PUBLICATION DATE: Thursday 19th March 2020






On 16 March, we called on the gambling industry to stop using C19 to exploit vulnerable people and to stop abdicating responsibility for white labels and affiliates. We also called on the Betting and Gaming Council (BGC) and the Gambling Commission (GC) to take immediate action on the white label market. Following from this, I would like to offer my own personal and ongoing experiences of the concerning practices around white labels and affiliates.[i]

In the case we highlighted – which marketed an online casino as C19 safe – I have had personal experiences with the licence holder in question, that uses a white label.  Most non-industry people reading this won’t have ever heard of the company, Aspire Global Communications (AG).  Neither had I, until I embarked upon my journey of discovery a couple of years back, when I decided to put my detective skills to good use and find out who the 75+ online accounts I had used actually were with.  When you’re in the haze of a disordered mindset, it matters not who you gamble with.

The reason I had so many accounts was because after each ‘payday’ gambling binge, I’d write the same old email at 3am telling the company that I couldn’t control my gambling and wished to be permanently self-excluded.  So, when the next moment came along, perhaps after a few months of being ‘responsible’ and trying my best not to gamble, I’d eventually succumb and simply type the words, ‘online casino’ into the search engine.

One day, it was the turn of AG to accept my disordered behaviour and make a tidy £1800 from me within the space of a couple of days.  ‘Karamba’ was their site and in the blink of an eye, my pay was gone.  The email was sent and off I went to face a set of night shifts which began a further painful and long month ahead, riding my moped through the dark countryside of Dorset in bone-crunching temperatures as I couldn’t afford to put fuel in my car.  Because at that time I took full personal responsibility for my gambling, I never once wrote to a gambling company to ask for my money back.  Why would I?  It was all my fault after all.

But looking back through the 1000s of pages of emails and Subject Access Request (SAR) material I had received, my sense of shame and guilt around the fact that my own personal responsibility and my own willpower was never enough, began to subside.  I saw that some 25-35% of my accounts were with the same licence holders – after self-excluding from one online gambling site, that same license holder let me sign up with a different online site, they also owned.

Another trend emerged also.  This being the bombardment of emails and texts I had been receiving daily and again, whilst in the disordered mindset, I never even noticed.  I wondered whether there was a correlation between my disordered gambling episodes and receiving the marketing.  There were most definitely some trends – for example, around anniversaries of particularly heavy and disordered gambling there was an obvious increase in the bombardment.

Looking into the addresses on the emails then became another fascinating part of my investigation.  It became impossible to track down the actual sources of a lot of these emails.  Often, I would be metaphorically taken to Miami or Florida, but I decided to focus on the simple source of the companies behind the affiliates and white labels.  AG were one of a number of companies that had sent me texts and emails after I had self-excluded.  Knowing that each separate email and text was an individual breach of the licensing conditions, I asked AG to take account of their failings.  The company completely blanked me.  I even had to talk to a director on the phone to get my SAR dealt with, this is how bad they were.  I put the case to bed because what else could I do?  The GC had the evidence and weren’t interested, as is the norm, unless the case hits the papers and has resulted in criminality.

But then came a fine from Sweden against AG for failings.  On a whim, I decided to email them again to see if this news might have changed their stance.  Sure enough, within a few weeks they offered me my deposits of £1800 back, so long as I signed the settlement agreement they sent to me.  I debated the issue with my partner and we collectively decided to take the money and finally have an enjoyable summer, together with my daughter, who I had deprived of holidays until now.

A month passes by and a text message appears via an affiliate, for, none other than AG.  This time I spoke to a top boss.  He told me AG had learned from my case and would ensure such practices would end.  Yet, just three days ago I received another text message linking me to site operated by AG.  I also received one a few weeks back.  As per the first time, the company have blanked me.  Then on Wednesday, I came across the distasteful email on C19, which was not only sent on behalf of AG, it was also sent to a self-excluded customer.

On behalf of Gamvisory Group, I again call upon the GC and the BGC to take immediate action on the issue of white labels and to rout out the affiliates that are causing the industry and moreover disordered gamblers, immeasurable harm.  Thus far, we have been ignored.



[i] For those who don’t know, some UK-operating licence holders use ‘white label’ businesses to be able to market themselves here in the UK and benefit from UK custom without having to go through the same licensing process of the UK-operating company that they are aligned with. These companies do not need gambling licenses, and the regulations make license holders who use them responsible for what they do.  They are listed accordingly on the Gambling Commission’s website:

Affiliates are used by many UK-licenced companies to seek out new custom and generate more revenue from existing customers.  This is done by marketing and other means, with the affiliate normally taking a percentage of the ‘yield’ created by the custom, or via one-off fees.