Responsible Conduct of Gambling: A Practical Safer Gambling Framework

Duty of Care in Practice: Identify, Interact, Evaluate

Player protection is not only about giving tools. Teams also need a consistent way to spot elevated risk, respond in a proportionate way, and confirm whether the response helped. This is where duty of care workflows matter. A common structure is Identify, Interact, Evaluate, which turns responsible conduct of gambling into an operational routine that can be trained, audited, and improved over time.

Identify: detect risk signals and assign a risk level

The goal is to spot patterns that may indicate loss of control or escalating harm, then route the case to the right type of action. Signals should be evaluated in context, not as single “red flags.”

Examples of signals often used in safer gambling monitoring

• Rapid increases in deposits, stake size, or session length

• Multiple deposits in a short window, especially after losses

• Frequent failed deposits or repeated payment attempts

• Withdrawal reversals or attempts to cancel withdrawals repeatedly

• Persistent late night play that intensifies over time

• Sudden pattern shifts after a long period of stable play

• Support contacts showing distress, anger, desperation, or “need to win back” language

• Repeated use of bonuses in a way that looks compulsive rather than recreational

• Returning immediately after time out or attempting to shorten a break

Best practice

• Use a tiered risk model (low, medium, high) so interventions are consistent

• Document the signals and the reason for the tier decision for auditability

• Combine behavioural indicators with account context, not assumptions about the person

Interact: use a proportional intervention ladder

Interventions should be supportive, clear, and designed to reduce risk. The aim is not to punish players. It is to slow down escalation and make safer choices easier.

A practical intervention ladder

1. Nudge and education
   Provide a short message pointing to limits, time outs, and activity history.

2. Direct safer gambling message
   Explain what pattern triggered the outreach, offer specific tool recommendations, and encourage a break if appropriate.

3. Human support interaction
   A trained agent contacts the player, checks wellbeing, and helps set limits or initiate a break.

4. Mandatory protections when risk remains high
   Apply stronger actions such as enforced limits, deposit caps, or account restrictions in line with policy and local rules.

Message design principles

• Use plain, neutral language

• Avoid threats, shame, or pressure

• Do not frame intervention as a promotion or bonus opportunity

• Include one clear next step (set a limit, take a time out, self exclude, contact support)

Evaluate: measure impact and refine

Without evaluation, the workflow becomes a box ticking exercise. Evaluation answers two questions: did the intervention reduce risky patterns, and are teams applying the policy consistently?

KPIs you can track

• Tool uptake after outreach (limits set, time outs started, self exclusion initiated)

• Changes in behaviour (reduced session length, reduced deposit frequency, fewer withdrawal reversals)

• Engagement metrics (message open rate, response rate, support contact outcomes)

• Repeat incident rate within 7, 30, 90 days

• Consistency and quality (case notes completeness, tiering accuracy, escalation timing)

Responsible Marketing and Promotions: What to Avoid and What to Do Instead

Marketing is one of the fastest ways to increase risk if it pushes urgency, exaggerates winning, or targets people who are likely to be vulnerable. A safer gambling approach treats advertising and promotions as part of consumer protection, not just growth. Responsible conduct of gambling applies here through clear rules, consistent approvals, and messaging that does not mislead or pressure.

What marketing should avoid

Use this as a practical “do not” list for ads, landing pages, push notifications, email, influencer content, and affiliate placements.

• Targeting or appealing to minors in imagery, language, placement, or partnerships

• Implying gambling is a financial solution to debt, bills, or hardship

• Overstating chances of winning or presenting gambling outcomes as predictable

• “Risk free” or “guaranteed” framing that hides conditions or creates false certainty

• Urgency and pressure tactics that push immediate deposits or extended play

• Normalising excessive play by praising long sessions, big deposits, or “all in” behaviour

• Blurring entertainment and income by describing gambling as “easy money”

• Influencer content that feels like advice on how to win, rather than entertainment disclosure

• Misleading bonus presentation where key terms are hidden or hard to understand

What to do instead: a safer marketing checklist

These actions make promotions clearer and reduce the risk of misleading or coercive messaging.

• Use plain language for bonuses and key conditions, especially wagering requirements and time limits

• Make key terms visible on the first view, not buried behind multiple clicks

• Avoid manipulative UI patterns such as countdowns that create panic or shame based prompts

• Include safer gambling signposting where appropriate, especially on high intent landing pages

• Apply frequency controls so messaging does not bombard users who show risk signals

• Segment responsibly by excluding self excluded users and suppressing marketing to users in risk workflows when policy requires it

• Document approvals with a clear owner for copy, creative, and targeting rules

Bonus and promotion clarity: minimum standards

Promotions are not automatically unsafe, but unclear promotions create confusion and can drive chasing.

• State the wagering requirement clearly and show a simple example calculation

• Explain what counts toward wagering and what does not

• Show expiry dates and limits in the same screen as the headline offer

• Separate bonus funds from cash in balances and explain any restrictions

• Avoid framing bonuses as a solution to losses or a way to “get even”

Affiliate and partner conduct controls

Affiliates can create brand risk if they publish misleading claims. Keep partner rules short, enforceable, and measurable.

• Require approved messaging and ban “guaranteed win” language

• Restrict placements likely to reach minors

• Enforce transparent disclosures for sponsored content and influencer partnerships

• Use ongoing monitoring and remove partners that repeatedly break rules

• Keep an audit trail of approvals and violations

KYC, Age Assurance, and AML: Core Controls for Safer Play and Compliance

Strong identity and financial crime controls support player protection in two ways. First, they help prevent underage access and reduce impersonation or account misuse. Second, they create cleaner, more reliable player data, which improves risk monitoring and customer interaction. In a practical safer gambling program, KYC, age assurance, and AML are not separate from player protection. They are foundational safeguards that responsible conduct of gambling relies on.

Age assurance: prevent underage access

The goal is to make it difficult for minors to register, deposit, or gamble, and to detect suspicious cases early.

Minimum practices

• Age gating at registration with clear eligibility rules

• Identity verification before high risk actions, depending on jurisdiction and policy

• Restricted access until verification for features where required

• Consistent checks across devices and channels to prevent bypass

• Clear handling rules for suspected underage accounts, including suspension and review

Operational notes

• Train support teams to recognise common underage indicators, but avoid assumptions.

• Keep a documented process so actions are consistent and auditable.

KYC basics: know who is using the account

KYC is broader than age. It aims to confirm the account holder is real and that payment methods and account activity align with that identity.

KYC controls often used

• Identity and address verification where required

• Name matching and payment verification to reduce third party payment risk

• Duplicate account checks to prevent repeated bonus abuse and evasion of limits

• Source of funds or affordability style checks when local rules require risk based financial verification

Keep KYC messaging clear and neutral. Poor wording can feel punitive and may drive users to unregulated alternatives. The goal is to be firm on rules while staying transparent about why checks exist.

AML basics: reduce money laundering and fraud risk

AML focuses on detecting and responding to suspicious activity patterns. It protects the business, but it also supports safer play by identifying high risk behaviour linked to fraud, coercion, or financial distress.

Common AML red flags in gambling contexts

• Unusual deposit and withdrawal patterns that do not match typical play

• Frequent deposits followed by rapid withdrawals with minimal gameplay

• Multiple accounts linked to the same payment method or device signals

• Repeated failed deposits or attempts across many payment methods

• High volume activity that escalates sharply without a clear explanation

• Attempts to bypass verification or provide inconsistent information

What good looks like

• A documented escalation path from automated detection to human review

• Clear case notes and decision reasons

• Timely reporting and compliance actions in line with local requirements

The “no credit” principle

Many safer gambling frameworks discourage extending credit for gambling. Where it applies, a simple policy is to avoid features that encourage play on borrowed money or defer payment in ways that can worsen harm. If your market allows credit related products, treat them as higher risk and ensure additional controls and clear consumer information.

Quick checklist for implementation

• Define when checks happen (registration, before deposit, before withdrawal, thresholds, risk triggers)

• Make outcomes clear (verified, pending, restricted, suspended)

• Log decisions and evidence for auditability

• Align KYC and AML alerts with safer gambling monitoring so teams see the full picture

• Train frontline teams on consistent language and escalation rules

Governance, Training, and Accountability: Making Safer Gambling Work in Real Operations

Policies and tools only reduce harm if people use them consistently. Governance is the layer that turns intentions into repeatable decisions across product, marketing, support, and compliance. A mature program assigns clear ownership, trains teams on real scenarios, and measures outcomes with a small set of reliable KPIs. This is where responsible conduct of gambling becomes durable instead of seasonal or reactive.

Roles and ownership model

You do not need a large team, but you do need clear accountability so decisions are consistent and auditable.

Core roles to define

• Safer gambling lead or program owner responsible for policy, roadmap, and reporting

• Compliance and legal to interpret obligations and approve controls and messaging

• Customer support leadership to implement interaction playbooks and quality checks

• Product and UX to design tools, friction, and disclosure flows that people actually use

• Data and risk analytics to define signals, thresholds, alert quality, and dashboards

• Marketing governance to control campaigns, segmentation, and affiliate compliance

Operating rhythm

• A regular review cadence, such as monthly KPI review and quarterly policy refresh

• A documented escalation process for high risk cases and complex complaints

• Clear version control for policies, templates, and training materials

Training that improves decisions, not just awareness

Training is most effective when it is role based and scenario driven. Avoid one generic deck for everyone.

Training topics that matter

• How player tools work, and what to do when a player asks to change limits or reverse a withdrawal

• How to recognise and document risk signals without diagnosing the player

• How to apply the intervention ladder consistently and respectfully

• How marketing and bonuses can increase harm, and what language to avoid

• How to route issues that overlap with AML or identity checks

• How to handle self exclusion correctly, including marketing suppression and reinstatement rules

Quality control

• Regular sampling of safer gambling interactions for tone, clarity, and policy alignment

• Coaching loops for agents and periodic refresh training for all customer facing roles

KPIs that prove impact

Choose metrics that show whether protections are used and whether risky patterns reduce after intervention. Keep the KPI set small enough that teams actually watch it.

Tool adoption and usage

• Percentage of active players who set a deposit, loss, or time limit

• Time out and self exclusion starts and completion rates

• Activity statement views and export downloads

Intervention effectiveness

• Percentage of flagged cases that receive the correct intervention level

• Tool uptake within 7 days after outreach

• Reduction in risky patterns after intervention, such as shorter sessions or fewer repeated deposits

• Repeat incident rate within 30 and 90 days

Marketing and compliance health

• Rate of marketing suppression applied correctly for self excluded or high risk users

• Affiliate violations found per month and resolution time

• Percentage of campaigns that pass compliance review without rework

Operational consistency

• Case note completeness and decision traceability

• Time to action for high risk alerts

• Appeal and complaint outcomes related to safer gambling controls

Continuous improvement loop

A practical improvement cycle keeps the program effective as products and player behaviour evolve.

• Review KPIs, sample cases, and campaign performance

• Identify friction points in tools and intervention messaging

• Update thresholds, templates, and training based on evidence

• Document changes so audits are easy and the team learns over time

90-Day Implementation Roadmap: How to Roll Out a Safer Gambling Program

This roadmap is designed to be practical. It assumes you already have a live product and need to tighten player protection quickly without disrupting core operations. Adjust the order to match your regulatory requirements, but keep the sequence: define ownership, ship essential tools, build the interaction workflow, then measure and iterate.

Days 0 to 30: Set foundations and ship the essentials

Goal: establish accountability and deliver baseline player protections that are easy to access and hard to bypass.

1. Assign ownership and publish a clear policy

• Name a program owner and define escalation paths

• Document the intervention ladder and decision rules

• Create short internal guidance for product, support, and marketing

2. Audit your current user journey

• Map where deposits, bonuses, and re deposits happen

• Identify places where messaging or UX increases pressure

• Confirm where limits and self exclusion are available and how easy they are to find

3. Launch or upgrade essential tools

• Deposit, loss, and time limits

• Time out and self exclusion

• Reality checks and a clear activity statement view

4. Set minimum design standards

• Plain language, consistent placement, and cross device enforcement

• Immediate effect for tightening protections

• Cooling off for increasing limits where policy allows

5. Implement basic marketing suppression rules

• Ensure self excluded users do not receive promotional messaging

• Add basic campaign controls to reduce excessive nudging

Days 31 to 60: Build risk detection and customer interaction

Goal: turn tools into an operational system by detecting elevated risk and responding consistently.

1. Define risk signals and tiers

• Choose a starter set of behavioural signals

• Create low, medium, high tiers with clear thresholds

• Establish manual review rules for edge cases

2. Deploy alerting and case management

• Route alerts to trained teams

• Require consistent case notes and decision reasons

• Build templates for outreach messages and support scripts

3. Train the right teams with scenarios

• Role based training for support, compliance, product, and marketing

• Practice real situations such as withdrawal reversals, bonus disputes, and distress contacts

• Set a quality review routine for interactions

4. Introduce proportional interventions

• Nudge messages for low risk

• Direct safer gambling outreach for medium risk

• Human contact and stronger protections for higher risk cases when appropriate

Days 61 to 90: Measure, tune, and make it repeatable

Goal: prove impact, reduce false positives, and build a reporting rhythm that leadership will actually use.

1. Build a simple KPI dashboard

• Tool adoption and usage

• Intervention outcomes and repeat incident rates

• Marketing compliance health and suppression accuracy

• Operational consistency metrics such as time to action and case quality

2. Tune signals and messaging

• Reduce noise from alerts that do not correlate with risk

• Improve message clarity and reduce friction to taking a break or setting limits

• Review whether certain promos or journeys drive spikes in risky behaviour

3. Strengthen governance

• Formalise monthly reviews and quarterly policy refresh

• Document changes and keep version control for audits

• Define how product launches and campaigns must pass safer gambling review

4. Plan the next iteration

• Expand tool coverage or improve UX based on usage data

• Add richer segmentation and safeguards for higher risk segments

• Improve affiliate monitoring and enforcement if relevant

Frequently Asked Questions (FAQ)