New UKGC Tech Standards to Include Player Cheating, Confiscated Funds Guidelines

New technical standards are set to be implemented by the UKGC [United Kingdom Gambling Commission], with a near-final version of the upcoming standards just published this week by the UKGC.  Among the more stringent updates included in the revised standards are a full subset of guidelines addressing some of the most problematic issues in modern online-poker play, ranging from player collusion and the use of automated software aids (“bots”), to what happens when funds are confiscated by a site after cheating has been confirmed.

uk-gambling-commissionThe upcoming changes, which will go through one last round of industry and consumer feedback before being finalized, represent the first true overhaul of the UKGC’s technical standards in nearly a decade, since 2007.  Today’s online-poker world has changed markedly since then.  The UKGC issued a call for responses and suggestions back in 2015 as it began preparing the comprehensive update that now nears its final version.

When the agency sought industry input last year, four main areas were at the top of the list: (1) collusion, (2) automated poker robots (the “bots”), (3) third-party poker software (in the sense of live-time player aids), and (4) unregulated collection and use of poker hand histories.  In collecting information on those primary areas, the UKGC discovered additional areas of concern.  As the UKGC’s recent report proclaims, “the exercise identified a number of good practice measures, it also identified inconsistencies and issues across the industry.”

In other words, both players and UK-facing poker sites are likely to face somewhat more stringent rules once these guidelines come fully into force.  As they relate to peer-to-peer (online) poker for real money, the coming changes will be presented as technical changes/additions to two rules within the standards set, RTS 11 and RTS 16.

Here’s how the UKGC plans to strengthen RTS 11, which deals with collusion and cheating issues.  (New additions are noted in bold/italic.)

Proposed addition to RTS 11 (additions highlighted)/IPA 7

RTS requirement 11A

Measures intended to deter, prevent, and detect collusion and cheating must be implemented.

Gambling systems must retain a record of relevant activities to facilitate investigation and be capable of suspending or disabling player accounts or player sessions. Operators must monitor the effectiveness of the measures implemented.

RTS implementation guidance 11A

d. Detection measures may include, detecting and investigating the following, where appropriate:

i. players who frequently share the same tables

ii. players from same address who share the same table

iii. suspicious patterns of play (such as chip dumping)

iv. unusual gameplay statistics

e. Customer complaints about cheating should be investigated.

f. Records should be kept of investigations which result in an account being closed including:

i. player details (name, location, which licence the activity was in reliance on), scale of the offences (financial and number of players), time and date etc. 

ii. the reason for investigation (including whether it was initiated by customer contact) and the outcome

iii. any relevant evidence such as reports, screenshots, chat history etc. This information should be considered when updating the risks identified in relevant policies or procedures.

IPA 7A RTS requirement 11B

Information must be made available about the operator’s policies and procedures with regard to cheating, recovered player funds and about how to complain if a customer suspects other participants are cheating.

IPA 7A RTS implementation guidance 11B

a. As a minimum deterrent, customers should be informed that accounts will be closed if the customer is found to have cheated.

b. Relevant information should be included in terms and conditions or rules.

c. Information should include how an operator deals with seized funds recovered following integrity investigations. It is not expected to cover every scenario but should highlight the main aims of the policy.

Note the last paragraph of the above, which tentatively addresses what happens when cheaters’ funds are confiscated.  Some UK-facing sites have been accused of pocketing such confiscated funds rather than conducting a thorough review of the alleged cheating action and returning said confiscated funds to cheating players.  The new clause does not directly state that such funds must be returned to cheated players, but certainly indicates that the UKGC plans to monitor these situations in the future.

Issues dealing with the various forms of third-party software concerns — “bots”, live-time strategy assists and data-collection/use programs, will be dealt with in the new RTS 16.  That’s an expanded version of the old IPA 4 standard, which covered some of the same territory, circa 2007.

Here’s how the UKGC proposes that the expanded RTS 16 will read:

Proposed new requirement (formerly IPA 4 with some additions highlighted)

IPA 4/ RTS 16– Use of automated third party gambling software 

Peer-to-peer gambling

RTS aim 16

To make customers in peer-to-peer(s) gambling aware that they may be gambling against a software program (designed to automatically participate in gambling within certain parameters, sometimes referred to as a bot), or a human aided by third party software.

IPA RTS requirement 16A

Where peer-to-peer(s) customers may be gambling against programs deployed by other customers to play on their behalf, or customers assisted by third party software, information should be made available that describes that this is possible, and if it is against the operator’s terms and conditions to use certain types of software, how to report suspected robot use.

RTS requirement 16B

Operators must make it clear to players whether the use of third party software is permitted and if so which types. Operators that prohibit certain types of third party software must implement measures intended to deter, prevent, and detect their use.

RTS implementation guidance 16B 

a. Clear, accessible information about the types of software that are permitted or prohibited should be made available. This does not have to be an extensive list but could be a description of the key features of the software.

b. Operators should take steps to contact customers (via email, inbox message or some other appropriate method) to draw their attention to this information. Periodic updates should be sent to ensure up-to-date player knowledge is maintained.

The UKGC will accept continuing responses in connection to the proposed changes to its online-gambling technical standards until January 17th, 2017.  The proposed guidelines, a template for submitting comments, and contact information is all available via the UKGC’s website.

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