The Gambling Commission has reminded licensees in it’s most recent eBullitin that compliance with the Remote Gambling and Software Technical Standards (RTS) is required for regulatory compliance. Any form of breach must be reported to the Commission as soon as reasonably possible.

This follows the regulatory actions for both for Evolution Malta Holding Limited involving their games appearing on black market websites, and Stakelogic BV where the games were running faster than the required 2.5 seconds between cycles.

In the second instance, it was found that gambling software suppliers holding B2B licences reported RTS breaches, but the affected B2C remote operating licences did not.

Each affected licensee is responsible for meeting its own reporting obligations. Submitting a report as a software supplier does not automatically fulfil the obligations of an affected operator.

Therefore, operators should ensure that supplier notifications are escalated internally and assessed for their impact on the operator’s own compliance and reporting responsibilities.

REGULATORY REQUIREMENTS
Under the technical standards, Licence Condition 2.3.1 requires relevant licensees to comply with the Commission’s technical standards and requirements relating to timing and procedures for testing.

The reminder by the Commission explains that RTS breaches are potentially offences under section 33(2)(b) of the Gambling Act 2005.

Licence Conditions 15.1.1 and 15.1.2 require licensees to report information they know, or suspect relates to an offence under the Act. This includes offences that arise from a breach of of a licence condition. Reporting must be done as soon as reasonably practicable.

HOW TO REPORT

All reports must be submitted through the LCCP notification section of the Commission’s eServices platform.

LCCP Notification: Reporting offences/breaches

The notification should provide sufficient information for the Commission to assess the matter. This can range from businesses that are involved, details of the breach or suspected offence, the time it occurred, the action taken and a contact reachable for further enquiries.

OUR RECOMMENDATIONS
Read and review the reporting procedures to ensure that RTS breaches are properly reported to the Commission as soon as reasonably possible.

• Check the supplier notification arrangements in order for your business to receive timely information about technical issues affecting games or systems.
• Assign clear responsibility for assessing incidents and submitting regulatory notifications.
• Assess any outstanding technical incidents in order to establish whether your business has fulfilled its own reporting obligations.
• Keep clear records of any breach, affected products, reporting decisions, notifications and remediation. It is important that this is all documented.
• Assess staff training so that technical, operational and compliance teams understand when and how to escalate suspected RTS breaches.

Licensees should also review the Commission’s technical requirements and LCCP notification guidance against their current procedures.

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LINKS TO FULL DETAILS
See the Remote Technical Standards Here

See regulator actions for Evolution Malta Holding Limited and Stakelogic BV (links in text)