during the registration process that country of residence and citizenship are required information.

6. Bonus restrictions

Casino bonuses are generally only offered to certain players. There may be rules that state the bonus is only available to players from certain countries or players using certain payment methods.

The casino's point of view

Rules such as these can usually be found in the T&Cs for each specific bonus, with casinos claiming that their system is not able to prevent players from claiming bonuses that they are not eligible for. The player is expected to know and follow the rules, and the casino usually checks for this at the point a withdrawal is requested.

If it is discovered that the rules have been broken, the account will be closed and the balance confiscated. This is extremely unfair towards players.

The player's point of view

If these bonus restrictions are not technologically enforced by the casino, players can get a bonus that they shouldn't receive, only to find out about the restrictions when the casino declines their subsequent withdrawal request. This means that players are essentially gambling with no chance of winning.

If a player can claim a casino bonus, they assume it's theirs to play with. They have no reason to think that they shouldn't have received the bonus in the first place. This is why it is often very startling when they run into withdrawal issues because of the implementation of such rules.

Our position and recommendations for casinos

We believe that casinos should be configured to only give out bonuses to eligible players. Reasonable steps should be taken to prevent players from getting bonuses if they are not supposed to, and ideally these rules should be enforced via the casino software. If it is then determined that a player is not eligible to claim any bonuses, they can be restricted from doing so.

If the casino is not set up in this way, it should let players withdraw their winnings even if they have been allowed to use a bonus that they shouldn't have been able to claim. In other words, once a player gets a bonus, a casino shouldn't take it away from them or confiscate any winnings that originated from that bonus (unless some other rules have been broken).

Issues can also occur due to advertising communication. Casinos or their affiliates often send out e-mails about new bonus offers to players, including those who are not eligible to claim 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 claim them.

To summarize: Casinos should only give bonuses to players who are allowed to get them according to the Bonus T&Cs. If the casino makes the mistake of granting a bonus to a player who shouldn't have received it, the casino shouldn't take it away from them. Instead, the casino should accept that it was their mistake and pay out any winnings to the player.

7. Deducting money from dormant accounts

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

The 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 that knowingly use the 'dormant accounts' clause to earn extra money at the expense of players who might have forgotten that they left some money in their casino account.

The player's point of view

While casino accounts are very different to bank accounts, some players may think of them in a similar way. If they leave 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 that 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 that we tolerate without decreasing the casino's Safety index) before taking anything and use all possible means and tools available to them to let players know about this in advance. If they do not, it's simply unfair.

Of course, casinos usually claim to make a 'reasonable effort' to contact inactive players and let them know about it before confiscating any money. This is done to get them back to 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 type of communication a casino used to try and contact the player or how much effort was made in the process. Either way, we think that using emails alone is not sufficient to be classified as 'reasonable effort', but the bare minimum that casinos should make.

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 only has a couple of cents in their account. We consider 5% of the remaining balance the maximum that should be taken each month, but we would like to see even lower percentages. If the casinos deduct a fixed amount of money each month instead of a percentage of the remaining balance, this amount should be reasonably low, 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 is acceptable to confiscate it, but the rules mentioned in the following paragraph should be applied to this amount too.

If the casino still decides to deduct some money from the player's account after a certain period of inactivity, these rules should be followed:

• Wait for at least 180 days before deducting anything.
• Do everything possible to contact the player beforehand. Use methods like email, text messaging, phone calls and physical mail. Start with the "easiest" one (email) and then move on to other methods if the previous ones are unsuccessful.
• Never take more than 5% or €/£/$20 of the remaining balance per month from the player's account (lower value applies).

8. Betting patterns and strategies

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

The casino's point of view

Casinos mostly use this rule to protect themselves against bonus abusers, who can often be identified by 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.

The player's point of view

Players want to play the way they prefer. Because all casino games have a certain house edge, they see no reason why they should avoid certain types or sequences of bets.

Our position

We consider most cases in which casinos use rules regarding "betting patterns" or "strategies" to confiscate player's winnings to be unfair. You can read more detailed examples in our article about banning betting patterns and strategies.

Our recommendations for casinos

Our recommendation is quite simple: Don't use betting patterns as an excuse not to pay out winnings to players. These betting patterns can indeed be a sign that a player is doing something 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 the casino wishes to go against our recommendation and forbid the use of certain betting patterns, these should at least be specified in detail so that players know exactly what they can and cannot do. Otherwise, the 'betting patterns' rule could be used against everybody. We don't like this approach, nor will players if the casino uses it against them.

This being said, we still believe that forbidding betting patterns is unacceptable.

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, allowing them to withhold the winnings of players suspected of being bonus abusers.

The 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 statistical 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 a bonus has been claimed, the wagering requirements have been cleared and the player has asked for a withdrawal.

The player's point of view

If a player has received a bonus, they don't expect it to be taken away from them. They expect to be able to play with this bonus and withdraw money if they manage to win.

If a player is not a bonus abuser, they probably don't even know that something like bonus abuse exists. They also do not expect that they should have to monitor how many bonuses they claim, or how they play with a bonus.

If a player is a bonus abuser, the situation is a bit different, but if they do receive a bonus, they still expect to be able to use it and possibly win some money.

Our position

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

We don't support taking winnings from players after they have fully cleared the wagering requirements without breaking additional rules for bonus play, even if the casino suspects that the player is a bonus abuser. If a player has been able to claim a bonus and play with it, they deserve to keep the winnings.

Our recommendations for casinos

To battle bonus abusers, we recommend adjusting the Bonus T&Cs and applicable rules, such as the wagering requirements or maximum bet, to limit the ability to abuse casino bonuses.

When players are identified as bonus hunters based on their style of play, the casino should display an internal message and stop offering further bonuses to these players. Additionally, the mechanisms used to identify bonus hunters should be configured to minimize the chance of flagging recreational players as bonus hunters.

10. Restricted games for bonus play

Most bonuses are designed by the casino to be played on certain games, or at least certain types of games. Bets may contribute different percentages to the wagering requirements of the bonus in certain game genres, and some games may be completely excluded from use with a bonus.

Some casinos prevent players from accessing restricted games via the casino software, but most leave it up to the player to make sure they are following the rules.

The casino's point of view

It is an industry standard that bonuses can only be used on certain games, and a list of games the player should avoid using with a bonus is usually provided in the specific terms of the bonus or the general bonus terms and conditions.

If a player somehow uses one of these games with an active bonus, the casino generally considers it to be a breach of the terms and conditions and a reason to keep the winnings.

The player's point of view

While some more experienced players may be aware of this rule, there are many players who may not know about it. The list of restricted games can often be very long, and players do not want to spend time checking each game they wish to play to see if it is allowed.

Players may also assume that if the game can be accessed, there should be no problem with playing it.

Our position

We firmly believe that access to any games restricted from use with a bonus should be prevented by the casino software. In this way, the possibility for a player to make a mistake is removed.

If for some reason the casino software does not allow for this restriction, the games should be set up in such a way that they do not contribute to the wagering requirements of the bonus, meaning that no benefit can be obtained by playing them.

Our recommendations for casinos

If the restricted games are still accessible with the use of an active bonus, they should be set with a 0% wagering contribution as mentioned above. We do not consider it fair to confiscate winnings for playing a game that is available to be played.

11. Repeated application of bonus rules

As we have seen, most casinos have certain rules in place that players must adhere to when wagering a bonus, such as max bet and game restrictions. But what happens when all of the requirements have been met? Theoretically, any winnings should be made available to the player without further limitation. Unfortunately, it is not always that simple.

The casino's point of view

Bonuses usually consist of 'bonus funds' that are converted to winnings upon satisfying a wagering requirement, and by following the rules of the bonus T&Cs. If the player can meet these requirements and still have a balance left over, that balance will be added to their account as 'real money' winnings (subject to any limits).

The problem is that a lot of casinos continue to apply the rules of the bonus until the player has made a withdrawal of these winnings, and consider the funds to be "bonus funds" or "funds obtained from a bonus" until the withdrawal has been processed.

There is nothing in place to stop players from continuing to gamble with these funds, and of course they can still be lost to the casino. However, if a player manages to accumulate further winnings from these funds they may run into problems - such as having their balance reduced or even confiscated entirely - because of a bonus rule that they didn't know still applied.

The player's point of view

If all the requirements are met, and no rules have been broken, the player assumes that the winnings are theirs with no strings attached, especially if displayed to them as a "real money" balance in their casino account. They are allowed to withdraw these funds, so what could possibly be the issue with using these funds to play further?

Our position

It is unreasonable for restrictions to be applied if the bonus is finished. This creates a trap for players, because they are able to continue gambling but further winnings will still be subject to these limitations.

In an ideal world, we believe that once the wagering requirements of the bonus have been completed, the bonus winnings should have any win limits applied immediately and then be added to the player's real money balance. At this point, the bonus should be considered finished, and any related restrictions should no longer apply. The player should be able to withdraw the winnings or continue to play as they choose.

Our recommendations for casinos

When winnings from a bonus are added to a player's balance, assuming the wagering has been completed and any maximum win limits have been applied, they should be considered real money and treated as such. If a player chooses to continue to play with and risk these funds, they should be entitled to any winnings they obtain, in the same way as if they had deposited the funds into the account themselves.

If for some reason this is not possible due to the platform or software used by the casino, there should at the very least be an adequate warning presented to the player at the point the wagering has been completed (for example in a pop-up message or notification).

12. Self-exclusion

Players should have the ability to exclude themselves from playing at a certain casino as a part of responsible gambling practices. By using this feature, players let the casino know that they don't want to be allowed to play for a certain period of time, or even indefinitely. This could be for a number of reasons, but most notably because of problems such as gambling addiction.

Self-exclusion cannot generally 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, giving them time to think about whether they really want to do it or not. Some casinos also let players cancel their self-exclusion instantly. If the exclusion is due to a gambling problem, it should not be possible to cancel it at all.

Self-exclusions and related casinos

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

This is understandable, but the casino must ensure they inform the player of this rule and properly enforce it, or it can cause problems. We have seen cases in which a player has self-excluded from one casino and 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 playing in the first place.

There is an issue with this because it is very likely that the casino would have kept the player's money if they didn't manage to win. But the player did win, so the casino took advantage of the self-exclusion clause in the T&Cs and used it to decline 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 shouldn't be allowed to do so. This might not be the easiest thing to implement, but casinos should have their own software under control and be able to protect players in this way. It is especially important for players that are excluded due to gambling addiction, and they should not be allowed to play under any circumstances.

The casino's point of view

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

However, some casinos claim that they can't fully implement self-exclusion, and there are still some gambling sites that don't have this option. Additionally, casinos that collect little to no personal information about a player (for example 'Anonymous' casinos) are not able to effectively exclude a player, as there is no unique data by which to identify them and block them.

The player's point of view

Players who are experiencing problem gambling issues need the option to self-exclude because their gambling habits have gotten out of control. If a player wants to gamble during their self-exclusion period, it's likely that this could be against their best interests due to their lack of self-control.

Self-exclusion is intended as a tool to help players with gambling problems, but players also exclude themselves for a variety of other reasons. Exclusion means that casinos can no longer send the player marketing communication, so even players that do not have gambling problems might use this as a method to quickly cut all ties with the casino. Some casinos are aware of this, and so they do not treat exclusion requests with the necessary sense of urgency.

This is why we believe that stating if a self-exclusion is due to gambling problems from the beginning is a vital step that can prevent a lot of issues later on.

Our position

All casinos should have well-executed responsible gambling options that include self-exclusion at the very least. Whenever a player decides to self-exclude, the casino should determine the exact reasons for their decision. If it is because of a gambling problem, the player should be excluded swiftly and permanently. Otherwise, the player shouldn't be allowed to play until the predefined period of time is over.

Although there may be cases in which a casino really wants to implement self-exclusion but cannot, we believe that most casinos without a self-exclusion process (or with poorly implemented self-exclusion) deliberately exploit players with gambling problems.

Our recommendations for casinos

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

The casino's self-exclusion policy should also be strictly adhered to, and the casino should follow these guidelines:

Offer multiple ways to request self-exclusion

• The ability to request an exclusion via the player's account is recommended, as it is instant and there is little room for error.
• There should be additional options available (such as via e-mail or contacting live support), in case the player wishes to avoid logging in to their account entirely.

Process self-exclusion requests in a timely fashion

• When a player requests self-exclusion due to a gambling problem, the casino should process this request within a reasonable timeframe. There should be no option for the player to reopen the account. If the player still has money in their account balance, it should be returned to them without allowing them access to the account in any way that could allow further play.
• Immediate suspension is not required, but action should be taken promptly to protect the player.

Handle unverified accounts and pending withdrawals correctly

• If the player's account is unverified or there is a pending withdrawal, this should not delay the self-exclusion process.
• KYC (Know Your Customer) verification can be completed after suspension, but ensuring the player cannot lose their active balance, access pending withdrawals, or deposit additional funds is essential.

Send confirmation to the player

• The casino should provide formal confirmation to the player that their self-exclusion request has been received and processed.
• Maintaining records of players who requested self-exclusion but did not complete KYC is recommended for future reference.

Enforce self-exclusions

• If a player asks to be excluded for reasons other than gambling problems, 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 the casino belongs to a bigger group of casinos, players should be made aware of this when self-excluding. Ideally, players should be given the option to self-exclude from one casino only or self-exclude from all of them. All casinos should be listed, otherwise players will not know which casinos are related. If a casino lets someone play despite having a self-exclusion in a related casino, not being supposed to play should not be used as a reason to withhold their winnings.
• It should not be possible for a person excluded due to gambling problems to play at all. If somehow the casino allows such a player to play, they should not be able to win or lose, and all deposits should be returned to them.

13. Multiple accounts

In a vast majority of casinos, players are only allowed to have one player account per casino, as well as only one account per residence, IP address and device.

Opening more than one account is against the T&Cs, and duplicate accounts are generally closed after being discovered.

Most casinos only check for multiple 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 their duplicate accounts, the winnings are usually annulled. In some cases, the initial deposits might be returned to the player if the casino believes the duplicate account was created by accident.

The casino's point of view

Most 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 a small number of ways that players can use to gain an advantage over the casino or at least make the casino's advantage smaller. This is why it makes sense that casinos protect themselves by closing duplicate accounts.

Problems can also arise if more than one player from the same household opens an account. Due to shared details, such as residential address and internet connection, it is harder for a casino to determine if this is in fact two players or one player with two accounts, and often it will assume the latter.

The player's point of view

While some players do create multiple accounts with the intention of abusing the welcome bonus and gaining an unfair advantage, there are a number of situations where players might accidentally break this rule, or at least do so without any bad intentions. Some players register accounts at many different casinos, so they may forget they even registered an account previously.

Sometimes, players want to log in to their old account but don't remember their 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.

It is also common for players to recommend a casino to family members, friends, or partners in the same household, and they do not consider that this may cause issues later on.

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

Our position

We accept that it is the responsibility of players to make sure that 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 cannot 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 multiple accounts during account creation will become the industry standard in the future and players will be better protected.

In the meantime, each case should be considered separately. If the casino finds out that one player has created five separate accounts and claimed the full bonus amount on each of them, it is likely that this is a bonus abuser, and the casino has every right to penalize them. On the other hand, if a casual player mistakenly creates two accounts, only plays with one of them and doesn't even claim the bonus, the casino shouldn't penalize them just because it has a rule that can be used against them.

Our recommendations for casinos

To prevent such situations, it is feasible and effective to check for multiple accounts during the account creation process. We don't mean a full KYC (Know Your Customer) procedure that would involve ID verification, but a quick check of personal detail combinations that would only be shared by two separate people in very rare exceptions, such as first name, surname and date of birth. If the casino doesn't require this information during the registration process, it should start doing so. Additionally, the player's IP address could also be recorded and checked.

In most cases there will not be a match, and the casino can let the player play, only triggering a full KYC procedure when the player submits their withdrawal request. However, if the casino does get a match, it is possible that the player already has an account. In these cases, the casino should notify the player and/or ask them to complete a KYC procedure to make sure that they don't already have an account.

Even if this is not a technologically feasible solution, the casino shouldn't punish players who created a second account unknowingly and didn't intend to abuse the welcome bonus. If the player hasn't caused you any harm, and has gained no unfair advantage, it's best to contact them and find an acceptable solution for all involved parties, such as keeping one account open and closing the other one(s).

14. Player verification timeframe

In nearly all casinos, players are required to provide certain information about themselves as part of the "Know Your Customer" procedure. Normally, this process is initiated at the point a player first requests a withdrawal of their winnings, when a casino asks the player to submit a number of documents for verification.

Casinos tend to allow players a specific timeframe to provide the requested information, and should this request not be met, the player may find their account blocked and funds confiscated.

The casino's point of view

It is understandable that the casino requires players to prove their identity – this is a measure against fraudulent activity. Players need to show that they are using their own legitimate funds, in their own account and via their own payment methods, as well as providing acceptable forms of identification.

If these documents are not provided promptly, the casino assumes that the player is up to no good and confiscates their balance.

The player's point of view

While most players can also see the necessity of such checks, it may not always be possible to access and provide the requested information in a short period of time. There could be many reasons a player is not able to comply – what happens if a player is due to go on vacation, for example?

Casinos can request any number of documents, and in some cases, these might even need to be notarized, which could also take the player some extra time to complete.

Our position

We understand the need for KYC but believe that casinos should be more reasonable and not use a delayed submission of documents as a reason to confiscate a player's balance.

Our recommendation for casinos

In an ideal world, we would like to see no timeframe specified at all, with the player's account merely becoming inaccessible until the documents are received. If there is a suspicion of fraud, the casino should request further documentation or implement other methods, such as verification via video call.

If a timeframe absolutely must be implemented, the minimum we believe to be acceptable is 28 days (1 month). This should be enough time, in most cases, for a player to gather and send the necessary information.

15. Enforcing rules

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

We have witnessed many cases of casinos informing players that they have breached the T&Cs, accounts being closed and winnings voided, without providing any further information about what the players have actually done wrong. At this point, the casinos often stop communicating with players, leaving them clueless, confused, and angry.

The 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 they've done something wrong, as well as informing the player about any losses (in the form of withheld winnings, canceled bonuses, etc.) that they are about to suffer.

The player's point of view

Whenever a player is accused of doing something against the rules, the 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 answers.

Our position and recommendations for casinos

If the casino decides to punish a player for doing something wrong, the least it can do is to let the player know how they specifically broke the rules, and which rules were broken. The casino should at least include this information in the message informing the player about the issue:

• Which rules they specifically broke (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

16. Transparency

In this section we will talk about what information casinos should share with players. Specifically, we will discuss:

• The return to player (RTP) of available games – The RTP of the game is arguably the most important mathematical characteristic of each casino game. It tells players which games are better, and which are worse for them from a mathematical point of view.
• Game and account history logs – Giving players the possibility to check their game history and find out how much money they have won or lost over time is a very welcome tool, but, unfortunately, not many casinos do this the right way.

The casino's point of view

Not all casinos want to make information such as RTP and account history easily available to players because it lets players know how much money they can expect to lose (RTP) and how much money they've already lost or won (history logs). If a player realizes how much money they've lost over time, this could be harmful to the casino's business; therefore, it's better for the casino to keep this information hidden.

Casinos often claim that implementing this is difficult from a technological point of view, which can be true to a certain extent, but we don't see it as a valid reason for not implementing these 'transparency' features.

When it comes to RTP, it's true that some game providers don't publish the RTP of their games, so casinos might not have this information for all titles, but we're sure that they know the RTP of the vast majority of the games that they offer to players. It's just a matter of sharing it with players.

The player's point of view

Not all players care about their account history or the RTP of the games that they play, but we know that many of them do. Making this information readily available enables them to make good decisions regarding which games to play and whether they should be playing at all.

The history log is important as a responsible gambling tool as well because it lets players know how much money they have lost or won over time. It's very likely for frequent players to have lost more money than they've won since opening their account, but they generally don't remember this clearly and may underestimate their overall losses. This is why it's important for them to be able to get the actual numbers.

Our position and recommendations for casinos

All players should know the RTP of the games that they are playing. This information should be available as easily as possible and should (ideally, but not necessarily) be written directly in the browser window when playing the game.

Similarly, players should be able to access their account history and see how much money they've lost or won since opening their account.

We would like to see all casinos meet these criteria, although they are not part of industry standards at the moment. This being said, we hope that more and more casinos improve in this matter and make more and more information readily available to players in the future.

Published: 

25 Sep 2019