The Financial Fairness podcast

Guests: Rob Davies and Matt Zarb-Cousin

May 2022

In the UK we have a difficult relationship with gambling. A ‘little flutter on the horses’ or a weekly lotto ticket is a fiercely protected part of our culture. However, policy has not kept up with changes in the gambling industry, particularly the move to online gambling. How do we protect people better from gambling harms?

We speak to Rob Davies, journalist and author of 'Jackpot: How Gambling Conquered Britain' and Matt Zarb-Cousin, Director of Clean Up Gambling and co-founder of Gamban. Mubin talks to them about the techniques the industry uses to get you hooked, hears powerful testimony on the financial and mental health impact of gambling addiction and explores potential for future reform through the new gambling act.

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Transcript

Mubin: So Rob, this might sound like a stupid question but what actually counts as gambling? Other products are sometimes seen as being a form of gambling. For example, crypto currencies or even some forms of stock market trading. What would be your definition?

Rob: I don't know if it's a stupid question. It's a big question, one of the interesting characteristics of gambling is that it's a huge and diverse industry. So, you're talking about anything from the National Lottery weekly draw that some people might do from time to time, to  more high octane products like virtual sports, which is like a little fake sort of cartoon horse that goes around a screen and people can bet on that,

And, the difference between that and investing in shares or say cryptocurrency is complex. I mean, if you take something like online slot machines, that's just a random number generator, right. So that does differ from investing in, say, a company, which has sort of certain key fundamentals that you can look at and decide whether you want to invest in. There are probably more similarities with sports betting where you can bring some knowledge to bear on how you bet. But even then, you can't really be a long term investor in football betting. I mean, some might say you can, but it's not necessarily the same as storing your money in a pension fund that tracks the FTSE 100, for instance. So, I think there are differences there. And of course, there are regulatory differences – there is a gambling regulator, that regulates gambling, and there are all sorts of laws that cover that. And then there are financial regulators, that govern the stock market. And then there's almost no regulation when it comes to cryptocurrency, where people are kind of day trading, for instance, with crypto or with shares, making very quick transactions based quite often on sentiment - I think that is a bit more like gambling. And I certainly, that's where I see similarities, although the law doesn't treat it that way necessarily.

Mubin: I read in one of your articles that British punters lose more than £11 billion each year which is a huge sum of money and equates to £164 pounds for every man woman and child. Has that changed over the last few decades - what's been the long term trend, is it growing?

Rob: Yeah, if you include the National Lottery, it's about £14 billion, as I mentioned earlier, it's quite a diverse industry, right. So, there's lots of different things going on within those numbers. By and large, the figure has gone up. Once you factor in inflation, the rise looks less steep, but there's still a significant rise. And then when you look at certain products, they've gone up hugely. So if you look at online casino games, obviously, the internet has only been around in a kind of mass form for 20 odd years, so there's been a huge increase there. There's been a massive increase in betting on football, for instance. So you really need to drill down into the figures to work out where participation and where spend has increased.

take for instance, things like horse racing, that hasn't seen the same kind of increase that Traditional high street bookmaker betting on the horses has been left in the dust really by mobile phone betting on football games, obviously football being much more popular.

But if you went back 20 years, you didn't really have that kind of high frequency opportunity to bet because, there might only be 10 games on a Saturday for instance, and you're betting on the outcome. These days, because you've got a mobile phone, you're betting during the game during multiple games, during games all over the world, on what's going to happen in the next 10 minutes. So, that's one of the reasons why you've seen that, that sort of big discrepancy in how quickly some parts of the industry have grown relative to others.

Mubin: We saw a really big change in gambling in 2005, with the liberalization of the gambling laws. Can you tell us about the drivers behind this and the main changes that happened.

Rob: Sure, so in 2005, the government is aware that online gambling is becoming increasingly popular. There are a lot of offshore operations in places like Malta and Gibraltar. And they figure we need to get on top of this, put out a proper regulatory landscape and essentially, tax and regulate this industry properly and make Britain the kind of global centre of the gambling industry, and that's what they tried to do. Probably the biggest change in terms of the way people notice gambling in their daily lives was that it took the shackles off advertising.

Previously, the only gambling that could be advertised on television was bingo, and the National Lottery. All of a sudden you have the bookmakers, the online casino products, they could all advertise as well. And of course, this coincides with some other changes, such as the increase in the amount of football that's broadcast on TV. So suddenly, you have many more opportunities for these companies to advertise. And you also have the rise of social media. And one of the most interesting things about this legislation and how it came to be is that it was written in 2005, it was enacted in 2007 - and the iPhone was invented in 2006. So, you have a law that is written without the understanding that within a few years, everybody is going to have, to all intents and purposes - a casino in their back pocket. And at the time, you may remember this, the kind of moral panic in newspapers like the Daily Mail and probably in newspapers like mine, The Guardian was about super casinos. We’re going to have super casinos in Manchester and Blackpool. And there was a lot of opposition to that. And, , the fear was, they'd be havens for crime and addiction and so on. Those ideas seem almost quaint now, when you compare them to the opportunities to gamble, 24/7 that exists for pretty much anybody with a phone.

Mubin: . So, clearly we've got the, gambling in our back pocket as you have outlined. Who's most at risk here?

Rob: I mean, in my experience of speaking to people who are addicted to gambling, it can happen to anybody. It's certainly no respecter of wealth for instance. I think a lot of people assume that it's primarily a problem for people who come from more disadvantaged backgrounds. I think there is something to that. But I've also spoken to people who could have had their gambling debts cleared by relatively wealthy relatives, for instance. Disproportionately its men, and disproportionately its young men. It depends partly on the activity., betting on horse racing in the bookmakers tends to be an older man's game. Whereas betting on your mobile phone on sport, and football, tends to be for younger people. Women are catching up, that's one of the things the industry has realised, the industry got to a point where it was really serving almost all the men between the ages of 18 and 35 in the country, right? So, they suddenly start thinking, well, we've saturated the market, where else can we pick up new custom. And one of the most successful areas for them in the past five or so years, anecdotally, is in getting more women to gamble. And that tends to be on slightly different products, it tends to be on online casino, online bingo, slot machines, stuff like that, and they'll do advertising campaigns that, very much targeted towards women or what they think women want. And what we have seen is an increase in the number of women seeking treatment for gambling addiction. So, correlation does not equal causation, necessarily, but there are certainly more women gambling than there were before and more women seeking treatment for addiction problems.

Mubin: A real targeting of different types of group that you've identified there. And during the course of your work, you've met many gamblers as well as friends and family who've been effected. Can you just tell us a bit about sort of harms caused and impacts gambling can have?

Rob: The one that springs to mind, the obvious one is financial difficulty. And I've spoken to people who have gambled away their mortgage, their kids inheritance, their kids university fund, while sitting on the sofa next to their spouse. And the first thing the spouse knows, is when the debt collectors arrive, or when the letters start arriving, when the mortgage payment doesn't go out. So that's the really obvious one. And I think, unlike other types of addiction, I'm not saying gambling addiction is worse, but it's different. There are other types of addiction that don't always lead to financial ruin, although it can happen. With gambling addiction, that's almost always the way it goes, right? Because if you're really deep into it, you will keep gambling until there is no more money left. And at that point, you'll find other ways to get a hold of money, whether that's borrowing from payday loan companies, borrowing from relatives, stealing from relatives, stealing from your employer. So, at that point, you end up with not just the gambling addicts effected, but on average, according to quite a high level study on this, six or seven other people affected by that person's gambling addiction.

So financial ruin is the obvious one. But mental health is the other big one. What they talk about is the feeling of loss of control, the feeling of shame, that they're unable to get out from under this demon, they that they're unable to stop, they're out of control, that they're somehow a bad person. And that's a narrative that the kind of discussion around gambling has fed over the years there's this phrase ‘responsible gambling’, which sort of puts the onus on someone who is, in effect, an addict who is unwell. Now it is important that people take personal responsibility for their problems, and people who are in gambling addiction recovery, often talk about this but there's this idea, there are problem gamblers. as opposed to the idea that there are problem products or a problem industry, or, problem marketing or problem advertising.

Mubin: And do you think that's being more recognised now and if so, why do you think that’s happened?

It is slowly being more recognised. I think, seven or eight years ago, when I started writing about this, I would talk to people I knew about gambling addiction, and some of the stories I was coming across seemed relatively novel to people. It didn't, for instance, feature very much in say, TV drama storylines, and so on. I think the big change in terms of public awareness happened with the debate over fixed odds betting terminals, which were these machines that you got in betting shops that essentially offered a form of digital roulette - you could walk up to one of these machines, you could put in £100 every 20 seconds And those seem to be particularly alluring to people suffering from addiction. And I reported on them a lot, other people that other newspapers reported on them a lot. And you got these kind of horror stories. And eventually it became a big political issue, it was hitting the headlines pretty regularly. And campaign to limit the amount you can bet on these machines was spearheaded by the then Sports Minister, Tracey Crouch. And she ended up resigning as a point of principal, in a row over how and when the restrictions on these machines were going to take place, this all became very high profile stuff, and I think that really brought gambling into the public consciousness.

Mubin: Now, one of the things you say in your book ‘Jackpot’, you highlight a number of ways in which gambling has become more addictive. And the sort of psychological methods used - such as for greater use of more complex bets, the sort of dark nudges. And you also talk about this illusion of control. Could you just say a bit more about that and has that intensified?

Rob: Yeah, I mean, I want to be a bit careful about sort of saying that gambling has become more addictive. I think what's interesting is that, , the rise of online gambling has allowed game designers and companies to tweak their products in ways that have a demonstrative effect on the psychology of the people who are playing them.

You mentioned the illusion of control, for instance, I mean, this is something that has existed since time immemorial, when it comes to pre internet gambling products. But I'll give you an example here.

Say you've got an online slot machine, there are some games, where you sort of press a button, and then you sort of wait for the outcome. And it'll say you've either won or you've lost. And there are others where you can, if the, let's say, the reels are spinning, after you've initially pressed go, you can choose when to stop them. And there are good studies that show that people think that if they have some kind of control, or some kind of, they can take some kind of action during the game, that they believe they have control over the outcome, when really, it's just a random number generator. So that's the kind of thing we're talking about.

One of the other studies I found really interesting is again, imagine the spinning reels on one of those one armed bandits in Las Vegas, the ones where you need three cherries in a row or three gold bars, or whatever it is. If you've got two cherries, and the third reel, spins, and it briefly touches on the cherry, and then moves past it, so you lose, people tend to think – ‘ah, the opportunity to win has gone’ and they stop, they're more likely to stop playing. However, if they can see if the if the reel had spun, you know, an inch more, it would have landed on cherries, but it didn't quite get there, they have this feeling that the opportunity is still there, and they should keep playing. Right? When again, it's just a random number generator, these things are utterly meaningless. So, it’s these kinds of psychological truths that gambling companies are very aware of, and that they can exploit. And, it's, to some degree, they don't even need to do it deliberately. If I'm a gambling company CEO, and 10 people come to me with a new gambling game they've invented, and I'm deciding which one I want to buy and plug into my system, I can test them, let's say for a month, and take a little look at which one comes out the most successful in revenue terms. So I'm just going to pick the one that makes me the most money. And the likelihood is that that's going to be the one that people are finding most compelling, potentially most addictive. So, it's not as if there's a kind of evil genius behind it all necessarily going – ‘I want to exploit addiction’ - that's just the way the business is set up

Mubin: Yeah, it's all about making money really isn't it and this illusion of control, like you say, it's time immemorial. And you have a really interesting example in the book where, the way people throw dice - and I've done this as well – were if you want a low number, you throw it really gently, and if you want a high number, you really use a load of force to try and get those two sixes.

So, we're now in this really interesting period where the government's reviewing the gambling act. So going back to the changes you talked about in 2005, what do you think we might see in the gambling act?

Rob: I mean, it's anybody's guess. And I would love to know more than more than I do, right? Because that's my job. I think it's quite likely that we'll get some kind of big headline grabbing eye catching policy, like a ban on sponsorship by gambling companies on the front of football shirts. The difficulty then will be well, what do they do about sponsorship elsewhere? You know, advertising hoardings around the side of the pitch in football, for instance - if you're saying it shouldn't be on the front of the shirt, then I can't see the logic and saying it should be allowed around the side of the pitch.

Likewise, what about other sports for instance? What about sports that are actually far more reliant on gambling money than the kind of super rich football clubs take? Rugby league, darts, snooker, which would, some of which would really start to struggle without money from the gambling companies. Can they just do it to football and not to other sports, for instance? But yeah, I think that's one area. I think affordability checks, is really up for grabs. That's about the kind of checks and balances that gambling companies should be asking people to go through, the kind of hoops they should be asking them to jump through, depending on the amount that they want to gamble. And there's a suggestion that people would be asked to provide evidence of their income. And that's a very controversial idea that, there's obviously a balance between civil liberties and protecting people to be struck. A lot of people within the gambling industry, a lot of gamblers themselves would find that very unwelcome. But then there are reformers who say, , this is how we stop people losing more money than they can afford. And there are good examples of gambling companies, accepting large sums from people who couldn't afford it, and therefore, quite strong arguments for having these affordability checks - in some form.

I think companies are going to be asked to share a lot more data with the Gambling Commission, it can be quite difficult for regulators, and for, say, public health officials to determine which products in which activities are particularly harmful if they don't actually have the hard data that only the gambling companies themselves hold. So, I think you'll see some of that.

It would be nice to see the regulator either better funded or accompanied by a gambling ombudsman, that can intervene in disputes between customers and gambling companies.

I mean, one of the ones I find really interesting is this idea of a single customer view. At the moment, one of the industry's arguments is, look, if I see a person who's gambling too heavily, and I shut them down, and close their account, they're just going to go to another company and gamble with them. And historically, gambling companies have been able to use this to avoid giving payouts to people, when they haven't intervened properly to stop them gambling, it's very difficult to sue them because they just say, ‘Look, this person would have lost their life savings anyway, if it wasn't with me, it would be with somebody else’. Well, a single customer view approach would say, all of these companies have access to a central database, which shows the same red flags in this person's gambling, whether that's, , losing 1000s of pounds at three in the morning, or, , betting more than they can afford based on one of those affordability checks. If you have that, then suddenly, it becomes very difficult to make those same legal arguments. So, I think that's an area that's particularly interesting.

Mubin: And what do you think the response from the industry might be in relation to these changes? Do you think they'll be more accepting of them or does it all depend on what's put the table?

Rob: I mean, what you've seen over the last year or so, is the gambling industry, having been quite sluggish in improving player protection - that doesn't apply to all firms, some firms are better than others. Once they've seen that the gambling review is coming down the line, they're suddenly falling over themselves to come up with new voluntary measures to show how responsible they are, because they've seen the writing on the wall. And what I often liken this to, is, when I see my cat up on the kitchen counter, and I could be across the other side of the room going stop doing that. But until I'm striding towards the cat with menace in my eyes, the cat doesn't jump off the counter. In fact, it's only when I'm about a millimetre away that it does so.

And the gambling industry is a bit like that.  All of a sudden, they see the potential for draconian regulations being imposed upon them, and now they're doing voluntary measures to make sure people are better protected. Now, it's good that some of those measures are happening, but it does give you an insight into how the industry thinks and it does make me worry that if the government decides, well, , this is a free market capitalist society and the industry has responded, , to what it sees as a threat, market forces are at play here, and they're doing the right thing. If that happens, and then they don't regulate strictly enough, then I think you're going to see some backsliding from the industry as soon as the issue has died down and attention is elsewhere.

I mean the other thing, of course, that they're doing is lobbying very hard against certain regulations. And they're doing that by taking MPs to days out at Ascot and Euro 2020. And, by making their case very strongly with members of the House of Commons, and it is having an effect. I mean, you're seeing MPs out there, parroting the attack lines of the gambling industry, sometimes word for word. So, the industry is doing pretty well at getting its voice heard in Parliament. And there's this idea that there's this powerful anti-gambling lobby. And it's ridiculous,  really, when you compare it to the kind of financial fire power and lobbying fire power it has at its disposal.

Mubin: Yeah and I think that's mirrored as well in terms of advertising. We did a piece of research recently which looked at how much funding there was to talk about harms and trying to get people to the right levels of support and it was a complete drop in the ocean compared to what the industry was spending.

Mubin: What do you think might be one of a really good policy ideas that we should really take up which might not be there within the sort of gambling act remit at the moment?

Rob: I think where the UK has a really good opportunity, is in that this is more or less the most mature gambling market in the world. There is a great deal of expertise and institutional memory about how things work. So, in terms of the technical aspects, some of the stuff I mentioned earlier is being a bit unsexy about how gambling operations work - how the player protection tools, that gambling companies use, work. I think that's where there's a really good opportunity to lead the way. And I think, I think the current gambling Minister does understand a lot of that. The question is where we get to once, , the rest of government in particularly the Treasury, which is worried about its tax take, has finished with the proposals that the gambling minister comes up with. But it is a landmark moment, and there will be other countries around the world, looking to the UK to see what we do.

Mubin: Thank you very Rob, I've really enjoyed listening to the insights there

Rob: Thank you.

Mubin: Matt, thanks very much for joining us. You've been really quite public about your past gambling addictions, which has been great at breaking down the stigma on the issue. Can you just tell us a bit more about the impact gambling has had on your life?

Matt: Of course, yeah. So, I was addicted to fixed odds betting terminals when I was when I was 16, until I was 20. And obviously got into a lot of debt and had a huge impact on my life in various different aspects. So, education, my relationships, my development, lots of things that I  missed out on as a result of, being addicted to gambling.

But then I think following that, and what probably isn't spoken about enough is, is the residual impact of an addiction once you've given up and a gambling addiction doesn't stop with abstinence or cessation, it has a lasting effect on your mental health. And it definitely did from my perspective. I had lots of mental health problems following quitting gambling, and I had, obviously a huge amount of debt that I had to deal with and pay back, and fixing my credit rating and all of that sort of stuff. one of the things that I definitely experienced were depression, anxiety, lots of highs and lows that were  a result of having been through that day in day out for four years, and the intensity of gambling addiction and the dopamine and adrenaline that's running through your brain all the time.

Mubin: And what was the support like? For you? Did you feel there were places you could go to people you could talk to? Or was it just you felt like this was something you were trying to deal with on your own?

Matt: I felt like it was something I was trying to deal with on my own. I did get therapy, Cognitive Behavioural Therapy, which was something that my family arranged, which I was very grateful for, obviously, but I think when I when I was trying to give up, I don't think the NHS clinic in London, it even opened at that point. And I felt like what was being offered by other support services wasn't comprehensive enough, it didn't give me much confidence. I did try Gamblers Anonymous meetings. And, again, I found, sitting there listening to people that were three or four times my age, explaining how they've destroyed their lives and how much money they'd lost wasn't something that I could relate to, at that point in my life. Obviously I was on that trajectory, but, it wasn't the same as getting proper support. And I think that the quality of, of treatment has obviously improved considerably since when I, when I was addicted.

Mubin: Through your work with Gam Ban you will have worked with thousands of people struggling with gambling addiction. What sort of harms do they talk about?

Matt: We always, I think, quite understandably, we focus on the amount people lose and the amount people lose is obviously a relevant factor and the financial harm that's experienced as a result of that, it's a significant factor in the harms that people experience. But I think that there are other factors as well.

It's the way that it impacts on just the mental health of people that gamble, on the people around them, who were affected by someone else's gambling, not just because they're financially impacted, but because of, , who this person that's become addicted to gambling has become and the fact that they, they suddenly, they don't want to do anything except gamble. All the time. So that can be very difficult for people. It's how it, affects, for example, employers, if someone who is working for a company steals money in order to fund an addiction. It's how it affects the community, if other people who have been affected by someone's crime that's been committed to fund gambling, the knock on effect is that they're in debt, and they can't get out of a debt spiral for several months. That's a form of gambling related harm, even if they're not addicted to gambling, because they've lost more than they can afford in one month. Or if it's people affected, affected others. Or I think one of the things that the prevalence surveys don't capture is the people that have given up gambling but who have already been harmed by gambling. So a prevalence study wouldn't capture me, for example, or even someone who gave up gambling in 2021, because it would ask about the last 12 months, and whether you've gambled in the last 12 months. Now,  if you're addicted to gambling, and you've quit and you've managed to recover from that, you're not going to say that you've gambled in the last 12 months, you're not going to be captured by a prevalence study. So it is a snapshot. So, I think that the harms extend way beyond what is captured by these studies. And lots of people get affected by gambling who might not may not consider themselves to be addicted

Mubin: That's a really interesting perspective in terms of who's captured in that data.

Do you think we take gambling harms seriously enough in comparison to other addictions, like tobacco or alcohol?

Matt: I think the closest that we've got to a public health message in terms of gambling related harm, is TalkBanStop. Now you might say, oh, I'm biased because I'm involved with Gamban, and that's part of the TalkBanStop campaign.

But I feel like that is at least a call to action about what people can do. If they feel as though they're getting addicted to gambling, it's a very specific call to action that encourages people to try to stop and these are the steps you can take. I feel like a lot of the messaging around gambling harm  - ‘When the fun stops, stop’  or ‘Bet Regret’ or ‘Take Time To Think’  - it's very focused on the individual. And it's very vague in what it's instructing people to do. So I think that proper public health messaging is hopefully one of the things that will come out of the gambling review. And that has to really look like the messaging around tobacco and alcohol, which is warning about the harms that it can do, and warning about the the practices and the products and the impact that they have on people in the long term.

And I feel like the way that perhaps this messaging is derived and where the funding has come from, it's usually like, for example, ‘When the fun stops, stop’, that was a Senate group initiative that was funded by the gambling industry. I think if there's a way to administer all of this independently where, you know, can be carried out by or overseen by, for example, Public Health England or public health professionals who were involved in, in tobacco campaigns or, or alcohol related campaigns, then I think we'll get better quality messaging.

Mubin: What about the industry, you've had a forensic eye on what the industry's been doing. And you've been working on gambling blocks, are these proving effective?

Well, the product that I co-founded is GamBan, and that's blocking software, that blocks access to gambling sites and apps. And it's designed to be as difficult to remove as possible. Now, some operating systems, this is more effective than on others. So for example, if you downloaded it on this Windows laptop that we're sitting in front of, I think, the vast majority of people find it very difficult to remove it. And it will block all the gambling sites and the apps including the black market and unregulated sites.

. The point is to put as many barriers as possible in place. And the most effective way to do that is through a layered approach. So, download GamBan, sign up to Gamstop, the self-exclusion register, call the National Gambling Helpline, Gamcare run, get treatment, they'll direct you to your bank, if they offer a gambling transaction block, get that in place, get all of these things in place. And then when you have the urge to gamble, as I know, it can be extremely, extremely difficult to resist, then at least you've got a bit of breathing space, you have to vault all of these different barriers in order to gamble. And in that time, you have that period of self-reflection.

And the evaluation of the first year of the TalkBanStop partnership between Gamcare, Gamstop and Gamban found it to be extremely effective. And we've thankfully got a second year. And hopefully this is something that can continue for a long time.

Mubin: What's the take up been like?

Matt: So, in the first year, we saw 9000 free licenses, distributed through the National Gambling Helpline. And Gamban has at last count about 113,000 registered users, it has fewer active users, people tend to drop in and out of use of Gamban. It's quite interesting. It's something that we're trying to figure out exactly what's happening with section of the user base, but many people will sign up, they'll get a five-year license, and, it will stay on their devices and they can put it on up to 15 devices. So the take up has been very strong. What we're hoping to do in the second phase of TalkBanStop is to make it a bit more seamless. So, people don't have to go through the helpline to get a code necessarily, they might be able to or a link to a free Gamban license, they might just be able to go through Gamstop. So if we can make everything more joined up, then I think that that will drive uptake.

One of the things I'd like to talk to you about is public attitudes to gambling. Have you seen a sea change in that since you started working in this Definitely seen a sea change. And I'm not saying that it's down to the campaigning, because obviously it does play a part. But I think it's, it's people's day to day lived experiences, that’s informing all of that. And the harms are so widespread, that everyone either has experienced gambling related harm to some extent, or know someone who has. Now, of course, lots of people place a bet, the occasional bet. And that's absolutely fineBut the reality is the gambling industry’s profits aren't derived from the people that have the occasional bet they come in from the 5%, who really are either addicted or at risk. there seems to be this kind of vague recognition in among the gambling industry, and its representatives that the way that they operate, and how they've been allowed to operate, isn't sustainable public attitudes have changed significantly, particularly in the last few years, particularly, I think, since fixed odds betting terminals, because I think people then thought, well hold on a minute, this is a product that's linked to addiction.

Mubin: So the white paper this review of a gambling act by government. What are you expecting to see in that?

Matt: Something that the industry are very keen to promote to people even if they sign up to bet on racing or sports, they'll cross sell slots to them, free spins and bonuses and all that sort of stuff. So, I think it's very important that product is restricted and made safer.

And things like affordability checks. I think it's now a question of not whether affordability checks happen, but at what threshold they take place, what losses, how much does someone have to lose before an affordability check kicks in. Now, this has been obviously a subject of great controversy among the gambling industry who want to kind of portray this as being very intrusive and nanny status.

These are the checks, these are checks that they're supposed to do anyway. And all we're saying is, if the operators have to do them, then there ought to be a standardised process that is enforced across the sector. So you don't have one operator intervening when someone loses £200 and one operator intervening with someone £2000,

Mubin: And if there's one thing you could really have that you'd like to see, say the industry do or government do, what would it be?

Matt: If I could just choose one of those things?

Mubin: Or it could be something else which may not be in the gambling act?

Matt: So at the moment in the 2005 gambling act, there's three licensing objectives. One is, the gambling should be fair and open. The second is that gambling should not be associated with crime. And the third is that gambling should not harm the young or vulnerable. And while the Gambling Commission says that everyone is theoretically vulnerable, I think that it's conceded that now it's not just like a subsection of society, they're saying that the whole population should be protected from harm. I think it would be strengthened if we had a fourth licensing objective that was to prevent harm to the population. And this would strengthen the mandate of the regulator.

Although I think the regulator has been moving broadly in the right direction. It's unrecognisable to when we, when we first started campaigning. It really did see itself 10 or so years ago as a sort of facilitator of gambling to grow the industry, that was its remit or what it understood its remit to be. And now it is very much focused on gambling related harm and prevention of harm.

But I think that, I think it could be - that mandate could still be strengthened. And the best way of doing that would be to have a public health approach to all or to its entire regulatory remit. I think that would really future proof the gambling act. I'd also like to see as well as the things I've mentioned, other products that are perhaps on the FCA regulatory perimeter at the moment, like crypto exchanges and spread betting, leverage trading platforms, all of these which have lots of gambling like characteristics, and which gambling related harm can arise from,  so knowing that we Gamban has blocked these sites and apps as well, because we think that, if you're a gambling addict, and you've blocked all the gambling sites and you've self excluded, and then you end up on the eToro, or trading 212, or what some of these leveraged trading platforms, you can end up losing even more money.

It’s very, very similar to gambling, it’s betting on price movements, it's not even owning an underlying asset. So very, very different to investing. So we block those two, but I’d like to see the Gambling Commission sort of determine, be able to determine that if gambling related harm could arise from these types of platforms, these innovative types of trading platforms or speculative platforms are speculation that get some degree of gambling regulation is applies to them, particularly around social responsibility and prevention of harm, because I, I know that people are experiencing huge amounts of harm from the recent crypto crash.

If that's happened to you, and you've bought a lot of Bitcoin and it's halved in value, and you've lost £1000s of pounds, you may not know that that was, that is a form of gambling related harm. And particularly if you start to chase your losses,. And if you don't know that you're experiencing gambling related harm, because there's nothing on the website that you're engaging with, or nothing to inform you that, what you're experiencing here is a gambling addiction, then you're not going to get the help that you need. You're just gonna think - I'm not very good at this. I'm sort of a bad crypto trader, how do I get better? So I'd like to see that the Gambling Commission take a more flexible role in determining what they deemed to be gambling like products

Yeah, that's very interesting because crypto currencies would be saying well, it's an investment. And there's it's not a win or lose situation, there is a product that you're investing in. So this would potentially widen it out to all sorts of other elements to where you can potentially win or lose all of your money depending on performance. So it'll be interesting to see how that one pans out.

But Matt, thanks so much for talking about your own personal journey and and just your insights into the sort of changes we may see with this white paper coming out and we look forward to seeing what actually happens here.

Matt: My pleasure, really good to chat. Thank you