L&L Europe: “We have found UKGC's guidance exceptionally useful in pushing for stronger RG”

L&L Europe stole the thunder at the Casino Guru Awards, winning the Operator Category in The Best Implementation of Responsible Gambling tools, impressing an expert panel of judges.

Yet, the company has had much insight to offer in the post-awards ceremony, detailing its hard work, and embracing regulatory guidance to help create a better Responsible Gambling framework that allows it to solve practical problems in the industry rather than second-guess the nature of certain regulatory changes.

As a result, L&L Europe is not just happy to impart any knowledge it has attained through hard work but is also happy to proactively show regulators how it builds a cohesive if demanding ecosystem to make sure players are protected. Much of today’s success in RG, the company attributes directly to the UK Gambling Commission and the watchdog’s guidance.

Q: You have won in The Best Implementation of RG Tools for operator as part of the Casino Guru Awards 2024. What were the efforts that led to this victory and why do you think you secured this accolade?

As an operator it is a huge honour to be nominated for, yet alone win an award in the safer gambling sphere. I honestly have to say that the Gambling Commission had a big part to play in us receiving this award, as they’ve been keeping us on our toes quite a bit over the last couple of years. They provide incredible guidance on their expectations for the market and give tailored feedback during assessments on our safer gambling work with customers. The path to this award was forged between years of operator and regulator coming together, L&L Europe and the Gambling Commission, and creating what I consider to be top level customer protection systems.

A key turning point in this journey was coming to a better understanding of the Gambling Commission and seeing that their actions with us, and other operators, are built upon trustworthy processes. From their initial assessments with us, there was quite a bit of fear and apprehension as we did not have much experience working with the Gambling Commission. After the assessment we would be left with their list of expectations for improvements but without clear guidance on how to accomplish them all. We thought "We want to succeed, just tell us how!".

It would be impossible for the Gambling Commission to directly specify how to do things for every licenced operator, who all have different types of back offices, third party integrations, internal procedures, and organisational structures. Not to mention, if they were too specific, it wouldn’t leave much room to detect the ‘bad apples’ in the industry. Over time, it became obvious that the regulator simply wanted to see improvements towards their expectations. Some expectations were very much black and white, while other areas allowed us to be creative in coming up with solutions. Through this partnership of sharing ideas, showcasing our developments, and improvement over time, the responsible gambling tools and services we have today were built.

Another important aspect is having the buy in for responsible gambling coming from the top of the company. Without this, we would have never achieved the Casino Guru award. We are lucky to have Christopher Dalli as our CEO who provides the leadership necessary to meet the ever changing and growing compliance requirements within the gambling industry. As a commercial business, it’s not always easy to find leadership that will put compliance at the forefront. All of L&L Europe needed to adapt to the changes the responsible gambling team were making; From the affiliate team changing deals, the customer support team making safer gambling interactions, the due diligence team combining AML and RG checks, and so on. The whole company is aligned with responsible gambling and breaking free from that siloed thinking was a bold move towards our current success.

Today our mindset has completely shifted from the fears and uncertainty we had from our first Gambling Commission assessment. We are excited to show them our work and we love to talk about what we are doing. Being in that position is not only a great feeling for the responsible gambling team, but for the whole company, where everyone knows we are doing our best to minimise harm.

L&L Europe is truly built around providing wonderful customer experiences within a proven safety net and that is where we could prove to the Casino Guru judges that this accolade would not be amiss if it went to L&L Europe. We are grateful and honoured to have been judged by our peers to not only be nominated, but to take home this special award.

Q: Your company went through an equally demanding evaluation process as all other contenders. What did you think of the process itself and do you think the way Casino Guru judges weighed in on your product offers a scrupulous enough assessment of RG Tools and the efforts to make them more impactful?

The evaluation process for the Casino Guru Awards is incredibly rewarding and thorough. Applying to an award category was enjoyable as we reminisced about what L&L Europe developed and achieved over the years. It also demarked a shift in our responsible gambling department where we realised we had made it. This was the right time for us to apply for an award. That doesn't mean the cycle of improvement ends, but we had reached a level of strength in our processes and procedures which endured scrutiny and garnered positive feedback.

First off, we really appreciate that the Casino Guru Awards are not pay to play. This helps even the smallest operator to pitch their name into the ring and completely removes the perception that award nominees are only for companies that buy a VIP table. I think the point is proven in the diverse nominees at the awards, rather than a repetition of brands who seem to simply pass an award back and forth between each other every year.

Next, the judging panel was amazing. A wonderful and varied group of experts in their fields. Being able to pitch our nomination and know that it will be seen by these incredibly talented people was already exciting. We are passionate about responsible gambling and pitching our work to them was a dream. The live Q&A session with judges also made the selection process fantastic as the questions were not known in advance. Nominees had to be able to discuss their work from any angle at the drop of a hat. This allowed for further scrutiny and details to be shared and show the character of the nominee.

I think our openness on our responsible gambling procedures, data, and analysis of outcomes helped convince the judging panel that we had something special. We are always happy to speak with others about our work as we do not view responsible gambling as a competition. All operators should be looking to do their best for customers and keep the image of gambling businesses positive. Sharing our well-earned experience and best practices is second nature to us. The awards nomination process felt not much different than how we would talk to another operator, although this was on a bigger stage.

Q: You have had close to a year from the moment you applied to the Casino Guru Awards 2024 ceremony. Could you highlight some of the achievements in implementing RG tools that you have reached during that period?

Our biggest project of 2023 and even going into this year is our responsible gaming matrix, which doesn’t yet have a catchy name like Entain’s ARC. While it isn’t a direct tool for customer use, the set up for this system will greatly enhance our detection and tool implementation for potentially at-risk customers.

The Gambling Commission’s newest SR guidance 3.4.3 on customer interaction makes it very clear that operators need to use a combination of human and automated interventions for the customers who need it most. Now, when looking at automations you always run the risk of false positives and needlessly interfering with non-risk customers, which isn’t good for the overall customer experience, especially when it has the capacity to outright shut off someone’s gameplay entirely.

This makes it a very delicate system to build, especially with us not being the biggest operator around. I envisage this to be an ongoing project for the long-term, with us consistently refining and tweaking parameters and analysing the results. It’s only been six months since this guidance came out, and we’re already going into version 2.0 of the system in the coming days. 2.0 sees significantly higher levels of parameters that consider everything from customer behaviour, tool usage, demographics, affordability, and room for manual scoring to be added for factors that fall outside the possibilities of automation.

In its final form the system will run across the whole database and make very quick decisions for the appropriate customers. The resulting actions will be tailored based on the risk observed and will take a variety of actions from setting of limits, triggering of interactions, restrictions on certain offers, or total account restrictions for the most at-risk customers. All of these decisions will then notify our responsible gaming team for which will make a manual review so to ensure the action was appropriate, and that the customer gets an avenue for disputes should they wish to do. It will also ensure our eye is always on the ball with who is/isn’t being flagged, so we can make further enhancements.

Q: Looking ahead in 2024 and beyond, what immediate priorities do you have to continue strengthening your RG Tools?

The exciting areas in 2024 will mainly be the UK White Paper consultations coming into fruition. We have followed the developments closely and are speaking to operators and suppliers to ensure we are ready for the new requirements. We tend to take many of the emerging UK regulations and experience across to our other markets as we want our colleagues to be proud to work at a company that focused on doing the right thing, rather than making a convoluted web of exceptions. Being at the forefront of player protection is a keystone of everything we do.

One contentious aspect of the White Paper is the affordability checks which were recently debated in Parliament. Our response to the consultation was that we are in favour of affordability checks and happy to see Current Account Turn Over (CATO) data is possibly making a comeback. L&L Europe are likely one of the few operators who have used CATO data for affordability checks in the past. It was unfortunate when the banking sector removed access to this dataset from our market.

When we had CATO affordability checks, we found it to be an extremely helpful responsible gambling tool. The data was sent through frictionless for nearly all customers and provided a clear indication of financial risk and insight on discretionary income. Additionally, the check would continue to run monthly where it would highlight current risks such as job loss, income changes, overspending, and so forth. While SCOR data will also be tested by the Gambling Commission in their upcoming pilot, we found that CATO did a great job on its own.

The next development priority for us would be to further our implementation of OpenBanking. We believe this could become so commonly used in the UK gambling market that it would possibly supersede the need for a CATO check. OpenBanking also enables synergy between the AML and RG teams as source of wealth/funds and the responsible gambling check are combined with the available granular customer data. Additionally, it streamlines and reduces the friction of these checks for customers, which is a win/win.

And finally, 2024 will see the development of AI tools and new ways to provide customer interactions. AI is still a very new, but powerful, tool that can supercharge responsible gambling teams. What we have experienced over the years is that getting a new tool needs to be done carefully. If you do not understand the problem you are trying to solve, then an answer that promises everything is quite alluring. However, adding more complexity to a system with a tool that looks great doesn't mean that you will get the desired outcome. In the ever-expanding pool of options and services offered to operators, we want everyone to remember the basics. Are you interacting with customers well? Are you reducing the volume and velocity of deposits? Are you informed of true affordability at an appropriate threshold? Are you consistently evaluating the outcomes for customers? Stick to these guiding principles and 2024 will see you on the right side of safer gambling compliance.

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