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Customer interaction guidance for remote gambling operators

Customer interaction describes how you identify people who may be experiencing, or at risk of developing, problems with their gambling, and how you interact with them to offer help or support.

Identifying at-risk customers 

You need to know:

  • the indicators of harm relevant to online gambling
  • how to spot when those indicators should trigger an interaction.

 You need to put together what you know about the customer, with the indicators of harm, to decide whether you need to interact. More information can mean better decisions. 

Some indicators of harm, such as high staking behaviour, can look similar to VIP and high-value customer activity. Even if you think the customer can afford it, they may still be at-risk. Your regular contact with your VIPs means you have many opportunities to get to know them well. 

What we expect you to do


  • Use a range of indicators relevant to your business. Do not rely on financial indicators alone. You should use realistic trigger points for when usual becomes unusual, and remember that not every customer will trigger every indicator.
  • Monitor customer activity, so that you can interact early, and quickly. Invest in systems and staff to manage your process effectively.
  • Make sure your process keeps pace with any increase in demand – through growth, mergers or other internal changes.
  • Train your staff to know their roles and responsibilities, and be supported and able to act when they spot harmful behaviour. This includes your VIP teams.
  • Your customers should not be at more risk because they gamble overnight or out of hours. You need to think about how you can protect these customers, and also new customers.
  • We expect you to take social responsibility seriously for all customers, including VIPs, and not let commercial considerations override customer protection. This means your VIP customers get the same level of protection as your other customers.

Using the right indicators for your business

Change compared with previous gambling activity is a general trigger that you could use for customer interaction. Building up a profile of your customers can help you spot changes in their behaviour. 

You should use a range of indicators. The PWC remote gambling research identified some account and play indicators, but they are not a definitive list. Your list could include:

  • Time and spend indicators: amount and frequency of time and deposits, time of day, large losses.
  • Account indicators: cancelled withdrawals, failed deposits, multiple payment methods.
  • Use of responsible gambling tools: changing deposit limits, trying to stop reversing withdrawals, previous self-exclusions or previous customer interactions.
  • Customer contact: information or hints from customers, frequent complaints, requests for bonuses following losses, or signs of distress.
  • Play indicators: chasing losses, erratic betting patterns and product choice.
  • A ‘big win’: research shows high staking following a win could hide or even lead to harmful behaviour.

If you use global thresholds, these should be realistic. To put this into context, you could look at the Office of National Statistics publications on levels of household income, or assess what is ‘normal’ for most of your customers. 

For new customers or higher risk groups you could use lower thresholds for interaction, or other tools such as compulsory deposit limits. 

Spotting harmful behaviour  

How you monitor activity depends on your business. For some very small operators, manual monitoring may work. Larger operators with more active customers will need comprehensive systems, which could include a mix of automated and manual processes. Options for spotting harmful behaviour include:

  • in-play real time monitoring to identify harmful behaviour as it occurs
  • daily reports on activity
  • chat-room monitoring and moderation.

The right information can mean better and quicker decisions. You should aim to integrate your systems so that staff have a more complete picture of the customer’s activity, and this includes records of previous customer interactions. 

Unmonitored overnight gambling carries an increased risk. Remote gambling research found that the highest risk customers were much more likely to gamble overnight than non-problem gamblers. Some operators have full 24-hour dedicated responsible gambling monitoring and support, so that customers have the same level of protection overnight as during the day. Another option could be more training and extra responsibilities for customer service staff or chat hosts to provide that support. 

Because VIP customers can also be at risk of harm, you should carry out a responsible gambling check when upgrading a customer to VIP status, and keep this under review. You can also use these opportunities to carry out checks for AML. This could also help you to support customers who have had major wins. 

Questions to think about

  • Are your indicators relevant to your products and customers?
  • Do you rely too much on financial indicators like deposit levels or losses?
  • How do you decide the right level of your thresholds?  Do you set your thresholds based on the staff you have to manage the workload, or do you think about what is right for your customers?
  • Do you take into account all relevant information, and act quickly? 
  • How could you assess the risk level of new customers?  What can you find out about your customers?  What protections could you put in place until you can find out enough about your customers?
  • Can your monitoring process keep up with demand?
  • Do you offer the same level of player protection for all your customers, no matter how long they have been a customer, what time of day they play, or whether they are VIPs?

Next: Guidance on interacting with customers