All Bookmakers must make sure that the Card payment machine they are using blocks accepting Credit Card payments. As it is their responsibility not to accept payment for a bet placed with them from a Credit Card.

Best Practice advise for use of Debit Card machines.

Make sure your Debit Card payment provider is fully aware of the sector you work in i.e., the gambling industry, and that your Debit Card payment provider is happy for you to be accepting payment from the public making payment for gambling bets using their Debit Cards.

Have an agreement that your Debit Card payment provider can block anyone trying to make payment for a bet using a Credit Card. If you are using a Debit Card payment provider who does not have this facility in place you are liable for the consequences of taking a bet paid for by a Credit Card. As the use of phone wallets on peoples phones has become much more used to pay for transactions. This makes the risk of someone placing a bet using a Credit Card a much greater risk. As you will be unaware of type of card as you will not be able to see a card. If your Debit Card provider does not specialise in this sector you are at risk of been caught processing a bet using a Credit Card and will face prosecution for this from the Gambling Commission.

We would advise that no bookmaker lends his Debit Card payment machine to another bookmaker to be able to use at any time. On a day a bookmaker is not working, and another bookmaker asks can he use the other bookmakers Debit Card payment machine to be able to accept Debit Card payments we strongly advise that this practice does not happen.

Reasons for not sharing Debit Card machines.

  1. It breaches your contract with your Debit Card machine provider.

  2. The person placing a bet using the debit card will see a different name than that of the person he placed bet with and can report transaction as fraudulent.

  3. Debit Card provider will refund all transactions to clients who placed bets.

  4. The Debit Card provider will probably remove the machine from bookmaker for breaching their contract with them.

  5. With so few Debit Card providers willing to accept betting transaction you risk whole sector being black listed for breaching contract with your Debit Card provider for lending to another bookmaker.

If anyone needs to apply for a Debit Card provider, we recommend AIBMS. AIBMS specialise in betting transactions, so they have a detailed knowledge of the betting sector.

If anyone requires anymore information or advice they can contact the office and request more information.

Update 02/11/2023 - AML & Bookmakers using Debit Card Machines, please read in conjunction with the notice 1st August (above).

All operators are required to uphold the licensing objectives under Part One of the Gambling Act 2005 which includes, ‘keeping crime out of gambling’. Licence Condition 12.1.1. of The Licence Conditions and Codes of Practice states that:

  1. ‘Licensees must conduct an assessment of the risks of their business being used for money laundering and terrorist financing. Such risk assessment must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic or any other material changes, and in any event reviewed at least annually.
  2. Following completion of and having regard to the risk assessment, and any review of the assessment, licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing.
  3. Licensees must ensure that such policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time’.

Licence Condition 5 also applies here which states that:

  1. ‘Licensees, as part of their internal controls and financial accounting systems, must implement appropriate policies and procedures concerning the usage of cash and cash equivalents (eg bankers drafts, cheques and debit cards and digital currencies) by customers, designed to minimise the risk of crimes such as money laundering, to avoid the giving of illicit credit to customers and to provide assurance that gambling activities are being conducted in a manner which promotes the licensing objectives.

Licensees must ensure that such policies and procedures are implemented effectively, kept under review, and revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time’.