On 2 October, CMS Law reported that, following its consultation in relation to high value customers (also known as VIP), the Gambling Commission has now published new industry guidance as to how operators should treat them.  It is said that its intention is for this guidance to “clean up the malpractice” it has seen within VIP schemes and is offered as a “last chance” for operators to prove that such schemes can be operated appropriately.  If operators depart from the guidance, they should be prepared to justify their alternative approach. If the minimum expectations cannot be met, the Commission states that VIP programmes should not be in place.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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