Gambling Commission licence conditions and codes of practice

 All societies and local authorities licensed by the Commission to run lotteries are required to comply with the specific licence conditions and codes of practice relevant to them. The specific licence conditions are set out at the time a licence is issued.

 Some of the licence conditions and requirements of the codes of practice are referred to below. Specific details are contained in the  [Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/online)  .

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 Society and local authority lotteries - proceeds and other monetary limits](/licensees-and-businesses/guide/page/society-and-local-authority-lotteries-proceeds-and-other-monetary-limits)

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 Last updated: 23 February 2021

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Society and local authority lotteries - proceeds and other monetary limits

 A society or local authority lottery must apply a minimum of 20% of the gross proceeds of each lottery directly to the purposes of the society or in the case of a local authority a purpose for which the authority has power to incur expenditure.

 Up to a maximum of 80% of the gross proceeds of each lottery may be divided between prizes and the expenses of the lottery.

 In a single large society or local authority lottery the maximum value of tickets that can be sold is £5 million. The maximum aggregate value of lottery tickets that can be sold in any calendar year is £50 million (pro-rata limit of £31,311,475 in 2020).

 The maximum prize in a single lottery is £25,000 in the case of a small society lottery and £25,000 or 10% of the proceeds (gross ticket sales), whichever is greater, in the case of a large society or local authority lottery. Therefore, a large society or local authority lottery that sells the maximum number of tickets in a single lottery (£5 million) could award a maximum top prize of £500,000.

 Rollovers are permitted provided the maximum single prize limit is not breached.

 Every ticket in the lottery must be the same price and the cost of purchased tickets must be paid to the society before entry into the draw is allowed.

 There is no maximum price of a lottery ticket.

 No lottery organised by a large society or local authority may operate in such a way that a player can win a prize greater than the statutory prize limit of £500,000.

 No lottery organised by a large society or local authority may be linked to any other lottery in such a way that a person who wins a prize in one also wins a prize in another, unless the aggregate of those prizes is less than or equal to the statutory prize limit of £500,000.

 Where separate lotteries have a feature that allows a player to win a larger prize than the statutory maximum of £500,000 by selecting the same numbers in different lotteries and these lotteries are decided by the same draw, no advertisement or other marketing of the lotteries may refer to this feature. A lottery cannot be linked to a prize competition or free draw if the maximum amount which a person can win is more than £500,000 in aggregate.

 Where separate lotteries have a feature that allows a player to win a larger prize than the statutory maximum of £500,000 by selecting the same numbers in different lotteries and these lotteries are decided by the same draw, no advertisement or other marketing of the lotteries may refer to this feature. A lottery cannot be linked to a prize competition or free draw if the maximum amount which a person can win is more than £500,000 in aggregate.

 [Previous page
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 Information to lottery players: proceeds and prizes](/licensees-and-businesses/guide/page/information-to-lottery-players-proceeds-and-prizes)

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 Last updated: 23 February 2021

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 Social responsibility codes attached to all lottery operating licences include a requirement to take account of the Commission-s guidance on providing information to lottery players about how proceeds are used and the likelihood of winning a prize and how those prizes are allocated.  This information must be available prior to participating in a lottery.

 Further information about these requirements can be found in the Commission-s guidance  [Information to lottery players: proceeds and prizes](/licensees-and-businesses/guide/information-to-lottery-players-proceeds-and-prizes)  .

 This requirement is in addition to the current provision in social responsibility code (4.3.1), which requires all society and local authority lottery licensees to publish annually the proportion of lottery proceeds (as a percentage) returned to the purposes of the society or local authority, in the previous calendar year. This should be through either their annual report, lottery page of their society or local authority website or any other means appropriate to the size and scale of the organisation.

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 Society and local authority lotteries - proceeds and other monetary limits](/licensees-and-businesses/guide/page/society-and-local-authority-lotteries-proceeds-and-other-monetary-limits)  [Next page
 Ticket information](/licensees-and-businesses/guide/page/ticket-information)

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 All tickets in a society lottery or local authority lottery licensed by the Commission or society lottery registered with a local authority must state:

* the name of the society on whose behalf the lottery is being promoted
* the price of the ticket
* the name and address of the member of the society responsible for the promotion of the lottery. In the case of a small society lottery run under local authority registration the name and address of the ELM if there is one may be given as an alternative
* the date of the draw, or the means by which the date may bedetermined
* the fact, where that is the case, that the society is licensed by theCommission
* the website address of the Commission, if licensed by the Commission.

 Tickets that are issued through a form of remote communication or any other electronic manner must specify the information above to the purchaser of the ticket and ensure that the message can be either retained (saved) or printed.

 [Previous page
 Information to lottery players: proceeds and prizes](/licensees-and-businesses/guide/page/information-to-lottery-players-proceeds-and-prizes)  [Next page
 Sale of tickets](/licensees-and-businesses/guide/page/sale-of-tickets)

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 Last updated: 23 February 2021

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Tickets in society and local authority lotteries promoted under licence from the Commission must not be sold to anyone in a street.


 They can be sold:

* by a person in a static structure such as a kiosk or display stand
* from a shop premises in a street, or,
* door to door.

 For this purpose a ‘street- includes any bridges, road, lane, footway, subway, square, court, alley or passage (including passages through enclosed premises such as shopping malls) whether a thoroughfare or not. Society lotteries and/or the responsible ELM must also ensure that they have any necessary local authority permissions, such as a street trading licence. The Commission has recommended to licensing authorities that they also apply this restriction to small society lotteries. Small societies should check with the licensing authority they are registered with.

 Lottery tickets must not be sold to, or by, those under the age of 16.

 Society lottery tickets may be sold from vending machines. These machines may be sited anywhere that a society lottery ticket can be sold, as mentioned previously.

 They are not subject to restrictions on the number that can be sited and no licence is required to site or supply them. However, licensed operators (societies and/or ELMs) must ensure that they fulfil their social responsibility duties under the licence conditions and codes of practice in respect of preventing underage play and problem gambling. In the case of lottery ticket vending machines the operator may wish to ensure that the machine is located in a supervised area or that some other arrangements are put in place to prevent underage and problem gambling.

 To minimise the risk of fraud, societies licensed by the Commission should adopt one or more of the following measures when sending unsolicited mailings of lottery tickets:

* prohibit the unsolicited mailing of lottery tickets to non-members of the promoting society
* limit the value of tickets sent to any one address which is not that of a member of the promoting society to £20
* maintain records of tickets distributed and not returned. The Commission recommends that these records should include details of the address to which the tickets have been sent, their total value and their serial number. Information on unsold tickets not returned by the date of the lottery draw should be retained for at least six months.

 Society lottery operator licences (remote and non-remote) from the Commission allow societies to sell lottery tickets within Great Britain (England, Scotland, and Wales). If you wish to sell lottery tickets outside of Great Britain you will need to check the laws that apply in that jurisdiction.

 [Previous page
 Ticket information](/licensees-and-businesses/guide/page/ticket-information)  [Next page
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 For society and local authority lotteries promoted under licence from the Commission, accounting records must be retained for a minimum of three years from the date of any lottery to which they relate and they must be made available for inspection by the Commission on request. These records must contain, in respect of each lottery, details of the:

* the total proceeds
* the amount allocated to prizes
* the amount of proceeds allocated to expenses, and details of those expenses
* the amount applied directly to the purposes of the society or the purposes for which the local authority has power to incur expenditure as the case may be
* the number of sold and unsold tickets in each lottery.

 Where the cumulative proceeds of lotteries promoted by a society or local authority exceed £1,000,000 in a calendar year, the Commission must be sent a written confirmation from a statutory auditor that the proceeds of those lotteries have been fully accounted for in annual audited accounts. Such confirmation must be provided within ten months of the end of the period to which the accounts relate.

 A statutory auditor is someone who is eligible for appointment as a company auditor under section 1210 of the Companies Act 2006 but is not, in the case of a society:
 **a)**  a member of the society
 **b)**  a partner, officer or employee of such a member
 **c)**  a partnership of which a person falling within (a) or (b) is a partner.

 [Previous page
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 Lottery submissions](/licensees-and-businesses/guide/page/lottery-submissions)

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 Every society and local authority licensed by the Commission must provide a submission for each lottery. This must show the total proceeds and how they have been distributed between prizes and expenses and the amount applied directly to the society-s purposes, or purpose for which the local authority has power to incur expenditure.

 A licensed society-s or local authority-s submission must be sent to the Gambling Commission no later than three months after the date of the lottery draw or in the case of an instant (scratchcard) lottery within three months of the last date on which tickets in the lottery were on sale. At the time it is submitted each submission must be verified by a Personal Management Licence holder, a qualified person in the case of a small scale operator or the person (in the case of societies) named on the lottery tickets as being responsible for the promotion of the lottery.

 Lottery submissions should be completed online through the Commission-s  [eServices portal (opens in a new tab)](https://secure.gamblingcommission.gov.uk/EServices/Account/Login?ReturnUrl=%2feservices)  . Guidance on how to complete a lottery submission is available throughout the online system.

 Every society registered with a local authority to run small society lotteries must submit a statement providing the following information:

* the date on which tickets were available for sale or supply and the date of the draw
* the total proceeds of the lottery (remote and non-remote)
* the amounts deducted by promoters of the lottery in providing prizes, including rollovers
* the amounts deducted by the promoters of the lottery in respect of costs incurred in organising the lottery
* the amount applied directly to the purpose for which the promoting society is conducted or for which the local authority has power to incur expenditure (at least 20% of the gross proceeds)
* whether any expenses incurred in connection with the lottery were not paid for by deduction from the proceeds, and, if so, the amount of expenses and the sources from which they were paid.

 A registered society-s statement must be sent to the local authority within three months beginning on the day the draw (or last draw) in the lottery took place. It must be signed by two members of the society appointed in writing for that purpose by the society-s governing body and accompanied by a copy of that appointment.

 [Previous page
 Financial requirements](/licensees-and-businesses/guide/page/financial-requirements)  [Next page
 Social responsibility](/licensees-and-businesses/guide/page/social-responsibility)

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 [Section 235(2)(d) of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/235)  and Regulations under that section define a B3A machine as one where the results of the lottery are determined by the machine and/or the machine displays the results of the lottery without an interval of at least one hour between the sale of the ticket and the announcement of the result. These machines can only be sited in a members- club or miners- welfare institute holding a club gaming or club machine permit issued by the licensing authority. Clubs and institutes are entitled to site one category B3A machine on the premises.

 [Previous page
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 Proceeds and profits](/licensees-and-businesses/guide/page/proceeds-and-profits)

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 Last updated: 17 October 2022

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 [Section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254)  clarifies what is meant by ‘proceeds- and ‘profits- of alottery.

 ‘Proceeds- are the total amount paid for tickets before any deductions.

 ‘Profits- are the amount of proceeds less any deductions for prizes, rollovers, and reasonable expenses incurred in connection with running the lottery.

 [Previous page
 B3A lottery machines](/licensees-and-businesses/guide/page/b38-lottery-machines)  [Next page
 Misusing profits of lotteries](/licensees-and-businesses/guide/page/misusing-profits-of-lotteries)

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 Under  [section 260 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/260)  it is an offence to use or permit profits from a large society or local authority lottery to be used for any purposes other than for the purpose for which the lottery was permitted or promoted.  [Section 261 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/261/enacted)  applies the same offence to small society lotteries.

 [Previous page
 Proceeds and profits](/licensees-and-businesses/guide/page/proceeds-and-profits)

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The group-s function is to approve the destination of monies paid as part of regulatory settlements and to approve applications to be added to the approved LCCP RET list.


 The group's scope for Regulatory Settlement funds includes:

* the consideration of the destination for those parts of regulatory settlements which do not relate to identified victims and thus the monies are to be directed for socially responsible purposes
* approvals in response to operator proposals in relation to destinations. These proposals are normally considered after the regulatory settlement amount has been agreed by the Gambling Commission and publicly announced
* the consideration of destinations / proposals for pre-approval in principle, to be referenced in the event that they are proposed by an operator in the future, or where an operator requests assistance on an approvable destination.
* have any role in setting the amount which the Commission may approve as sufficient by way of divestment, payment in lieu of financial penalty or Commission-s costs of investigation
* agree the divestment of funds to victims (this may be completed during the enforcement process and may be done voluntarily by operators outside a regulatory settlement)
* have powers of commissioning or procurement, and does not manage money nor is accountable for spend.

 The group acts in accordance with the Commission-s Statement of Principles for Determining Financial Penalties, and particularly, the following extract:

###  Payments in lieu of financial penalties

 *2.14. Payments made in lieu of a financial penalty as part of a regulatory settlement do not need to be paid into the Consolidated Fund as financial penalties imposed under section 121 do. As a result there is more flexibility about how such monies may be used. However, The Commission will apply the following principles in approaching such agreed payments:*

* The Commission reserves the power to approve the destination of monies paid as part of a regulatory settlement
* Operators must not generate positive publicity from the settlement
* Payments need to be demonstrably over and above 'normal' RET contributions
* Where practicable, the operator should return money to any identified victims
* If victims cannot be identified or there are no victims, the monies should be given to charity for socially responsible purposes
* Socially responsible purposes would include purposes which address gambling related harm or in some way promotes one or more of the licensing objectives
* where payments are made with the aim of addressing gambling-related harm, the presumption is that the money would be paid to GambleAware (formerly Responsible Gambling Trust) to be used for specific agreed purposes that accelerate their commissioning plans
* Operators should have no interest in organisations who will receive divested funds
* There should be meaningful evaluation of the effectiveness of projects or research funded by a specific regulatory settlements
* Research findings must be made public to help raise standards
* Clear timeframes should be set for payment of monies and for delivery of work paid for from those monies.

 In applying the above principles, the Commission takes into account the following points, where relevant:

* where payments are made with the aim of addressing gambling harms, the funds should accelerate progress against existing structures to reduce gambling harms
* the operator must make the offer to direct funds under the current  [Licensing Compliance and Enforcement policy statement](/policy/licensing-compliance-and-enforcement-under-the-gambling-act-2005)  , but may initially make a proposal which seeks Commission input on what destinations they would consider approvable, consistent with the approach set out in the current  [Statement of Principles for Determining Financial Penalties](/policy/statement-of-principles-for-determining-financial-penalties)
* approvals will track and take account of the potential for overlap of funding of projects or programmes of work with funding or commissioning from other organisations (where known)
* it will normally be more effective to use one-off payments for projects or programmes of work that will not require ongoing funding
* the body to be in receipt of the funds must be willing to accept the money with clear associated paperwork that the monies are part of a settlement in lieu of financial penalty, not a voluntary donation.


 The group's scope for applications to join the LCCP RET list includes consideration of the application received, assessing criteria has been met through:

* evidence of appropriate governance through independent oversight or regulation
* evidence that they are signed up to deliver or commission one or more of the functions of research, prevention or treatment to reduce gambling harms
* a commitment to delivering aspects or actions of reducing gambling harms against a set timetable, within existing collaborative structures and to full but proportionate evaluation processes
* organisations seeking to be on the approved list for treatment should be part of the existing National Gambling Treatment Service, and/or part of existing NHS England, Scotland or Wales mental health or addiction services and registered with the CQC, or the Care Inspectorate Wales or Scotland.
* assessing organisations periodically, to ensure that the organisation still meets the criteria to be on the LCCP RET list.

 The group does not:

* have any role in deciding which organisations on the LCCP RET list gambling businesses contribute to and has no influence in facilitating financial contributions elsewhere
* have powers of commissioning or procurement, and does not manage money nor is accountable for spend.

 [Previous page
 Social Responsibility Funds Group - Terms of Reference](/licensees-and-businesses/guide/social-responsibility-funds-group-terms-of-reference)  [Next page
 Membership and attendance](/licensees-and-businesses/guide/page/social-responsibility-funds-group-terms-of-reference-membership-and)

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 Last updated: 28 February 2023

 Show updates to this content  Third bullet in 'Applications to join the LCCP RET list' updated as the National Strategy to Reduce Gambling Harms ran until April 2022.


 The group-s membership is as follows:

* Executive Director – Research & Policy (Chair)
* three other members at Director and/or Head of or above.

 A minimum of two members is required for the meeting to be quorate. Deputies may attend where necessary and will be approved by the members of the group prior to the meeting.

 The Chair can nominate another member to chair the meeting in their absence.

 A member of the legal team will attend to provide legal advice, including on application of the Gambling Commission-s Statements of Principles and Policies, but is not a member of the group.

 Other employees of the Commission or advisers may be requested by the Committee to attend meetings to assist with discussions on any particular matter.

 Any member of the group or attendee must declare any involvement in any proposed recipient, or regulatory process which has led to a particular regulatory settlement to be discussed at the group. Where the group identifies a possible a conflict of interest, or perception of bias due to this involvement, that attendee will be asked to leave the meeting for the relevant decision.

 [Previous page
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 Meetings and decision-making](/licensees-and-businesses/guide/page/social-responsibility-funds-group-terms-of-reference-meetings-and-decision)

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 The Group will meet at least quarterly, or more frequently if required.

 The Group can also review proposals by correspondence at the discretion of the Chair.

 Meetings can take place in person, by telephone or by video-conference


 The Governance Team will record decisions made and actions agreed.

 Externally, the information on the decisions for both LCCP RET approval and destinations of regulatory settlements approved and actioned will be published at least annually.

 The group may escalate issues to Executive Team where appropriate or where the group is deadlocked.

 [Previous page
 Membership and attendance](/licensees-and-businesses/guide/page/social-responsibility-funds-group-terms-of-reference-membership-and)  [Next page
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Applicants may appeal decisions made by this group, providing a written appeal is received within 28 days of the communication of the original decision. The appeal will be considered by a panel of two Commissioners who have had no previous involvement with the application. The appeal will be a paper process only.


 These terms of reference will be reviewed by the Executive Team annually.

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 Meetings and decision-making](/licensees-and-businesses/guide/page/social-responsibility-funds-group-terms-of-reference-meetings-and-decision)

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Sports Betting Intelligence Unit terms of reference

 The aim of the Gambling Commission (the Commission) is to make gambling fairer and safer  [1](#ref-1)  . Our five strategic priorities are to deliver this vision are to:

* protect the interests of consumers
* prevent harm to consumers and the public
* raise standards in the gambling market
* optimise returns to good causes from lotteries
* improve the way we regulate.

 In the summer of 2009 the Department for Digital, Culture, Media and Sport (DCMS) established a Sports Betting Integrity Panel (the Panel), bringing together experts from the betting industry, the police, players, fans, Sports Governing Bodies (SGBs), the legal profession and the Commission. The aim of the Panel was to make recommendations as to the design and implementation of an integrated strategy to uphold integrity in sport and associated betting.

 One set of the recommendations of the Panel-s report concerned the Commission, building on its existing work to establish a Sports Betting Intelligence Unit (SBIU). The Commission welcomed this recommendation and the SBIU became operational in 2010.

 The primary role of the SBIU is to contribute to the Commission-s strategic priorities. It will do this by supporting and facilitating collaboration across operators and other agencies concerned with raising standards in relation to sports betting integrity. It also strives to foster national and international standards where it is clearly in the interests of British consumers to do so.

 This document sets out the terms of reference for the SBIU, based on the recommendations of the Panel and the benefits of our experiences since the unit was formed.

##  Terms of Reference

##  Further information

##  Footnotes - SBIU terms of reference

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 Last updated: 19 January 2022

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 The SBIU will focus upon collecting and analysing information and intelligence relating to potentially criminal activity in respect of sports betting, where that activity:

* relates to a sporting event that occurred in Great Britain
* involves parties  [2](#ref-2)  based within Great Britain
* actively occurred under a Gambling Commission licence .

 The SBIU will act as the operational hub of Britain-s Betting Integrity National Platform as set out in Article 13 of the Macolin Convention.

 It will help bring together the intelligence efforts of partners and play its part in protecting sports betting from corruption in support of the Sports and Sports Betting Integrity Action Plan and the strategic elements of the  [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents)  :

* the SBIU will develop intelligence to inform investigative decision making on the prosecution or disruption of criminal offences or regulatory action under the Gambling Act
* where relevant and appropriate, this intelligence may be made available to third parties to assist disciplinary action. This could include, for example, action taken by a Sports Governing Body under a sports rule or by a betting operator against an employee. Other disruptive action may be taken by any of the parties. The intelligence will also inform strategic analysis on sports betting integrity issues
* the SBIU will develop specific intelligence on individual events and/or individuals. It will not undertake general, pre-emptive monitoring of betting markets or sporting events. This remains the role of betting operators and sports governing bodies respectively
* the SBIU will provide bespoke support to international tournaments where relevant. More information can be found in  [‘Protecting Betting Integrity-](/licensees-and-businesses/guide/protecting-betting-integrity)  [3](#ref-3)  .
* the SBIU will contribute to debriefings of sports betting integrity cases conducted by the Commission and partners to develop and share knowledge, working practices and techniques.


 If you would like more information about the SBIU please consult the Commission-s website or contact the Commission on their general enquiry line on 0121 230 6666.

 If you have information concerning illegal gambling activity that you would like to report please contact the Commission on our confidential intelligence line on 0121 230 6655.


 1  [Gambling Commission strategy 2018 - 2021](https://assets.ctfassets.net/j16ev64qyf6l/1GBL4oxzfZHLnW6hha6Ixh/f6f50060887d969dfbfa0c4ff6ff3600/Strategy-2018-2021.pdf)

 2  Examples of ‘Parties- could include participants as defined by a sports governing body, employees of a betting operator, employees of a TV or telecoms company etc

 3  Additional information for event organisers can also be found in the Governments  [Gold Framework (opens in a new tab)](https://www.gov.uk/government/publications/gold-framework-2018-edition)


* [Sports Betting Intelligence Unit terms of reference](#)
* [Terms of Reference](#terms-of-reference)
* [Further information](#further-information)
* [Footnotes](#footnotes-sbiu-terms-of-reference)

 [Print this guide](#)


 The Gambling Commission (the Commission) was set up under the Gambling Act 2005 to regulate commercial gambling in Great Britain. We are committed to keeping crime out of gambling, ensuring gambling is conducted fairly and openly, and the vulnerable protected from harm or exploitation by gambling.

 We are also committed to raising standards in relation to sports betting integrity, as outlined in our  [corporate strategy](/about-us/transparency/strategy-plans-progress-and-reports/strategy-plan)  ‘Making Gambling Safer and Fairer.

 This document summarises the Commission-s policy and approach to protecting betting integrity, which is primarily concerned with sports betting. It should be stated that the principles within this document also apply to betting on non-sporting events; for example,the winners of film awards or outcomes of TV talent competitions.

 The integrity of betting, given its scale and popularity with the British public, is important to maintain and protect. Consumers must have confidence and belief that when they place bets, they are doing so on markets that are fair, free from betting related corruption and with British licensed operators that are effective in managing risk.

 Given the global nature of sport and gambling, we also need to understand international influences on sport, betting and communications if we are to fully realise and manage the current and emerging risks.

 There is evidence from abroad of increasingly sophisticated and organised criminal activity related to the provision of illegal betting and manipulation of sports results. Intelligence suggests that these criminal groups reportedly view match fixing and betting corruption as a less risky criminal activity compared to other offences such as drug smuggling or people trafficking.

 There have been incidents of corruption in the UK but these seem to generally be opportunistic rather than linked to organised crime. Based on current evidence, we believe that the risks of systemic corruption of sports betting and sports activities in the UK are currently less than that experienced in other jurisdictions. However, we are aware that we cannot assume that this position will be maintained. We know the impacts of such corruption would have a significant detrimental impact to the interests of the public, the ethical and commercial interests of sport and the betting industry and would harm Great Britain-s reputation as a safe place to bet and host sports competitions.

 It is expected there will continue to be situations where individuals seek to profit from betting by using insider knowledge or by choosing to ignore the rules of their sport or the terms of their employment. These infringements cannot be ignored, though it will notalways be appropriate to prosecute these persons through the Criminal Justice System. Alternatively, there may be more effective measures which can be taken by sports governing bodies and employers who have legal power to do so.

 The threat of ‘match fixing- (or match manipulation  [1](#ref-1)  ) and corrupted sports betting is an increasingly high profile international issue. The Council of Europe, European Union, Interpol, International Olympic Committee (IOC) and other international sports organisations are actively seeking to address the issue and the presidents of the IOC, FIFA and UEFA have spoken publicly of their concerns.


 1  As defined in the  [Macolin Convention: Manipulation of sports competitions (opens in a new tab)](https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000016801cdd7e)  means an intentional arrangement, act or omission aimed at an improper alteration of the result or the course of a sports competition in order to remove all or part of the unpredictable nature of the aforementioned sports competition with a view to obtaining an undue advantage for oneself or for others.

##  Background - Protecting betting integrity

##  Our strategy - Protecting betting integrity

##  Effective collaboration

##  Working with betting operators

##  Working with sport

##  Working with other law enforcement agencies

##  International collaboration

##  Managing the threats

##  Appendix 1 - Protecting betting integrity

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Background - Protecting betting integrity

 The past few years has seen a significant increase in awareness and reporting of sports betting integrity issues, particularly in the higher profile sports, which have been well documented. Evidence of corrupt betting in the UK has been in the main limited to what appear to be discrete cases, opportunistic in nature, rather than being evidence of systematic and systemic corruption. However, we cannot afford to be complacent in thinking that UK sports betting and sport is immune from the continued threats of organised criminal activity.

 In 2009, DCMS established a Sports Betting Integrity Panel, drawing together representatives of the betting industry, the police, players, sports governing bodies (SGBs), the legal profession and the Commission to make recommendations on the design and implementation of a collaborative approach to protect the integrity of UK sport and betting.

 The Panel-s report, commonly known as the Parry Report, made a series of recommendations, central to which was that the betting industry, sports governing bodies and associations, the Commission and police should commit to activity within their sphere of competency to prevent and deter those posing the threats. In addition, the report recognised how a collaborative approach could maximise the collective impact by working together to deal with the short and longer term issues. The recommendations included establishing the  [Sports Betting Intelligence Unit](/licensees-and-businesses/guide/sports-betting-intelligence-unit-sbiu)  within the Commission to deal with reports of betting-related corruption.

 Building on outcomes of the Parry Report, the Sports Betting Integrity Forum (SBIF) was established in 2012 to develop Britain's approach to protecting sport and sports betting against the risks to integrity. It brings together representatives from sports governing bodies, betting operators, sport and betting trade associations, law enforcement and gambling regulation. The Forum is part of Britain's national platform to address the risks of match-fixing and threats to sports betting integrity.

 The purpose of the Forum is to support and coordinate partners' individual and collective efforts in developing and implementing the  [Sport and Sports Betting Integrity Action Plan (PDF) (opens in a new tab)](https://www.sbif.uk/assets/files/Sport-and-Sports-Betting-Integrity-Action-Plan-2021.pdf)  (SBI Plan) which sets out the UK-s strategy for protecting integrity in sport and sports betting. The Forum keeps pace with the increasing complexities, such as international influences, focusing on prevention, disruption and deterrents. This approach reflects the belief that match-fixing presents a major and continuing challenge for the governance, culture, reputation and operational capabilities of sports and sports betting operators. The Commission is lead partner on the SBIF.

 The UK has also signed the Council of Europe-s Macolin Convention, which sets out the framework for managing risks associated with the manipulation of sporting events across Europe and beyond. In line with this framework, the SBIU and the SBIF form Britain-s national platform for managing betting integrity. The Commission represents the UK on the Council of Europe-s  [Group of Copenhagen (opens in a new tab)](https://www.coe.int/en/web/sport/network-of-national-platforms-group-of-copenhagen-)  , the network of national platforms which collaborates in the fight against betting integrity at an international level.


Our strategy - Protecting betting integrity

 The Commission remains committed to sustaining the national approach to managing betting integrity as defined in the SBI Plan. We will continue to work with partners and stakeholders in the betting industry, sport (including but not limited to SGBs, player associations and industry bodies) and law enforcement agencies to identify the vulnerabilities, support preventative action and strengthen the deterrents to corruption in betting. The collective objective is to prevent and discourage involvement in betting integrity issues by understanding the opportunities to subvert existing controls and making it more likely that those involved can be identified and appropriate sanctions imposed.

 To achieve this goal and support international efforts to combat the threats we are engaged with European and international efforts to develop effective operational collaborations.

 The Commission sees itself playing an important role through the continual development of the Sports Betting Intelligence Unit (SBIU), working in collaboration with partner organisations to identify the corruptors and corrupted. We aim to identify the longer term threats and to implement approaches that prevent and deter those that pose the greatest risk. To achieve this goal, we have established effective operational cooperation with our partners to maintain our understanding of the scale and scope of the threats presented to UK interests.

 The Commission will work on the principle of being risk-based and proportionate in determining the focus and scale of our activity.

 Whilst any lack of integrity related to how an event is managed will detract from the fairness and openness of that event and the interests of the sport involved, the Commission-s focus will be upon integrity matters directly related to betting. Specifically, where the outcome of an event has been influenced with the intention of benefiting through betting on it or where misuse of information is used when placing a bet. This includes making an assessment to consider if the offence of cheat has been committed.

 The Commission understands the importance of upholding betting integrity to sporting bodies, the betting industry and to the public. It is familiar with methods used in other countries to promote betting integrity such as restricting the types of bets offered or approving sports governing bodies- rules before allowing betting on those sports. The Commission has the power to impose such restrictions. However, the Commission does not consider, based on the available evidence, that such intrusive or resource intensive methods are warranted or would be effective in Great Britain, although we will continue to monitor developments in this area.


 We will work with partners to establish effective information exchange arrangements and promote the effective use of information to enable SGBs, betting operators and law enforcement, both nationally and internationally, to gain a better understanding of the risks faced and the options to manage those risks. The SBIU will act as the UK-s information and intelligence gateway.

 We will encourage and where appropriate facilitate sports governing bodies and betting operators to have effective direct agreements on joint working.

 Memorandums of Understanding (MOUs) that set out how we will work together are in place where appropriate with some organisations. The Commission will continue to review MOU requirements to sustain current agreements and initiate new ones as and when deemed necessary.


 The Commission will sustain its engagement with British licensed operators and others to maintain effective information exchanges. We will ensure that operators have appropriate clarity as to the work of the SBIU and the requirements of the Commission as to assurance that their controls are effective as set out in the  [Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/online)  . We will continue to work with betting operators- associations and trade bodies and other regulators on a national and international basis and will seek feedback as to how our national approach can be improved.

 As the regulator, the Commission is keen to emphasise that it is the primary responsibility of licensed operators to identify and mitigate the threats to the licensing conditions. We have an expectation that operators will comply with the conditions and have in place mechanisms to identify and act to protect their customers (and their own commercial) interests.

 The Commission considers  [licence condition 15.1.1](/licensees-and-businesses/lccp/condition/15-1-1-reporting-suspicion-of-offences-etc-non-betting-licences)  to be of particular importance in this context. In summary this is the requirement for betting operators to share information on suspicious activity with the Commission. A copy of the wording of this licence condition can be found at appendix 1. We expect operators to have in place systems and procedures to identify suspicious or unusual betting patterns which will enable them to report relevant information to the Commission and to SGBs.

 The Commission will share information with relevant third parties to meet its statutory duties and only when legally allowed under relevant Data Protection law. This information may be of a general or specific nature that could be used to mitigate emergent risks and promote good practice, recognising the constraints of confidentiality.


 The Commission has established good working relationships with many sporting bodies. We will continue to build new relationships with organisations seeking to take steps to preserve the integrity of their sport. This includes those with whom we may have had limited or no previous engagement or where we consider the risks to be greatest.

 We will encourage and facilitate sport governing bodies to share information with us and with operators about suspicious sporting activity possibly related to betting integrity in order to offer support and help decide on the most appropriate course of action.

 We will work with and offer expertise to sports and betting operators, as befits our capability and resource constraints to share good practice and expertise. We will work to understand what education programmes, rules or codes are in place regarding participants betting and the sanctions that can be applied if these are breached.

 Where appropriate, we will share with sport governing bodies information about our investigative techniques and procedures to help sports bodies build up their capacity to uphold their own rules and conduct investigations on issues relating to their sport.

 We will where appropriate disclose information gathered by the Commission investigations to assist Sports Governing Bodies in applying their disciplinary codes. We will do this in line with the requirements the relevant Data Protection Legislation.

 We will explore with SGBs, sports organisations and relevant others (for example, the Sports Betting Group, the Professional Players Federation, UK Sport etc) opportunities for the facilitation of the sharing of best practice.

 SBIU will also work with event organisers to  [provide bespoke support for international tournaments hosted in Great Britain](/licensees-and-businesses/guide/protecting-betting-integrity)  .


Working with other law enforcement agencies

 Sports betting investigations can be complex and resource intensive. The Commission recognises the competing priorities and operational challenges faced by law enforcement agencies. In circumstances where the scale and scope of the criminal activity related to sports betting integrity is considered to be of a serious nature then the Commission will engage with law enforcement agencies to discuss them adopting investigations, with Commission support and expertise.

 The Commission will continue to raise awareness of the threats and indications of sports betting corruption, the work of the Commission and the support it can offer police and law enforcement. Betting integrity cases often involve parties from a wide geographical range and therefore determining the best route for an investigation to take can prove problematic.

 The Commission has working relationships with the National Police Chief-s Council (NPCC) and Police Scotland and agreements are in place as to how we exchange information and facilitate joint operational activity. We will work with the National Crime Agency (and other agencies) in identifying the strategic threats to UK interests and specifically addressing the threats posed by the activities of organised criminality. We will contribute towards the UK Threat Assessment when requested.

 The SBIU will act as the secure intelligence and information portal between the Commission, law enforcement and other agencies. We will continually engage with and encourage these to identify, collect and share information and intelligence with us on potential betting integrity issues and promote the Commission as providing potential opportunities to add value to their work.


 Gambling and sport are global, multi million pound industries increasingly commercially linked, for example via ownership and sponsorship arrangements. They are promoted by modern technologies and advertising linking the excitement of sport with that of betting. Proliferation of the interest in and betting on sport has been assisted in the growth of internet use, ever increasing means for communications and 24/7 global access to both betting and broadcasting of coverage of sporting events.

 Whilst Britain will remain our primary focus, we recognise that British betting and sport is not immune to influence from external sources and domestic activities can in turn influence events elsewhere. As betting operators and sport have become increasingly globalised by virtue of changing organisations- scope and technology, so has organised crime. The evidence of organised crime groups infiltrating sport for betting corruption purposes both in Europe and in Asia indicates the need to ensure that we are communicating and collaborating with international stakeholders specifically to ensure British interests are protected.

 The Commission has neither the remit nor the resource to investigate this international criminality. However, in addition to establishing effective relationships with UK law enforcement agencies we will sustain our engagement with Interpol and Europol and support other foreign law enforcement investigations agencies as appropriate as an intelligence gateway to link them up with others.

 Many of the recent international developments have a positive impact for the Commission and others. For example, the Macolin Convention has developed engagement and cooperation between countries in the fight against corruption in Europe and beyond. It offers the prospect of strategies, and operational frameworks that will foster greater information, intelligence exchange and operational collaboration. The Commission and DCMS has been and will be involved in the development of these opportunities as necessary to ensure UK interests are represented.

 The regulatory landscape is rapidly changing as countries review and revise their policies with regards to the acceptability of gambling and in particular sports betting. The regulation of gambling is becoming more globally linked through inter regulator contacts, information exchange MoUs and mechanisms and the work of associations such as the Gaming Regulators International Forum (GREF) and International Association of Gaming Regulators (IAGR). We also work closely with the Council of Europe and European Union.

 The Commission will engage through these channels to identify and address the threat of corrupt sports betting and will provide information and intelligence it considers appropriate to other regulators and national platforms.

 Similarly sport and the betting industry are recognising the international dimensions to addressing the threats to the integrity of their interests. Our engagement with such organisations is being widened to international sports federations or organisations (for example the International Olympic Committee) and international gambling / betting associations. These are both a valuable source of information and potential recipient of information from the Commission subject to the appropriate safeguards.


 The Commission will gather intelligence and information to assess what potential offences may have been committed to decide on the proportionate and appropriate response and action. This will include who is best placed to address the offences and what actions or investigations can be carried out simultaneously.

 How we do this is set out in the Gambling Commission-s  [Betting Integrity Decision Making Framework](https://assets.ctfassets.net/j16ev64qyf6l/7idXWC0z9DPThoai2pQLdK/3ee8ef2d740b893c3c7361739874d768/Betting-integrity-decision-making-framework.pdf)  . CHANGE THIS ONCE PDF IS CONVERTED.


Appendix 1 - Protecting betting integrity

 The following codes are relevant to this information:

 [15.1.1 - Reporting suspicion of offences etc – non-betting licences](/licensees-and-businesses/lccp/condition/15-1-1-reporting-suspicion-of-offences-etc-non-betting-licences)

 [15.1.2 - Reporting suspicion of offences etc – betting licences](/licensees-and-businesses/lccp/condition/15-1-2-reporting-suspicion-of-offences-etc-betting-licences)


* [Protecting betting integrity - May 2019](#)
* [Background](#background-protecting-betting-integrity)
* [Our strategy](#our-strategy-protecting-betting-integrity)
* [Effective collaboration](#effective-collaboration)
* [Working with betting operators](#working-with-betting-operators)
* [Working with sport](#working-with-sport)
* [Working with other law enforcement agencies](#working-with-other-law-enforcement-agencies)
* [International collaboration](#international-collaboration)
* [Managing the threats](#managing-the-threats)
* [Appendix 1 - Protecting betting integrity](#appendix-1-protecting-betting-integrity)

 [Print this guide](#)


Betting Integrity Support for Major Sporting Events

 Sport and sports betting rely upon high standards of integrity. Match-fixing and related betting corruption undermines the ethos, reputation and commercial viability of sports and betting businesses. It can have an impact on the social, political and economic benefits derived from sports and sports betting. It can tarnish the reputation of participants across sport and impact upon the UK-s reputation as a safe environment within which to host sporting events and conduct gambling related business.

 The Gambling Commission-s Sports Betting Intelligence Unit (SBIU) can offer support to stakeholders responsible for hosting major events and tournaments in the UK, to help manage the potential risks of match-fixing or other betting integrity issues.

##  Who are the Sports Betting Intelligence Unit?

##  How can the SBIU support tournament organisers?

##  Appendix 1: Managing Betting Integrity

---

 Last updated: 18 January 2022

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Who are the Sports Betting Intelligence Unit?

 The SBIU is a unit within the Gambling Commission which deals with reports of betting-related corruption. While evidence of corrupt sports betting in the UK has so far been limited to what appear to be isolated incidents, it is recognised that there is no room for complacency.

 It is important for consumers to have confidence and belief that when a bet is placed with a Gambling Commission licensed betting operator, it is on markets that are fair and free from betting-related corruption.

 The SBIU works closely with the betting industry, sport governing bodies, international federations and competition organisers, as well as domestic and international law enforcement agencies to understand potential threats and to help protect the integrity of sport and betting.

 The SBIU collects information and develops intelligence about potentially corrupt betting activity. It receives information from various sources including (but not limited to) reports from the betting industry regarding suspicious activity on betting markets, concerns identified by sport governing bodies or tip-offs through the Gambling Commission-s confidential intelligence line.


How can the SBIU support tournament organisers?

 The SBIU can provide advice and support to major event organisers regarding the design of their processes for managing betting integrity risks. The SBIU can also coordinate stakeholder engagement for incidents where criminality is suspected (see reference to the ‘Triage Process- in the Gambling Commission-s  [Betting Integrity Decision-Making Framework (PDF)](https://assets.ctfassets.net/j16ev64qyf6l/7idXWC0z9DPThoai2pQLdK/3ee8ef2d740b893c3c7361739874d768/Betting-integrity-decision-making-framework.pdf)  and support joint communications strategies.

 Unusual and suspicious betting can be an indication of potential match-fixing or other integrity issues. Any betting operators offering services to consumers in Great Britain have to comply with the Gambling Commission-s  [Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp)  . This includes  [reporting suspicious betting activity to SBIU](/licensees-and-businesses/lccp/condition/15-1-2-reporting-suspicion-of-offences-etc-betting-licences)  .

 Betting operators may also, on occasion, identify sports participants placing bets in breach of sporting regulations.  [Licence Condition 15.1.2(2)](/licensees-and-businesses/lccp/condition/15-1-2-reporting-suspicion-of-offences-etc-betting-licences)  obligates Gambling Commission licensed betting operators to share such information with those sport governing bodies named within  [Schedule 6 of the Gambling Act (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/schedule/6/part/3)  .

 Any support provided by the SBIU will be proportionate to the profile of the event and the potential risks that exist. The SBIU will work closely with major event organisers and other relevant stakeholders to ensure any agreed processes are fit for purpose.

 The SBIU have provided integrity support to numerous major international sporting events including the:

* 2012 Olympic Games
* Rugby World Cup 2015
* IAAF Athletics World Championships 2017
* ICC Cricket World Cup 2019 and UEFA Euro 2020 (football).

 On an annual basis the SBIU also works closely with the organisers for major sporting events such as the Six Nations (rugby union), Wimbledon (tennis) and The Open (golf).

 Appendix 1 outlines a suite of options for organisers to consider when implementing a strategy for managing betting integrity risks for a major sporting event. It also highlights the type of support and assistance that the SBIU can provide.


###  Actions for consideration by organisers of major international events hosted in the UK

 **Action:**  Engagement with the Gambling Commission-s Sports Betting Intelligence Unit (SBIU) as soon as possible prior to the event to discuss integrity support arrangements.

 **Notes:**  This will facilitate early planning and discussion regarding key operational aspects such as intelligence collection, information sharing and communications strategies in the event of an integrity incident.

 Contact details:

 Sports Betting Intelligence Unit:  [sbiu@gamblingcommission.gov.uk](mailto:sbiu@gamblingcommission.gov.uk)

 **Action:**  Ensure clear betting rules and regulations are in place.

 **Notes:**  Provide clarity around which participants are covered by any rules/regulations/codes that are in place for the event (e.g. athletes, officials, coaches, support staff, friends and family, etc.).

 Outline any betting restrictions that apply to participants, define  [misuse of inside information](//assets.ctfassets.net/j16ev64qyf6l/4KPgzbWpVpd5ZPsE444S9F/f4c8a91df1d3e578d698a6fbd24c5a55/Misuse-of-inside-information.pdf)  in the context of your particular sport, ensure participants know what to do in the event of a corrupt approach and are clear on their obligations regarding what type of information to report (and to whom).

 Rules and codes should be supported by robust procedures for investigating incidents / allegations, along with a framework of sanctions that can be applied dependent upon the nature and seriousness of the incident (e.g. fines, suspensions, bans, etc.).

 Consider how aligned the National Governing Body-s rules are with those of any International Federations also involved in the delivery of the event.

 World Rugby-s  [Keep Rugby Onside (opens in new tab)](https://dev.integrity.worldrugby.org/)  is an excellent example of how to manage and promote protecting betting integrity at international level.

###  Actions for consideration by organisers of major international events hosted in the UK

 **Action:**  Ensure processes and procedures are in place for managing and sharing information to comply with data protection legislation.

 **Notes:**  Various pieces of legislation and accompanying guidance exist to support the sharing of information and personal data within the UK:

* [Data Protection Act 2018 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2018/12/contents/enacted)
* [Guide to the UK General Data Protection Regulation (UK GDPR) | ICO (opens in new tab)](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/)
* [Gambling Act 2005 - Section 30 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/30)  and  [Schedule 6 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/schedule/6)
* [Data Protection Act 2018 - Schedule 1 (Part 2) para.28: Standards of Behaviour in Sport](https://www.legislation.gov.uk/ukpga/2018/12/schedule/1/paragraph/28/enacted)  .

 Further practical considerations for event organisers and sports organisations can include the following (non-exhaustive) list:

* Identify a dedicated point of contact to handle information
* Ensure a documented information governance framework is in place outlining your procedures for securely handling and storing data (more advice on this can be found on the website of the  [Information Commissioner-s Office) (opens in new tab)](https://ico.org.uk/)
* Establish memoranda of understanding (MOU) and/or information sharing agreements with key partners.

 **Action:**  Educate all relevant participants to ensure they understand any integrity regulations that apply to them and the potential consequences of any breaches (not only to themselves but also the reputational damage it could cause to their sport, their fellow athletes/teammates, their families, etc.).

 **Notes:**  Keep communications simple and reiterate the key messages.

 Keeping an accurate record of when and where education was undertaken is critical for fair and consistent application of the relevant betting rules and regulations.

###  Actions for consideration by organisers of major international events hosted in the UK

 **Action:**  Consider preventative options to protect athletes.

 **Notes:**  Consideration can be given to the deployment of Integrity Officers at certain venues (e.g. hotels, open training areas, sporting arenas, etc.) where participants might be at a higher risk of exposure to corrupt approaches.

 **Action:**  Ensure processes are put in place for participants to report suspicious activity and corrupt approaches.

 **Notes:**  Ensure any related policies and obligations are well communicated. Appoint a trusted source to deal with any reports and ensure processes are in place that include protection for those individuals who reporting such concerns.

 Ensure education covers not just in-person approaches, but also those via social media and messaging applications, as corruptors can often pose as potential sponsors, agents or fans to initiate conversations with athletes or other sports participants.

 **Action:**  Consider conducting a ‘betting integrity risk assessment- to determine key threats to your event.

 **Notes:**  Considerations could include risk-assessing the following aspects:

* Risk profiles of athletes, teams and officials taking part in the event
* Competition structure of the event
* Available betting markets on the event.

 If you require any advice on the production of ‘betting integrity risk assessments-, the SBIU can provide further guidance upon request.

 **Action:**  Identify appropriate points of contact who will deal with different types of betting integrity incidents throughout the event

 **Notes:**  Operational points of contact may be required to deal with the following types of issues:

* Suspected event manipulation, reports of suspicious betting patterns, breaches of betting rules or sports codes, negative rumours/media coverage, etc.
* Coordinating communications activity (e.g. multi-agency press releases) relating to integrity incidents
* Managing reports of corrupt approaches made to participants.

 Senior officials should also be identified to manage higher profile incidents (e.g. where significant negative media coverage is anticipated or where an incident is serious enough to be escalated to government ministerial level).

 **Action:**  Seek understanding of the betting markets being offered on your event.

 **Notes:**  Contacts for the major betting operators who are members of the Sports Betting Integrity Forum (SBIF) can be found on the  [SBIF website (opens in new tab)](https://www.sbif.uk/)  .

 There are also a number of different online resources (just search for ‘betting market comparison-) that show which betting operators are offering markets (and the specific types of market that are offered) for different sporting events at any given time.

 **Action:**  Schedule a post-event evaluation session, involving key integrity stakeholders and covering any lessons learned, good practice ideas, etc.

 **Notes:**  This could be considered on a case-by-case basis, proportionate to the profile of the event.

 The aim of such a session would be to gather perspectives from a broad range of integrity stakeholders and identify challenges, successes, etc. Output could be used to inform a post-event evaluation report, owned by the sport, and used to support planning for future iterations of the event.

###  Actions for consideration by the Sports Betting Intelligence Unit (SBIU)

 **Action:**  Set up initial meeting to discuss support arrangements.

 **Notes:**  SBIU will outline the initial requirements for support prior to the meeting.

 Useful information to be provided by the sport will include details of any betting rules in place, education programmes and information handling arrangements.

 Logistics will be discussed and agreed including availability of key personnel, general operating procedures, communications strategies and, if appropriate, emergency cover arrangements.

 All processes can be documented using an established set of templates.

 **Action:**  Consider whether scenario-testing should be run prior to the event.

 **Notes:**  This is usually only required for high-profile major international events but, in practice, can be applied to any events, where deemed appropriate. Such testing aims to walk through potential scenarios, testing policies and operational procedures prior to the start of an event.

 **Action:**  Produce operating procedures in conjunction with the sport.

 **Notes:**  Operating procedures could include details such as the dates of coverage of any support being provided, process for managing out-of-hours reports, information-sharing processes and other day-to-day support arrangements.

 The level of support offered by SBIU will be proportionate to the potential risks and profile of the event and will be assessed on an event-by-event basis.

 **Action:**  Draft a communications policy in conjunction with the sport and other key stakeholders.

 **Notes:**  The Gambling Commission will identify a relevant colleague from within their Corporate Affairs Team as the point of contact for the sport. Event organisers will be required to identify suitable contacts within their own organisations.

 **Action:**  Identify and agree procedures for sharing information (pursuant to applicable data protection legislation).

 **Notes:**  This will be discussed in detail at the initial meeting and processes established on a case-by-case basis dependent upon the nature of the information likely to be shared and the legal status of the various stakeholders involved.

 **Action:**  Where appropriate, draft a memorandum of understanding (MoU) covering support arrangements.

 **Notes:**  This will be considered on a case-by-case basis.

 **Action:**  Notify betting operators of support arrangements for the event.

 **Notes:**  In most cases support will be managed via SBIU standard business processes.

 SBIU will notify betting operators of the support arrangements in place and request that an appropriate level of priority be applied to subsequent reporting processes.

 **Action:**  Where appropriate, engage the Council of Europe-s  [Network of National Platforms (Group of Copenhagen) (opens in new tab)](https://www.coe.int/en/web/sport/network-of-national-platforms-group-of-copenhagen-)  .

 **Notes:**  The SBIU fulfils the role of operational information hub for the UK-s National Platform. It can therefore engage with the wider ‘National Platform- network, where appropriate, to raise awareness of the event and ensure pan-European coverage of any related integrity concerns that might be identified.

 **Action:**  Where appropriate, identify suitable law enforcement representatives to provide intelligence/operational coverage for the event with regards integrity arrangements.

 **Notes:**  This will be considered on a case-by-case basis and can form part of the operating procedures.

 **Action:**  Produce integrity stakeholder contact list and circulate as appropriate.

 **Notes:**  This ensures appropriate named points of contact are identified and in the event of an integrity incident or any other matters requiring stakeholder collaboration.


* [Betting Integrity Support for Major Sporting Events](#)
* [Who are the Sports Betting Intelligence Unit?](#who-are-the-sports-betting-intelligence-unit)
* [How can the SBIU support tournament organisers?](#how-can-the-sbiu-support-tournament-organisers)
* [Appendix 1: Managing Betting Integrity](#appendix-1-managing-betting-integrity)

 [Print this guide](#)


 The aim of the Betting Integrity Programme is to protect British consumers against the risks associated with betting on events that have been manipulated for betting purposes or involve misuse of inside information related to betting markets.

 This document is aimed at those bodies the Commission might work with in respect of betting integrity. It sets out the Commission-s processes and decision making framework in the context of betting integrity, from when it first receives a piece of information through to when a case is closed.

 The Sports Betting Intelligence Unit (SBIU) is the intelligence hub of what has become known as the UK-s national platform  [1](#ref-1)  . The national platform supports collaborative working between the Commission, law enforcement agencies, betting operators and sport governing bodies (SGBs) to help address match fixing and betting integrity issues in the UK.

 This document may be revised from time to time to reflect any developments in the Commission-s approach.

##  Background - The Gambling Commission-s betting integrity decision making framework

##  SBIU Decision Making Flow Chart

##  The Commission-s approach and decision making framework

##  Sources of information

##  SBIU development and assessment

##  Decisions on how to progress the intelligence gathered

##  Issue Management Group

##  Case Management Group

##  Effective use of resources

##  Investigation (Commission or Police)

##  Investigation - Sports Governing Body

##  Information to SGBs and Operators during investigations

##  Voiding

##  Enforcement

##  SBIU dissemination

##  Sharing information with partners

##  Appendix 1 - The Gambling Commission-s betting integrity decision making framework

##  Footnotes - The Gambling Commission-s betting integrity decision making framework

---

 Last updated: 21 January 2022

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Background - The Gambling Commission-s betting integrity decision making framework

 The overall aim of the Commission, and its partners, is to reduce the likelihood of corruption and where it is discovered to cause it to end. This is best achieved by working together on a combination of prevention, disruption and sanction opportunities. It should be noted that betting in Great Britain is not restricted to sport; bets can be placed on a number of different markets such as political markets, TV talent competitions, winners or nominees of awards or novelty bets such as the colour of the Queen-s hat at a royal event. The decision making framework applies equally to each of these markets i.e. it is not restricted to sports betting.

 There are various other publications that help set out and support the Commission-s decision making processes, most notably the Licensing, Compliance and Enforcement policy statement, the  [Licence Conditions and Codes of Practice (LCCP)](/licensees-and-businesses/lccp)  , the  [SBIU Terms of Reference](/licensees-and-businesses/guide/sports-betting-intelligence-unit-terms-of-reference)  , the Betting Integrity Policy Position Paper, the Misuse of Inside Information Paper and the In Play (In-Running) Betting Paper.

 A key component of the Commission-s work on betting integrity is  [LCCP licence condition 15.1](/licensees-and-businesses/lccp/1/15)  which requires betting operators to share information on suspicious or irregular market activity with the Commission.

 Under the Gambling Act 2005 (the Act) the Commission has powers to prosecute offences of cheating and to void bets. Our powers to prosecute cheating offences apply where a person cheats at gambling or where they do anything for the purposes of enabling or assisting another to cheat at gambling.

 If the SBIU receives information that indicates potential criminality, the Betting Integrity Triage Process can be invoked.

 In such cases, relevant stakeholders will meet to discuss the available intelligence. This allows each party to understand the potential issues and agree what action can be taken and by whom in relation to both criminal and sports investigations. Appendix 1 provides an overview of the process.

 We also have powers to make an order to void individual bets accepted by, or through, the holder of a betting specific licence.

 Pursuing a criminal sanction will not always be possible and often will not be the most effective or efficient approach to take. It is difficult to prove that the result of an event has been manipulated simply by watching it; instead, a criminal case will very often rely on establishing relationships between those involved and identifying the flow of money.

 In some cases, a SGB sanction may be more appropriate and can act as a timely deterrent. This is because the standards of proof required for a civil sanction are lower than those required for a criminal sanction. SGB-s rules can be an effective control to achieve joint aims and the decision making framework is reflective of these considerations. However, each case will be considered on its merits and to inform potential action by stakeholder. Furthermore, SGB action does not rule out the possibility of a criminal charges being brought where appropriate.

 Once a piece of information is received there are broadly four key partners who can be involved in a case – the Commission, SGBs, betting operators and the police (and/or other law enforcement agencies).

 The flow chart on the next page, in general terms, sets out how a case progresses and the decision making processes. However, it should be noted that this model does not purport to capture all circumstances and the approach may vary. The flow chart will aid understanding of the structure and different sections of this document.


This flow chart, in general terms, sets out how a case progresses and the decision making processes. However, it should be noted that this model does not purport to capture all circumstances and the approach may vary. The flow chart will aid understanding of the structure and different sections of this document.


 The Commission receives information from a variety of sources, including but not limited to:

* betting operators
* bet monitoring companies
* Sport Governing bodies (SBGs)
* law enforcement
* Commission-s confidential hotline
* media and other open sources
* other regulators
* group of Copenhagen  [2](#ref-2)  .


 Having received the information, the SBIU will look to establish whether there is any potential criminal activity.

 The SBIU will also consider whether the activity falls within its terms of reference, in particular whether the activity:

* relates to a sporting event that occurred in Great Britain
* involves parties  [3](#ref-3)  based within Great Britain
* actively occurred under a Gambling Commission licence.

 The quality and detail of information provided may vary substantially. Whilst the SBIU will assess all information provided it must prioritise its use of resources. Accordingly, it may be that not enough information is available to warrant further work on an issue at that stage. However, all information is logged and if further relevant intelligence came to light, the issue could be looked at again.


Decisions on how to progress the intelligence gathered

 SBIU will assess the intelligence gathered to decide on the most appropriate course of action. At this point the following potential next steps are available for consideration:

* no further action – for example, this could be due to a legitimate explanation being identified that accounts for suspicious betting activity or insufficient information is available to proceed with a regulatory or criminal investigation. However, all information received will be logged for intelligence purposes in line with Data Protection principles and the Commission-s own policies
* if the SBIU are satisfied that there is potential criminal activity the issue will be referred to the Issue Management Group (IMG) for a decision as to how it will be progressed. Broadly speaking this establishes whether the Commission could progress a case or if it should be referred to another law enforcement agency with broader powers
* refer to a SGB – this could be where there is potentially a breach of a sport-s rule. The SGB would be best placed to identify and pursue any breaches of rules, regulations or codes of conduct
* refer to betting operator/employer – this could be where there is potentially a breach of employment terms and conditions or contracts of employment. The relevant organisation would then decide how to proceed
* refer to international stakeholders, most likely via the network of national platforms (known as the Group of Copenhagen) or via Interpol or Europol.

 Our investigatory powers, such as those under Regulation of Investigatory Powers Act 2000 (RIPA) and Proceeds of Crime Act 2002 (POCA), can only be utilised when investigating a potential crime. As such we could not use our powers once we consider an issue unsuitable for criminal investigation.


 Cases are progressed to IMG via an Incident Referral Form (IRF). Included within an IRF is a synopses of is the key issues, including any risks or breaches of licencing objectives/ or Social Responsibility Code and a reference to any alleged offences under the Gambling Act 2005 (or other legislation).

 The purpose of the IMG is to ensure that emerging issues or trends are escalated appropriately within the Commission.

 The potential outcomes from IMG can include:

* further intelligence development
* referral to SGBs or betting operators/employers for disruptive (including disciplinary) action
* escalate to the Case Management Group (CMG).


 The purpose of the CMG is to ensure that the Commission responds appropriately to key issues, which due to their scale, complexity or novelty are of strategic significance to the Commission. The CMG-s role is to identify and manage emergent risks and provide clarity, support and direction to Commission casework.

 Escalated IRFs will be discussed at the fortnightly CMG. However, there are arrangements in place if there are time critical issues that require more immediate action. An allocated Case Manager will be in attendance for direction regarding their allocated IRFs. CMG will ensure that the Case Manager has a steer on the focus of investigation, risk priorities, resource requirements and communications.


An underlying aim of this approach is to ensure that criminal activity ceases. This means that the partners involved can use their resources in the most effective and efficient way possible to achieve an effective combination of prevention, disruption and sanction.


The Commission-s broad policy framework in relation to the investigation and prosecution of offences under the Act, including the Commission-s powers is set out in the Commission-s document  [Licensing, compliance and enforcement policy statement (June 2017)](/policy/licensing-compliance-and-enforcement-under-the-gambling-act-2005)  . Investigations in respect of betting integrity can be taken individually by the police or Commission or the lead can be taken by one and supported by the other as outlined in the Triage Process (Appendix 1). This arrangement can change during the course of a case depending on developments.


Where or when appropriate, some cases may be referred to a SGB to consider potential breaches of sports rules. The Commission will support SGBs where appropriate and in line with the SBIU ToRs.


Information to SGBs and Operators during investigations

The Commission may, where appropriate, share information with SGBs and betting operators during investigations. It may be feasible for a SGB to prepare or progress disciplinary cases under sports rules at the same time as a criminal one and it may be appropriate for betting operators to take appropriate action in their own right. These should be the subject of joint discussions as part of the Triage Process to ensure neither the criminal nor the disciplinary action could negatively impact on the other.


 The Commission has powers to void individual bets either as a disruptive end in itself or as a stage on the way to a prosecution. More detail about this power is set out in section 5.49 of Licensing, compliance and enforcement policy statement (June 2017).

 Where the Commission exercises this power, any contract or other arrangement relating to the bet will be void, and any money paid in relation to the bet must be returned to the person who paid it. The power to void a bet only applies to the parties to a specific bet; it does not apply to all bets placed on an event.

 In some circumstances the Commission would provide information to operators to support any action they may take relating to suspension or non-payment of bets that are deemed to be unfair.


 Following an investigation the Commission may proceed to prosecution, issue a caution or decide to take no further action. Information concerning the framework for deciding how to proceed following an investigation is set out in section 6.8 to 6.11 of Licensing, Compliance and Enforcement policy statement (June 2017).

 The Commission may take action if failings by a licensee are found to be a factor and would deal with such cases under our regulatory powers.

 Whilst the Commission can take prosecutions itself, often such court cases will be led by the relevant prosecuting authority, particularly where a police force has either led an investigation or been involved in one. Whether or not to prosecute will often be a decision for them in the first instance. If the Crown Prosecution Service, (or Procurator Fiscal if a case is being investigated by Police Scotland) does not think it appropriate to prosecute, the Commission is unlikely to proceed independently with a criminal investigation unless there are exceptional circumstances (for example, the need to set a legal precedent).


Following the outcome of a case, including where there is no further action, the SBIU may disseminate information to other parties. The information that can be shared will be dependent on the case and any legal restrictions which may apply. The SBIU would also welcome any relevant information from partners on the completion of any action taken by them regarding lessons learnt or emerging themes, to feed back into the wider strategic intelligence picture.


 The Commission will generally look to share information with partners where it is considered appropriate to do so. Generally, and particularly for non-law enforcement partners, this will be in a summarised format. The Commission is usually more able to share data with law enforcement agencies for the purpose of criminal investigations.

 Section 30  [4](#ref-4)  and Schedule 6  [5](#ref-5)  of the Act provide a limited list of third parties with whom the Commission may provide information received by it in the course of its duties. However, the Commission may choose to provide information to parties not listed on Schedule 6 where this is considered appropriate in furtherance of the licensing objectives and is not prohibited by any statutory provision or legal principle. Where necessary, information provided by the Commission to third parties may be subject to conditions, including the requirement to apply adequate information handling procedures. The Commission would not be able to pass data to those that do not have appropriate information handling procedures.

 All disclosures of personal data made by the Commission will be subject to the requirements of the Human Rights Act 1998 and the Data Protection Act 2018 and  [General Data Protection Regulation (GDPR) (opens in a new tab)](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/)  .


Footnotes - The Gambling Commission-s betting integrity decision making framework

 1  As defined in Article 13 of the Council of Europe-s  [Convention on the Manipulation of Sports Competitions (opens in a new tab)](https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000016801cdd7e )

 2  The Council of Europe-s network of national platforms

 3  Examples of ‘Parties- could include participants as defined by a sports governing body, employees of a betting operator, employees of a TV or telecoms company etc

 4  [Section 30, Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/30)

 5  [Section 6, Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/schedule/6)


* [The Gambling Commission-s betting integrity decision making framework](#)
* [Background](#background-the-gambling-commissions-betting-integrity-decision-making)
* [SBIU Decision Making Flow Chart](#sbiu-decision-making-flow-chart)
* [The Commission-s approach and decision making framework](#the-commissions-approach-and-decision-making-framework)
* [Appendix 1 - The Gambling Commission-s betting integrity decision making framework](#appendix-1-the-gambling-commissions-betting-integrity-decision-making)
* [Footnotes](#footnotes-the-gambling-commissions-betting-integrity-decision-making)

 [Print this guide](#)


 In addition to some small lotteries, which are ‘exempt- from the requirement to hold a licence, the Act permits licensed or registered non-commercial societies and local authorities to promote lotteries. It is the view of the Commission that the intention is to allow noncommercial societies and local authorities to use a lottery as a means of raising funds to support their purposes.

 The Act also allows those societies and local authorities to appoint a person - who is not a member, officer or employee of the society or local authority - as an ELM to make the arrangements for the lottery on their behalf. Where arrangements for the lottery are made by an ELM on behalf of a society or local authority, both the ELM and the society or local authority promote the lottery (  [Section 252(4) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252)  ). The intention of the provision is relatively limited in scope; it is designed to do nothing more than allow a society or local authority to outsource the running of its lottery or a part of its lottery to a third party.

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 Lottery proceeds - Advice note April 2013 (Updated July 2020)](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020)  [Next page
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 [Section 254(1) of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254)  defines the proceeds of a lottery as ‘the aggregate of amounts paid in respect of the purchase of lottery tickets- (the total amount paid for tickets before any deductions). The Act also specifies the way in which the proceeds of a lottery must be distributed, as follows under section 99(2):

###  99 Mandatory conditions of lottery operating licence

 **(2).**  The first requirement, is that at least 20% of the proceeds of any lottery promoted in reliance on the licence are applied-
 **(a)**  in the case of a licence issued to a non-commercial society, to a purpose for which the promoting society is conducted
 **(b)**  in the case of a licence issued to a local authority, for a purpose for which the authority has power to incur expenditure.

 The Act describes the proportion of the proceeds remaining after prizes and expenses have been deducted as the ‘profits- of the lottery (  [Section 254(2) of the Gambling Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254)  ).

 The Commission-s view is that the intention of the requirement to apply ‘at least- 20% of the proceeds to the purposes of the promoting society is to maintain the fundamental principle set out in the Act for society and local authority lotteries that they are only permitted as a mechanism to enable fundraising for purposes other than that of private or commercial gain. Society and local authority lottery operators are reminded that 20% is the minimum amount of proceeds from each lottery that must be applied to their purposes. In the Commission-s view the ‘purposes- of a society are the aims and objectives for which the society primarily exists. The ‘profits- of a lottery cannot be used for any other purpose.

 Lottery promoters should also take note of the licensing objective in the Act that requires all gambling to be conducted in a ‘fair and open way-. This has specific relevance to society or local authority lotteries who advertise a specific percentage return to their purposes from each lottery on tickets or in marketing material. Societies and local authorities must ensure that the advertised percentage rate of return is met if they are to avoid acting in a manner inconsistent with the second licensing objective.

 The level of expenses and prizes allocated from the proceeds must not be such as to reduce the profits to below 20%. In addition to profits the proceeds can only be used to:

* provide prizes
* pay expenses ‘reasonably incurred- organising the lottery.

 In circumstances where the proceeds are insufficient to pay the total expenses and the cost of providing prizes in the lottery, the society or local authority must still ensure that 20% of the proceeds are applied to its purposes. In such cases the society or local authority may have to pay the expenses of the lottery and/or the cost of prizes from other (non-lottery) sources of income such as their financial reserves and the lottery may result in an overall financial loss for the promoting society or local authority.  [1](#1)

 In ensuring all lotteries are conducted in a ‘fair and open way-, societies are required to publish each year the proportion of all lottery proceeds (as a percentage) that were returned in the previous calendar year to the purposes of the society (or, in the case of local authorities, applied to purposes for which the authority has power to incur expenditure).  [2](#2)  The purpose of this is to provide the consumer with information to enable them to see how their money is spent and make decisions about where they spend it.

 Societies and local authorities should calculate the proportion of lottery proceeds returned as profit to the good cause as follows: total profit (amount returned to good cause) in a calendar year, divided by total proceeds (ticket sales) in a calendar year, multiplied by 100 to provide a percentage figure.

 The percentage must only take account of money related to the lottery proceeds (money collected from ticket sales), it must not include funds raised through other activities of the good cause, charity or local authority.

 There is no prescribed way of making this information available, although it should be in a manner that is easy for the consumer to find and understand through the most commonly used medium for that society. Many societies may decide to add the information to the lottery pages of their website, to their annual report or in their annual membership/subscriber newsletter. They can also add the information to their current lottery campaign material. There is no restriction on societies and local authorities providing supporting information about the importance of the work carried out via the lotteries they promote.

 Social responsibility codes attached to all lottery operating licences include a requirement to take account of the Commission-s guidance on providing information to lottery players about how proceeds are used and the likelihood of winning a prize and how those prizes are allocated. This information must be available prior to participating in a lottery.

 Further information about these requirements can be found in the Commission-s guidance:  [Information to lottery players: proceeds and prizes](/licensees-and-businesses/guide/information-to-lottery-players-proceeds-and-prizes)  .

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The expenses of a lottery - lottery proceeds

 The Act defines the expenses of a lottery as ‘costs reasonably incurred organising the lottery-. It is the responsibility of the promoting society or local authority to ensure that when making the arrangements for a lottery, that any expenses have been reasonably incurred. The expenses of a lottery are the costs incurred organising the lottery and this may include expenditure such as the salaries of those organising the lottery, the cost of selling or supplying lottery tickets, printing and distributing tickets and marketing material or paying any fee to an ELM or other service provider that has been rightly incurred in the course of organising the lottery (or part of the lottery) for the society or local authority. The expenses of a lottery do not include any expenditure relating to any other fundraising activity not directly connected to organising the lottery, even if that fundraising activity is undertaken in conjunction with the promotion of a lottery.

 Where an ELM is employed to make the arrangements for all or part of the lottery, including paying prizes and expenses, the society or local authority is equally responsible with the ELM  [3](#3)  for the promotion of the lottery. That includes ensuring that all expenses are ‘reasonably incurred- and that a minimum of 20% of the proceeds are returned to the purposes of the promoting society or to the local authority. It is also important that the promoters of the lottery ensure that the lottery is conducted fairly and openly and that consumers are not misled as to the proportion of the ticket price that is applied to the purposes of the society.

 When apportioning the expenses of a society or local authority lottery and recording how the proceeds collected have been used to pay the expenses, the Commission-s view is that it is reasonable for some of the ‘start up- costs from the proceeds genuinely attributable to the lottery as a whole rather than those related to a specific lottery to be spread over a number of lotteries. These may include, for example, the marketing and advertising or the initial costs of recruiting members to a new lottery. Any expenses that are spread over a number of lotteries must be expenditure directly attributable to those lotteries and the Commission would expect any expenses being treated in this way to be spread over a reasonable and time limited period. The Commission also considers that it is not unlawful for a promoter to use income from sources other than lottery proceeds to fund the start-up costs or other costs of a lottery.

 Irrespective of how a lottery operator decides to spread the costs of a lottery the priority must be to ensure that a minimum of 20% of the proceeds of each individual lottery are applied to the purposes of the promoting society or local authority.

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 ‘Proceeds- and ‘profits- of a lottery](/licensees-and-businesses/guide/page/proceeds-and-profits-of-a-lottery)  [Next page
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The Commission requires all lottery promoters to comply with the licensing objectives and treats any breach of the licence conditions very seriously. It expects all licensed lottery operators to put in place arrangements to make sure that the proceeds of each lottery are distributed in a lawful and compliant way. That includes ensuring that a minimum of 20% of the proceeds of each lottery promoted are applied to the purposes of the society or local authority and that any expenses are reasonably incurred. Misuse of the ‘profits- of a lottery may constitute a criminal offence  [4](#4)  . In circumstances where a breach of the Act and/or the licence conditions occurs the Commission will consider what regulatory or other action it needs to take. That could include a review of the operating licence of the promoting society, local authority and ELM and following that review the Commission has the power to impose sanctions such as a formal warning, additional licence conditions, a financial penalty or suspension or revocation of an operating licence.


 1  Lottery operators will wish to take note of Charity Commission advice on how charity law applies to fundraising:  [Charities and Fundraising (opens in a new tab)](https://www.gov.uk/government/publications/charities-and-fundraising-cc20)

 2  Social Responsibility code 4.3.1

 3  [Section 252(4) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252)

 4  [Section 260 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/260)

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 Lottery submissions - lottery proceeds](/licensees-and-businesses/guide/page/lottery-submissions-lottery-proceeds)

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