Gambling Startups
Offering a licensable activity in, or even from, the UK will require a licence from the UK Gambling Commission. There is such a wide range of activities that fall under the remit of the commission that you should not assume that your business is exempt. Consider these less obvious examples of companies requiring a licence:
- game operators offering 'loot' boxes whose items take a range of values which may be auctioned or exchanged for real money (even if the exchange of money occurs outside the operators business);
- those allowing items ('skins') to be gambled within a game, either with a 'house' or with other players, when those items can be exchanged for real money as above;
- a software company, based in the UK, who builds gambling software even if that software is for companies unregulated by the UK Gambling Commission, and will never be used by UK consumers.
Over many years in the gambling industry I have developed an acute sense of what the UK Gambling Commission and Isle of Man Gambling Supervision Committee consider to be responsible operations. Having obtained my Personal Management Licence and successfully applied for licences in the UK and Isle of Man I am well placed to help you through the application process, or relieve you of that stress and make the application on your behalf.
My Experience
Gambling Specific:
UK and Isle of Man Licence Applications; I have successfully completed licence applications in both these jurisdictions for Mustard Systems Limited, managing the entire process from initial requirements gathering to the final submission.
Compliance / Policy Work; the creation of company wide policy documents to address the regulatory requirements following review of the legislation.
Information Security and Remote Technical Standards; I prepared the ISMS policies and was the main point of contact for the auditor. I ensured our development team produced a product compliant with the Gambling Commission's Remote Technical Standards.
Payment Services and PCI-DSS; acquiring a suitable payment processor and acquiring bank can be notoriously difficult for new licence holders; a lot of the mainstream payment providers do not deal with gambling related companies. Additionally, you will be required to be compliant with the Payment Card Industry Data Security Standard and, at the very least, complete and Self Assessment Attestation of Compliance - a process I have completed for Mustard Systems Limited.
Third Party Integrations; I have experience sourcing and evaluating third parties for the supply of game state data, pricing data, ID&V, payment services, casino games, address finders, and live chat. I have enough technical experience to evaluate their offering, and enough commercial experience to negotiate at industry rates.
App Development; I worked closely with an external team who built the Android and IOS apps for MustardBet. On a weekly basis I worked with their PM to review progress, monitor performance and prioritise the backlog. I was also responsible for managing the process and relationship with Google and Apple once the products were complete.
Startups:
Getting stuff done; everything is urgent, but not everything is important. Calmly managing priorities to make steady progress is vital to a startup's success. Eventually I should run out of important things to do - that's the point at which you fire me.
Fail fast; a theme I have seen repeated far too often is the fear of putting something live because it's not yet *something* (it really doesn't matter what the *something* word is). This fear of failure is completely natural, but it's crippling your ability to move forward. Define an MVP, agree it, and once it's built, get it out the door and start learning. And when I say agree it, I mean every single stakeholder must agree that the definition of the MVP gives a product suitable to put in front of a customer. Don't put off the conversation with sales (it's always sales) until after you've built it hoping to convince them then. Seriously, just don't.
Build, Measure, Learn; as a mathematician and quant (before I moved into Ops) I have the statistical ability to create and run meaningful experiments and it's my belief that this iterative cycle is the most important part of building a successful startup. The agile framework lends itself to integrating these results into the business development as quickly as possible.
Creating a productive environment; Andrew Garrood, CEO of MustardBet, is fond of saying, "we're defined by how we fix things" - we all make sub-optimal decisions, but it's how we deal with them, what we learn, and how we apply that to the future which fosters productivity. During the innovation stage employees must have freedom to fail - in a startup you simply can't afford the time and monetary cost of operating in any other way.
Growing the team; as the business grows it will be natural to find employees with more exacting domain knowledge - I can't be your payments / compliance / AML guy forever - nor would I want to be. I do, however, have plenty of experience recruiting for these roles and getting people operational.
About You
If you're branching out into a world in which a gambling licence is a requirement, but don't have the internal knowledge or experience to jump straight in to making the application please get in touch.
I am available as a permanent employee, contractor or consultant - all subject to availability.
If you're building another 'me-too' bookmaker then you may be better served with one of many Corporate Service Providers who can walk you through the application. You may also want to consider proving your commercial viability as an affiliate before going through the long process of acquiring a licence.