Affordability
Introduction
Look out for the interactive elements throughout the guide, clicking these will provide you with additional information.
Inter shop communication is key to successfully navigating the affordability process – all shop team members will need to be aware of a customer who has reached an affordability threshold in order to carry out the relevant action on their next visit. This document will provide a comprehensive guide to the affordability process.
Following the links embedded throughout this guide, demonstrates as you would navigate within the process.
Contents
Click the 'Start Training' button below to work your way through the training module. Alternatively, you can click one of the 'Quick Reference Links' below to navigate to a specific part of the training.
Start Training
Quick Reference Links
FAQs
Customer Interactions
Money Laundering
Support and Staying Safe
Know Your Customer
Monitored Customers
£3,000 loss in 30 days
£1,000 loss in 7 days
£12,000 loss in 365 days
£5,000 stakes in a day
£125,000 stakes in 365 days
£15,000 loss in 365 days
£25,000 stakes in 90 days
Getting to Know Your Customers
Building a picture of our customers' background allows us to communicate much more effectively. Getting to know our customers is the basis for everything we do!
Understand betting pattern
Recognise changes in behaviour
Why should you get to know your customers?
Customer loyalty
Personal service
Recognise changes in betting habits
Offering refreshments
Getting to Know Your Customers
Building a picture of our customers' background allows us to communicate much more effectively. Getting to know our customers is the basis for everything we do!
Name
Personal circumstances
What should you get to know?
Employment
Family situation
Common interests
Betting habits
Monitored Customers
For a customer to be managed through the automated affordability process they must be a monitored customer. Once a monitored customer has been created all bets regardless of stake should be monitored moving forward. There are no other reasons to create a new monitor customer profile. If a customer is already monitored within your shop, then you must continue to monitor all of their business regardless of stake value. By following this process we are identifying the customers that could potentially be at risk of gambling harm. This allows us to analyse their gambling, identify betting behaviours and allows us to interact at key stages during their gambling.
OTC
SSBT
FOBT
Monitored Customers
Monitored Customers
Monitored Customers
Monitored Customers
Customer Interactions
A customer interaction is our opportunity to converse with a customer regarding their current gambling activity.
Our 3 stage, structured approach to customer interactions is:
Identify
Interact
Evaluate
The two main reasons we would interact with a customer are:1. Upon identifying an indicator of potential gambling harm 2. Upon receiving an affordability email
Customer Interactions
Safer gambling leaflets are tools to assist you with your interaction. You could make the customer aware of additional tools that are available. Hover over each leaflet to find out more.
Customer Interactions
Once you have completed the interaction with the customer, it must be logged via the SRR page on the Compliance Hub. It is best to do this whilst the conversation is fresh in your mind. You should detail as much of the conversation as you can, paying particular attention to the information you have provided to the customer and the safer gambling tools they were made aware of, as well as the customer’s response to this. Always have in the back of your mind that someone who has never met yourself or the customer will be reading the interaction, and trying to assess the customer based on what you have written.
Customer Interactions
When receiving any affordability alerts it would be prudent to see if any interactions have previously been logged for the customer in question. This may better prepare you for an interaction you know you need to perform with a customer. Finally, we need to evaluate the interaction we have just had. The evaluation of an interaction can be carried out directly after the interaction and/or over the coming days and weeks after the interaction has taken place. You are evaluating the customer’s behaviour and/or betting patterns following your interaction. By taking the time to detail the conversations you have with your customers, you then allow the Compliance Analysts to build a picture of the customer's journey with Betfred to best enable them to support you in identifying customers who may require further intervention.
Customer Interactions
If you complete an interaction with a customer, it is good practice to make your team members aware of this so that they can continue to observe the customer in your absence and conduct further interaction as required.
A customer who usually stakes £10 a race increases their stakes to £50 a race and is becoming noticeably agitated.
You would speak with the customer and point out that you have noticed an increase in their spend and ask them if everything is ok.
You could also make them aware of safer gambling tools that are available to them.
If on the back of this interaction the customer acknowledges their increased spend and reverts back to their usual staking pattern, this would be your evaluation.
£1,000 loss in last 7 days
Each day, you must check the Compliance HUB for any £1,000 loss affordability alerts that are new or still pending. The Early interaction should take place with the customer prior to any bets. 1. Inform the customer of their recent losses. 2. Ask the customer if they are happy with their current level of spend. 3. Log a detailed account of the conversation via the affordability alert on the Compliance HUB.Only once you have completed the interaction, it is important that you then follow the link, this takes you to the SRR for the automated affordability alert. Following these steps and logging the interaction before accepting any further bets will prevent exceptions being received the following day.
£1,000 loss in last 7 days
£3,000 loss in last 30 days
This is known as an enhanced interaction. If one of your monitored customers is identified as losing at least £3,000 in a rolling 30 day period, you will receive an automated email the following day prompting you to complete an interaction prior to the customer placing another bet. This interaction is integral in the customer’s journey. This is where you must make the customer aware of the control measures available in shop and where to get additional support should they require it. When completing this interaction, you should record a comprehensive account of the conversation you have had with the customer as an SRR via the affordability alert, clearly detailing the information you have provided and received. The level of detail recorded is key to documenting the customer’s journey. This is known as the narrative and the more detail contained within the interaction the better equipped the Compliance Analysts are to assess the customer's exposure to potential gambling harms.
£3,000 loss in last 30 days
The customer is eligible to receive an automated interaction alert once every 30 days, but can happen at any point after they generate the £1,000 alert. You will receive reminder emails every day for 30 days until you have followed the link within the email and logged an SRR. Even if the customer returns after 30 days you still must follow the steps in the email. If you do not follow the link within the email and log the SRR before the next bet is accepted from the customer an exception will be generated.
£3,000 loss in last 30 days
£12,000 loss in last 365 days
If a customer is identified as losing £12,000 in a rolling 365-day period, you will receive an automated email instructing you to request photographic ID that provides proof of address and date of birth on the customer's next visit. The ID must be obtained, logged and scanned via the ID/SOI printer app, prior to any further gambling taking place. When asking the customer to provide ID you should complete an interaction and make the customer aware of the safer gambling measures available to them. It is important to note that the customer is averaging losses of at least £1,000 a month at this stage. When completing this interaction, you should record a comprehensive account of the conversation you have had with the customer, clearly detailing the information you have provided and received.
£12,000 loss in last 365 days
The level of detail recorded is key to documenting the customer’s journey. This is known as the narrative and the more detail contained within the interaction the better equipped the Compliance Analysts are to assess the customers exposure to potential gambling harms. On the day the identification is requested, customer can gamble in one single transaction, up to the value of £1,000. Following that, no further bets to be taken until ID is supplied. You will receive reminder emails every day for 60 days until you have followed the link within the email to log the customer's ID. Even if the customer returns after 60 days you still must follow the steps in the email. If you do not follow the link within the email and log the ID before another bet is taken an exception will be generated.
£15,000 loss in last 365 days
If one of your monitored customers is identified as losing £15,000 or more in a rolling 365 day period and did not complete a satisfactory self-certification at the £6,000 stage, your shop will receive an automated email. Attached to the email will be a Source of Income letter. You will need to print the letter and include a self-certification leaflet, placing both in a sealed envelope ready for the customer on their next visit to the shop. Each letter has a unique reference number that relates directly to the customer. It is imperative that only the letter sent is issued to the customer for whom it is intended. Where staffing levels allow, the customer should be handed the letter in a discreet way, you should explain to the customer that it is a request for documentation to allow us to ensure their gambling is in keeping with their level of affordability. (Source of Income / Funds)
£15,000 loss in last 365 days
The letter will explain to the customer they have two options for supplying information for review: When approaching a customer, where possible you should speak to the customer in a discreet way, explaining the two options available to them.
Providing financial documentation
Self-certification form (details can be found on £6,000 loss stage)
£15,000 loss in last 365 days
On the day the documentation is requested, customer can gamble in one single transaction, up to the value of £1,000. Following that, no further bets to be taken until you have received notification that their source of income has been verified by the Compliance Team. You will receive reminder emails every day for 60 days until you have followed the link within the email confirm the customer has been handed their letter. Even if the customer returns after 60 days, you still must follow the steps in the email. If you do not follow the link within the email and confirm the letter has been given to the customer before another bet is taken, an exception will be generated.
£15,000 loss in last 365 days
£5,000 stakes in a day
There are two ways in which a customer can reach the £5k stakes in a day ID request. Once a customer has staked £5,000 in a day, you must then request and log full details of their ID, as well as scan a copy of their ID via the ID/SOI printer app prior to accepting any further bets from the customer. When asking the customer to provide ID you should then log the full details of the interaction on the SRR page, making the customer aware of safer gambling measures available to them. Once ID has been provided, full details should be logged under the 'Customer ID' section of the Compliance Hub.
Single bet of £5,000 or more
Cumulative bets totalling £5,000 or more
£5,000 stakes in a day
To satisfy an ID request the customer must be able to provide photographic ID along with the following information: • Full Name • Address • Date Of Birth To log a customer’s ID, you should go onto the Compliance Hub > Customer ID. When logging the customer’s ID, you are asked to select the customer’s “Monitored Customer” name from the drop down menu. By doing this, it will link the customer’s ID to their monitored customer profile in the till. This means if the customer goes on to reach the £25,000 stakes or £12,000 loss ID request threshold, you will not receive an automated email prompting you to request ID again. Making the process smoother for both your shop and customer.
£5,000 stakes in a day
£25,000 stakes in 90 days
Once a customer has staked £25,000 in a rolling 90 days, you will recieive an automated email instructing you to request photographic ID, prior to the customer placing any further bets. The customer must provide you with photoprahic ID, you should log full details of their ID, as well as scan a copy of their ID via the ID/SOI printer app prior to accepting any further bets from the customer. (The customer can have upto £1000 in one transaction, on the day of the request should they not have ID with them) When asking the customer to provide ID you should then log the full details of the interaction on the SRR page, making the customer aware of safer gambling measures available to them. Once ID has been provided, full details should be logged under the 'Customer ID' section of the Compliance Hub and a copy scanned via the ID/SOI app on your shop printer.
£25,000 stakes in 90 days
To satisfy an ID request the customer must be able to provide photographic ID along with the following information: • Full Name • Address • Date Of Birth To log a customer’s ID, you can either - By doing this, it will link the customer’s ID to their monitored customer profile in the till. This means if the customer goes on to reach a £5,000 stakes or £12,000 loss ID request threshold, you will not receive an automated email prompting you to request ID again. Making the process smoother for both your shop and customer.
Follow the link in the affordability email send to your shops email inbox, this will direct you to the ID log in the Compliance Hub.
Via the Compliance Hub, under Customer ID > Affordability > Select the customer to provide ID. This will take you to the ID log for that customer.
£125,000 stakes in 365 days
When a customer is identified as having staked a minimum of £125,000 in a rolling 365 day period, the customer will be required to provide us with proof of their source of income / wealth / funds. Your shop will receive an automated email. Attached to the email will be a Source of Income (SOI) letter. You will need to print the SOI letter and place it in a sealed envelope and issue it to the customer on their next visit to the shop. Each letter has a unique reference number that relates directly to the customer, it is imperative that only the letter sent is issued to the customer for whom it is intended. Where staffing levels allow, the customer should be handed the letter in a discreet manner. You should explain to the customer that it is a request for documentation to allow us to ensure their source of funds is in keeping with their current level of gambling. Be confident in letting the customer know this is now standard practice amongst all high street bookmakers.
£125,000 stakes in 365 days
The letter explains to the customer they have two options for supplying documents: Sending documents via the ID/SOI printer app on behalf of the customer should always be a last resort. Customers should be encouraged to provide their documents themselves via their personal email, to allow for fluid communication between the customer and compliance.
By email to info.documents@betfred.com
To the address on the letter they receive
Money Laundering
"Money laundering is the illegal process of making money, which has been generated by criminal activity, look to have come from a legitimate source"
Money Laundering
Money Laundering
Placement is the first stage of money laundering where criminals use various methods like gambling, blending of funds, currency smuggling, etc. to introduce proceeds of crime into financial system.
Placement
Layering is essentially the use of placement and extraction over and over again, using varying amounts each time, to make tracing transactions as hard as possible.
Layering
Integration in money laundering is when criminals introduce illegally obtained funds into the economy through seemingly legitimate transactions - making the dirty money appear clean. But it's important to remember this: The money is still not clean.
Integration
Money Laundering
Loading cash into the SSBTs and printing a value ticket. Leaving the store with the value ticket.
How can customers use our premises to launder money?
Loading cash into the FOBTs and withdrawing a ticket to be collected at the counter.
Placing large stakes on short odds.
Placing bets on known non runners.
Asking for the payout to be made in a different way in which the bet was accepted, e.g. paid in cash, winnings back to card.
Money Laundering
Unrecognised Crime
Case Study: Regular customer, who owns the very popular fish and chip shop in the village, is losing approx. £300 on the FOBT’s on 3 / 4 nights a week. This money could be coming straight from the till in the restaurant, therefore it may not have been declared as income, which would mean that no tax will have been paid on it. This equates to £46k - £62k a year of tax evasion. Think about the customers in your shop who may have similarities to the case study above.
Money Laundering
Internal Suspicious Activity Reports
Crime could be anything from dealing drugs, selling counterfeit goods, theft, fraud or anything else we have discussed over the last few pages. If you suspect any of your customers are commiting a crime on the premises, it is your responsibilty to report this. You can do this via the ISAR report on the Compliance Hub.
How do you record any suspicious activity?
Support and Staying Safe
Ask the Compliance Team a Question
The most efficient way to contact the compliance team is via 'Ask the Compliance Team a Question' on the Compliance Hub. Once your message has been received, a Compliance Analyst will call you at your shop at the earliest opportunity. When sending your message it is important to include the details for what you wish you discuss so that the analyst can have any necessary information available for the call. If you believe you have an emergency/ urgent compliance concern, you should always seek guidance from your Area Team in the first instance. If your question relates to the Affordability process, you should first refer to the training documents on the Learning Hub to see if your question is answered. If not, you should select 'Affordability Trigger Alert' from the drop down when completing your question.
Link
Support and Staying Safe
Where you have identified an indicator of potential harm caused by problem gambling, it is important that we interact with these customers in a supportive way. This is where your knowledge about the customer will allow you to determine how to approach the interaction. If you do not know the customer you should apply knowledge about the average customer to determine your next step. - Listen to the customer and try not to talk over or argue with them - Build rapport through empathy - Put yourself in the customer's shoes - Lower your voice, if the customer gets louder, start speaking more slowly and in a lower tone Your calm demeanour will reflect on them and will help them to settle down. Never get angry or upset, if the customer is swearing or being verbally abusive never take it personally. Remember to utilise the Safer Gambling tools available in your shop to provide information to the customer and support your interaction. Your safety is paramount and you should only ever interact if you feel safe to do so. If you do not feel it is safe, in this situation you would still complete an SRR and select 'A concern about a customers gambling but no interaction made'.
Compliance Emergencies
If it is felt that a customer is an immediate risk to themselves, for example, using words or phrases which indicate that they wish to cause harm to themselves. Offer the customer the 'You Are Not Alone' leaflet, stop serving the customer straight away and contact a member of your Area Team immediately for advice and support. You should also record an SRR detailing the full reasons for your concern. In addition to the above, if you become aware of a current or past customer who has committed suicide, you must record this as an SRR, including as much detail as possible, and make your Area Team aware in the first instance. It is a licence requirement that the business notifies the Gambling Commission if we know or have reasonable cause to suspect that a person who has gambled with us has died by suicide (LCCP 15.2.2). In the event that you believe you have any kind of compliance emergency, your Area Team should be your first port of call to provide guidance and support. Remember, conducting regular and meaningful interactions with customers who are displaying indicators of gambling related harms can help them to seek any support they may need.
Disposable Income
Its important to think about your customers circumstances when deciding on the apropriate level of interaction. The next 4 activities will help to show disposable income for individuals with differant salaries and personal circumstances you should always ask yourself, based on what i know about a customer, is thier gambling affordable and sustainable.
Disposable Income
Name: Wendy Aisle Net Salary: £20,984 Job Title: Retail Location: Glasgow Rent/Mortgage: £1,000 Council Tax: £125 Gas & Electric: £172 Water: £80 TV Licence: £14 Internet: £30 Mobile Phone: £50 Subscription: £25 Debts: £150
Disposable Income
Name: Penny Payne Net Salary: £28,645 Job Title: Nurse Location: Stoke Rent/Mortgage: £750 Council Tax: £105 Gas & Electric: £130 Water: £50 TV Licence: £14 Internet: £33 Mobile Phone: £65 Subscription: £70 Debts: £80 Car: £125
Disposable Income
Name: Bob T Builder Net Salary: £35,870 Job Title: Self-Employed Location: Cardiff Rent/Mortgage: £900 Council Tax: £110 Gas & Electric: £160 Water: £70 TV Licence: £14 Internet: £34 Mobile Phone: £40 Subscription: £65 Debts: £400 Car: £600
Disposable Income
Name: Elon Gates Net Salary: £41,765 Job Title: Senior Manager Location: London Rent/Mortgage: £1,600 Council Tax: £95 Gas & Electric: £180 Water: £85 TV Licence: £14 Internet: £27 Mobile Phone: £55 Subscription: £97 Debts: £350 Transport: £400
Training Sign Off
Thank you for taking the time to complete the Affordability Training. If you require further guidance, please refer back to the training or your affordability flip chart for guidance. Click on the sign off button in the Learning Hub to confirm your undrstanding of this training.
The most common reason for this is because all affordability SRRs need to be logged via the link provided within the email. Please follow the link or via the affordability section of the Compliance Hub, completing all mandatory fields before saving the SRR this will stop any future reminders.
Yes, you will stop receiving email reminders for customers after the following timeframes:• £1,000 loss in 7 days: 30 days • £3,000 loss in 30 days: 30 days • £5,000 stake in 1 day: 60 days • £6,000 loss in 365 days: 60 days • £12,000 loss in 365 days: 60 days • £15,000 loss in 365 days: 60 days • £25,000 stakes in 90 days: 60 days Although you are no longer receiving a reminder, the interaction and any other necessary actions will still be required to take place on the customer’s next visit to the shop.
If a customer’s documents are accepted and they are cleared to gamble, your shop will receive an email to inform you of this, and your Area Team will also be made aware.
No, once a customer has been issued with a Source of Income letter they should not be allowed to gamble in any capacity until they have received confirmation that their documents have been accepted.
Log this as an SRR. Using the email link provided, tick the box stating that you have issued the SOI letter to the customer.
All customers receive a response to the documents they provide within 72 hours. If a customer believes they have not yet had a response. The customer can request an update by contacting info.documents@betfred.com.
Yes, each occasion should be treated as a separate action. You will need to conduct an interaction and log the SRR via the email link each time an email is generated. It is essential that regular and meaningful interactions are logged for our customers reaching the affordability alerts, to ascertain if the customer is comfortable with their level of gambling and that we have up to date logs to support this information.
The reminder will only be removed once you follow SRR link within the email and tick the box to confirm that the SOI letter has been provided to the customer. Once this action has been completed, this will prevent further reminders from being sent to your shop.
The details of where the customer needs to send their information is contained on the letter. info.documents@betfred.com Spectrum Arena,56/58 Benson Road, Birchwood, Warrington, Cheshire, WA3 7PQ. Always encourage your customer to send their documents via email as this will allow us to respond within 72 hours. Only if the customer cannot send their own documents, these can be scanned via the ID/SOI printer app.
Yes – there are many reasons to interact with a customer, and many tools available to prompt you to conduct an interaction such as: FOBT Alerts, mandatory and voluntary SSBT Alerts Customers behaviour Customers betting patterns 3rd party concerns for a customer
No, once a customer has been issued with an ID request letter they should not be allowed to gamble in any capacity until they have received confirmation that their documents have been accepted.
If the customer opts to complete the self certification form, you should inform them that once it has been completed it will be reviewed by the compliance team and follow the steps set out in £6,000 loss process. Once reviewed the customer, shop team and area team will be emailed by the compliance department informing them if it has been accepted or not. If it is accepted then the customer can continue to gamble. If it is not accepted the customer will be requested to send in source of income documentation as outlined in option 2 (physical documents). Again, the customer, shop team and area team will receive the outcome from the compliance department once a decision has been made.
If you believe you have identified a customer who has previously been asked for Source of Income in another shop, then you should contact your Area Team or the Compliance department as a matter of urgency to see if bets can be accepted from the customer.
No, the action does not need to be carried out with this customer. The bet(s) should be reassigned to the correct customer and your Area Team should be informed of this error immediately.
The ID should be logged on the Compliance Hub > Customer ID > Create New ID. If the customer is monitored, ensure you select their monitored customer name from the drop-down menu on the ID page as this will link the ID directly to the customer.
You can still have an interaction with the correct customer. Following the interaction an SRR should be logged on the Compliance Hub, under Customer Interaction > Create New SRR.
A customer interaction is in no way intended to be intrusive, they are designed to ensure that the customer is comfortable with their level of gambling and to provide evidence that the customer has been made aware of the following: o Level of spend o Losses incurred o Safer gambling tools available to them
If the customer opts to send their physical documentation to the Compliance department, the customer will be reviewed and the customer, shop team and area team will be emailed by the compliance department informing them if it has been accepted or not. If it is accepted then the customer can continue to gamble.
You will need to inform your Area Manager/Team, as the alert email may need to be communicated to the other shop team.
Yes, at this stage it will be even more important to conduct an interaction with a customer, both when an alert is and is not received. It is important to remember the customer has either staked a minimum of £125,000 or lost a minimum of £15,000 over a rolling 365-day period to be issued with a Source of Income request. It is important that regular interactions are still taking place to ensure that the customer is still comfortable with their level of gambling.
A passport alone is not enough to satisfy an ID request, the customer will need to provide a utility bill to complete the process.
Affordability 2025
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Transcript
Affordability
Introduction
Look out for the interactive elements throughout the guide, clicking these will provide you with additional information.
Inter shop communication is key to successfully navigating the affordability process – all shop team members will need to be aware of a customer who has reached an affordability threshold in order to carry out the relevant action on their next visit. This document will provide a comprehensive guide to the affordability process.
Following the links embedded throughout this guide, demonstrates as you would navigate within the process.
Contents
Click the 'Start Training' button below to work your way through the training module. Alternatively, you can click one of the 'Quick Reference Links' below to navigate to a specific part of the training.
Start Training
Quick Reference Links
FAQs
Customer Interactions
Money Laundering
Support and Staying Safe
Know Your Customer
Monitored Customers
£3,000 loss in 30 days
£1,000 loss in 7 days
£12,000 loss in 365 days
£5,000 stakes in a day
£125,000 stakes in 365 days
£15,000 loss in 365 days
£25,000 stakes in 90 days
Getting to Know Your Customers
Building a picture of our customers' background allows us to communicate much more effectively. Getting to know our customers is the basis for everything we do!
Understand betting pattern
Recognise changes in behaviour
Why should you get to know your customers?
Customer loyalty
Personal service
Recognise changes in betting habits
Offering refreshments
Getting to Know Your Customers
Building a picture of our customers' background allows us to communicate much more effectively. Getting to know our customers is the basis for everything we do!
Name
Personal circumstances
What should you get to know?
Employment
Family situation
Common interests
Betting habits
Monitored Customers
For a customer to be managed through the automated affordability process they must be a monitored customer. Once a monitored customer has been created all bets regardless of stake should be monitored moving forward. There are no other reasons to create a new monitor customer profile. If a customer is already monitored within your shop, then you must continue to monitor all of their business regardless of stake value. By following this process we are identifying the customers that could potentially be at risk of gambling harm. This allows us to analyse their gambling, identify betting behaviours and allows us to interact at key stages during their gambling.
OTC
SSBT
FOBT
Monitored Customers
Monitored Customers
Monitored Customers
Monitored Customers
Customer Interactions
A customer interaction is our opportunity to converse with a customer regarding their current gambling activity.
Our 3 stage, structured approach to customer interactions is:
Identify
Interact
Evaluate
The two main reasons we would interact with a customer are:1. Upon identifying an indicator of potential gambling harm 2. Upon receiving an affordability email
Customer Interactions
Safer gambling leaflets are tools to assist you with your interaction. You could make the customer aware of additional tools that are available. Hover over each leaflet to find out more.
Customer Interactions
Once you have completed the interaction with the customer, it must be logged via the SRR page on the Compliance Hub. It is best to do this whilst the conversation is fresh in your mind. You should detail as much of the conversation as you can, paying particular attention to the information you have provided to the customer and the safer gambling tools they were made aware of, as well as the customer’s response to this. Always have in the back of your mind that someone who has never met yourself or the customer will be reading the interaction, and trying to assess the customer based on what you have written.
Customer Interactions
When receiving any affordability alerts it would be prudent to see if any interactions have previously been logged for the customer in question. This may better prepare you for an interaction you know you need to perform with a customer. Finally, we need to evaluate the interaction we have just had. The evaluation of an interaction can be carried out directly after the interaction and/or over the coming days and weeks after the interaction has taken place. You are evaluating the customer’s behaviour and/or betting patterns following your interaction. By taking the time to detail the conversations you have with your customers, you then allow the Compliance Analysts to build a picture of the customer's journey with Betfred to best enable them to support you in identifying customers who may require further intervention.
Customer Interactions
If you complete an interaction with a customer, it is good practice to make your team members aware of this so that they can continue to observe the customer in your absence and conduct further interaction as required.
A customer who usually stakes £10 a race increases their stakes to £50 a race and is becoming noticeably agitated.
You would speak with the customer and point out that you have noticed an increase in their spend and ask them if everything is ok.
You could also make them aware of safer gambling tools that are available to them.
If on the back of this interaction the customer acknowledges their increased spend and reverts back to their usual staking pattern, this would be your evaluation.
£1,000 loss in last 7 days
Each day, you must check the Compliance HUB for any £1,000 loss affordability alerts that are new or still pending. The Early interaction should take place with the customer prior to any bets. 1. Inform the customer of their recent losses. 2. Ask the customer if they are happy with their current level of spend. 3. Log a detailed account of the conversation via the affordability alert on the Compliance HUB.Only once you have completed the interaction, it is important that you then follow the link, this takes you to the SRR for the automated affordability alert. Following these steps and logging the interaction before accepting any further bets will prevent exceptions being received the following day.
£1,000 loss in last 7 days
£3,000 loss in last 30 days
This is known as an enhanced interaction. If one of your monitored customers is identified as losing at least £3,000 in a rolling 30 day period, you will receive an automated email the following day prompting you to complete an interaction prior to the customer placing another bet. This interaction is integral in the customer’s journey. This is where you must make the customer aware of the control measures available in shop and where to get additional support should they require it. When completing this interaction, you should record a comprehensive account of the conversation you have had with the customer as an SRR via the affordability alert, clearly detailing the information you have provided and received. The level of detail recorded is key to documenting the customer’s journey. This is known as the narrative and the more detail contained within the interaction the better equipped the Compliance Analysts are to assess the customer's exposure to potential gambling harms.
£3,000 loss in last 30 days
The customer is eligible to receive an automated interaction alert once every 30 days, but can happen at any point after they generate the £1,000 alert. You will receive reminder emails every day for 30 days until you have followed the link within the email and logged an SRR. Even if the customer returns after 30 days you still must follow the steps in the email. If you do not follow the link within the email and log the SRR before the next bet is accepted from the customer an exception will be generated.
£3,000 loss in last 30 days
£12,000 loss in last 365 days
If a customer is identified as losing £12,000 in a rolling 365-day period, you will receive an automated email instructing you to request photographic ID that provides proof of address and date of birth on the customer's next visit. The ID must be obtained, logged and scanned via the ID/SOI printer app, prior to any further gambling taking place. When asking the customer to provide ID you should complete an interaction and make the customer aware of the safer gambling measures available to them. It is important to note that the customer is averaging losses of at least £1,000 a month at this stage. When completing this interaction, you should record a comprehensive account of the conversation you have had with the customer, clearly detailing the information you have provided and received.
£12,000 loss in last 365 days
The level of detail recorded is key to documenting the customer’s journey. This is known as the narrative and the more detail contained within the interaction the better equipped the Compliance Analysts are to assess the customers exposure to potential gambling harms. On the day the identification is requested, customer can gamble in one single transaction, up to the value of £1,000. Following that, no further bets to be taken until ID is supplied. You will receive reminder emails every day for 60 days until you have followed the link within the email to log the customer's ID. Even if the customer returns after 60 days you still must follow the steps in the email. If you do not follow the link within the email and log the ID before another bet is taken an exception will be generated.
£15,000 loss in last 365 days
If one of your monitored customers is identified as losing £15,000 or more in a rolling 365 day period and did not complete a satisfactory self-certification at the £6,000 stage, your shop will receive an automated email. Attached to the email will be a Source of Income letter. You will need to print the letter and include a self-certification leaflet, placing both in a sealed envelope ready for the customer on their next visit to the shop. Each letter has a unique reference number that relates directly to the customer. It is imperative that only the letter sent is issued to the customer for whom it is intended. Where staffing levels allow, the customer should be handed the letter in a discreet way, you should explain to the customer that it is a request for documentation to allow us to ensure their gambling is in keeping with their level of affordability. (Source of Income / Funds)
£15,000 loss in last 365 days
The letter will explain to the customer they have two options for supplying information for review: When approaching a customer, where possible you should speak to the customer in a discreet way, explaining the two options available to them.
Providing financial documentation
Self-certification form (details can be found on £6,000 loss stage)
£15,000 loss in last 365 days
On the day the documentation is requested, customer can gamble in one single transaction, up to the value of £1,000. Following that, no further bets to be taken until you have received notification that their source of income has been verified by the Compliance Team. You will receive reminder emails every day for 60 days until you have followed the link within the email confirm the customer has been handed their letter. Even if the customer returns after 60 days, you still must follow the steps in the email. If you do not follow the link within the email and confirm the letter has been given to the customer before another bet is taken, an exception will be generated.
£15,000 loss in last 365 days
£5,000 stakes in a day
There are two ways in which a customer can reach the £5k stakes in a day ID request. Once a customer has staked £5,000 in a day, you must then request and log full details of their ID, as well as scan a copy of their ID via the ID/SOI printer app prior to accepting any further bets from the customer. When asking the customer to provide ID you should then log the full details of the interaction on the SRR page, making the customer aware of safer gambling measures available to them. Once ID has been provided, full details should be logged under the 'Customer ID' section of the Compliance Hub.
Single bet of £5,000 or more
Cumulative bets totalling £5,000 or more
£5,000 stakes in a day
To satisfy an ID request the customer must be able to provide photographic ID along with the following information: • Full Name • Address • Date Of Birth To log a customer’s ID, you should go onto the Compliance Hub > Customer ID. When logging the customer’s ID, you are asked to select the customer’s “Monitored Customer” name from the drop down menu. By doing this, it will link the customer’s ID to their monitored customer profile in the till. This means if the customer goes on to reach the £25,000 stakes or £12,000 loss ID request threshold, you will not receive an automated email prompting you to request ID again. Making the process smoother for both your shop and customer.
£5,000 stakes in a day
£25,000 stakes in 90 days
Once a customer has staked £25,000 in a rolling 90 days, you will recieive an automated email instructing you to request photographic ID, prior to the customer placing any further bets. The customer must provide you with photoprahic ID, you should log full details of their ID, as well as scan a copy of their ID via the ID/SOI printer app prior to accepting any further bets from the customer. (The customer can have upto £1000 in one transaction, on the day of the request should they not have ID with them) When asking the customer to provide ID you should then log the full details of the interaction on the SRR page, making the customer aware of safer gambling measures available to them. Once ID has been provided, full details should be logged under the 'Customer ID' section of the Compliance Hub and a copy scanned via the ID/SOI app on your shop printer.
£25,000 stakes in 90 days
To satisfy an ID request the customer must be able to provide photographic ID along with the following information: • Full Name • Address • Date Of Birth To log a customer’s ID, you can either - By doing this, it will link the customer’s ID to their monitored customer profile in the till. This means if the customer goes on to reach a £5,000 stakes or £12,000 loss ID request threshold, you will not receive an automated email prompting you to request ID again. Making the process smoother for both your shop and customer.
Follow the link in the affordability email send to your shops email inbox, this will direct you to the ID log in the Compliance Hub.
Via the Compliance Hub, under Customer ID > Affordability > Select the customer to provide ID. This will take you to the ID log for that customer.
£125,000 stakes in 365 days
When a customer is identified as having staked a minimum of £125,000 in a rolling 365 day period, the customer will be required to provide us with proof of their source of income / wealth / funds. Your shop will receive an automated email. Attached to the email will be a Source of Income (SOI) letter. You will need to print the SOI letter and place it in a sealed envelope and issue it to the customer on their next visit to the shop. Each letter has a unique reference number that relates directly to the customer, it is imperative that only the letter sent is issued to the customer for whom it is intended. Where staffing levels allow, the customer should be handed the letter in a discreet manner. You should explain to the customer that it is a request for documentation to allow us to ensure their source of funds is in keeping with their current level of gambling. Be confident in letting the customer know this is now standard practice amongst all high street bookmakers.
£125,000 stakes in 365 days
The letter explains to the customer they have two options for supplying documents: Sending documents via the ID/SOI printer app on behalf of the customer should always be a last resort. Customers should be encouraged to provide their documents themselves via their personal email, to allow for fluid communication between the customer and compliance.
By email to info.documents@betfred.com
To the address on the letter they receive
Money Laundering
"Money laundering is the illegal process of making money, which has been generated by criminal activity, look to have come from a legitimate source"
Money Laundering
Money Laundering
Placement is the first stage of money laundering where criminals use various methods like gambling, blending of funds, currency smuggling, etc. to introduce proceeds of crime into financial system.
Placement
Layering is essentially the use of placement and extraction over and over again, using varying amounts each time, to make tracing transactions as hard as possible.
Layering
Integration in money laundering is when criminals introduce illegally obtained funds into the economy through seemingly legitimate transactions - making the dirty money appear clean. But it's important to remember this: The money is still not clean.
Integration
Money Laundering
Loading cash into the SSBTs and printing a value ticket. Leaving the store with the value ticket.
How can customers use our premises to launder money?
Loading cash into the FOBTs and withdrawing a ticket to be collected at the counter.
Placing large stakes on short odds.
Placing bets on known non runners.
Asking for the payout to be made in a different way in which the bet was accepted, e.g. paid in cash, winnings back to card.
Money Laundering
Unrecognised Crime
Case Study: Regular customer, who owns the very popular fish and chip shop in the village, is losing approx. £300 on the FOBT’s on 3 / 4 nights a week. This money could be coming straight from the till in the restaurant, therefore it may not have been declared as income, which would mean that no tax will have been paid on it. This equates to £46k - £62k a year of tax evasion. Think about the customers in your shop who may have similarities to the case study above.
Money Laundering
Internal Suspicious Activity Reports
Crime could be anything from dealing drugs, selling counterfeit goods, theft, fraud or anything else we have discussed over the last few pages. If you suspect any of your customers are commiting a crime on the premises, it is your responsibilty to report this. You can do this via the ISAR report on the Compliance Hub.
How do you record any suspicious activity?
Support and Staying Safe
Ask the Compliance Team a Question
The most efficient way to contact the compliance team is via 'Ask the Compliance Team a Question' on the Compliance Hub. Once your message has been received, a Compliance Analyst will call you at your shop at the earliest opportunity. When sending your message it is important to include the details for what you wish you discuss so that the analyst can have any necessary information available for the call. If you believe you have an emergency/ urgent compliance concern, you should always seek guidance from your Area Team in the first instance. If your question relates to the Affordability process, you should first refer to the training documents on the Learning Hub to see if your question is answered. If not, you should select 'Affordability Trigger Alert' from the drop down when completing your question.
Link
Support and Staying Safe
Where you have identified an indicator of potential harm caused by problem gambling, it is important that we interact with these customers in a supportive way. This is where your knowledge about the customer will allow you to determine how to approach the interaction. If you do not know the customer you should apply knowledge about the average customer to determine your next step. - Listen to the customer and try not to talk over or argue with them - Build rapport through empathy - Put yourself in the customer's shoes - Lower your voice, if the customer gets louder, start speaking more slowly and in a lower tone Your calm demeanour will reflect on them and will help them to settle down. Never get angry or upset, if the customer is swearing or being verbally abusive never take it personally. Remember to utilise the Safer Gambling tools available in your shop to provide information to the customer and support your interaction. Your safety is paramount and you should only ever interact if you feel safe to do so. If you do not feel it is safe, in this situation you would still complete an SRR and select 'A concern about a customers gambling but no interaction made'.
Compliance Emergencies
If it is felt that a customer is an immediate risk to themselves, for example, using words or phrases which indicate that they wish to cause harm to themselves. Offer the customer the 'You Are Not Alone' leaflet, stop serving the customer straight away and contact a member of your Area Team immediately for advice and support. You should also record an SRR detailing the full reasons for your concern. In addition to the above, if you become aware of a current or past customer who has committed suicide, you must record this as an SRR, including as much detail as possible, and make your Area Team aware in the first instance. It is a licence requirement that the business notifies the Gambling Commission if we know or have reasonable cause to suspect that a person who has gambled with us has died by suicide (LCCP 15.2.2). In the event that you believe you have any kind of compliance emergency, your Area Team should be your first port of call to provide guidance and support. Remember, conducting regular and meaningful interactions with customers who are displaying indicators of gambling related harms can help them to seek any support they may need.
Disposable Income
Its important to think about your customers circumstances when deciding on the apropriate level of interaction. The next 4 activities will help to show disposable income for individuals with differant salaries and personal circumstances you should always ask yourself, based on what i know about a customer, is thier gambling affordable and sustainable.
Disposable Income
Name: Wendy Aisle Net Salary: £20,984 Job Title: Retail Location: Glasgow Rent/Mortgage: £1,000 Council Tax: £125 Gas & Electric: £172 Water: £80 TV Licence: £14 Internet: £30 Mobile Phone: £50 Subscription: £25 Debts: £150
Disposable Income
Name: Penny Payne Net Salary: £28,645 Job Title: Nurse Location: Stoke Rent/Mortgage: £750 Council Tax: £105 Gas & Electric: £130 Water: £50 TV Licence: £14 Internet: £33 Mobile Phone: £65 Subscription: £70 Debts: £80 Car: £125
Disposable Income
Name: Bob T Builder Net Salary: £35,870 Job Title: Self-Employed Location: Cardiff Rent/Mortgage: £900 Council Tax: £110 Gas & Electric: £160 Water: £70 TV Licence: £14 Internet: £34 Mobile Phone: £40 Subscription: £65 Debts: £400 Car: £600
Disposable Income
Name: Elon Gates Net Salary: £41,765 Job Title: Senior Manager Location: London Rent/Mortgage: £1,600 Council Tax: £95 Gas & Electric: £180 Water: £85 TV Licence: £14 Internet: £27 Mobile Phone: £55 Subscription: £97 Debts: £350 Transport: £400
Training Sign Off
Thank you for taking the time to complete the Affordability Training. If you require further guidance, please refer back to the training or your affordability flip chart for guidance. Click on the sign off button in the Learning Hub to confirm your undrstanding of this training.
The most common reason for this is because all affordability SRRs need to be logged via the link provided within the email. Please follow the link or via the affordability section of the Compliance Hub, completing all mandatory fields before saving the SRR this will stop any future reminders.
Yes, you will stop receiving email reminders for customers after the following timeframes:• £1,000 loss in 7 days: 30 days • £3,000 loss in 30 days: 30 days • £5,000 stake in 1 day: 60 days • £6,000 loss in 365 days: 60 days • £12,000 loss in 365 days: 60 days • £15,000 loss in 365 days: 60 days • £25,000 stakes in 90 days: 60 days Although you are no longer receiving a reminder, the interaction and any other necessary actions will still be required to take place on the customer’s next visit to the shop.
If a customer’s documents are accepted and they are cleared to gamble, your shop will receive an email to inform you of this, and your Area Team will also be made aware.
No, once a customer has been issued with a Source of Income letter they should not be allowed to gamble in any capacity until they have received confirmation that their documents have been accepted.
Log this as an SRR. Using the email link provided, tick the box stating that you have issued the SOI letter to the customer.
All customers receive a response to the documents they provide within 72 hours. If a customer believes they have not yet had a response. The customer can request an update by contacting info.documents@betfred.com.
Yes, each occasion should be treated as a separate action. You will need to conduct an interaction and log the SRR via the email link each time an email is generated. It is essential that regular and meaningful interactions are logged for our customers reaching the affordability alerts, to ascertain if the customer is comfortable with their level of gambling and that we have up to date logs to support this information.
The reminder will only be removed once you follow SRR link within the email and tick the box to confirm that the SOI letter has been provided to the customer. Once this action has been completed, this will prevent further reminders from being sent to your shop.
The details of where the customer needs to send their information is contained on the letter. info.documents@betfred.com Spectrum Arena,56/58 Benson Road, Birchwood, Warrington, Cheshire, WA3 7PQ. Always encourage your customer to send their documents via email as this will allow us to respond within 72 hours. Only if the customer cannot send their own documents, these can be scanned via the ID/SOI printer app.
Yes – there are many reasons to interact with a customer, and many tools available to prompt you to conduct an interaction such as: FOBT Alerts, mandatory and voluntary SSBT Alerts Customers behaviour Customers betting patterns 3rd party concerns for a customer
No, once a customer has been issued with an ID request letter they should not be allowed to gamble in any capacity until they have received confirmation that their documents have been accepted.
If the customer opts to complete the self certification form, you should inform them that once it has been completed it will be reviewed by the compliance team and follow the steps set out in £6,000 loss process. Once reviewed the customer, shop team and area team will be emailed by the compliance department informing them if it has been accepted or not. If it is accepted then the customer can continue to gamble. If it is not accepted the customer will be requested to send in source of income documentation as outlined in option 2 (physical documents). Again, the customer, shop team and area team will receive the outcome from the compliance department once a decision has been made.
If you believe you have identified a customer who has previously been asked for Source of Income in another shop, then you should contact your Area Team or the Compliance department as a matter of urgency to see if bets can be accepted from the customer.
No, the action does not need to be carried out with this customer. The bet(s) should be reassigned to the correct customer and your Area Team should be informed of this error immediately.
The ID should be logged on the Compliance Hub > Customer ID > Create New ID. If the customer is monitored, ensure you select their monitored customer name from the drop-down menu on the ID page as this will link the ID directly to the customer.
You can still have an interaction with the correct customer. Following the interaction an SRR should be logged on the Compliance Hub, under Customer Interaction > Create New SRR.
A customer interaction is in no way intended to be intrusive, they are designed to ensure that the customer is comfortable with their level of gambling and to provide evidence that the customer has been made aware of the following: o Level of spend o Losses incurred o Safer gambling tools available to them
If the customer opts to send their physical documentation to the Compliance department, the customer will be reviewed and the customer, shop team and area team will be emailed by the compliance department informing them if it has been accepted or not. If it is accepted then the customer can continue to gamble.
You will need to inform your Area Manager/Team, as the alert email may need to be communicated to the other shop team.
Yes, at this stage it will be even more important to conduct an interaction with a customer, both when an alert is and is not received. It is important to remember the customer has either staked a minimum of £125,000 or lost a minimum of £15,000 over a rolling 365-day period to be issued with a Source of Income request. It is important that regular interactions are still taking place to ensure that the customer is still comfortable with their level of gambling.
A passport alone is not enough to satisfy an ID request, the customer will need to provide a utility bill to complete the process.