Tim Miller Q&A: Public to private, a sense of freedom and social media enforcement

Can you expand on your approach to helping clients tackle illegal gambling operators? 

This will involve looking at both the supply and the demand side of the illegal market. 

On supply, I will be working with tech companies like Gaming Compliance International, to provide governments and regulators with better tools and better intelligence to properly understand and track the transactions that sit behind illegal gambling. I'll also be supporting the type of regulatory partnerships that I was known for building at the Gambling Commission by bringing together regulators and other stakeholders so that a joined-up approach can be taken to addressing the supply of illegal gambling. 

On demand, I will be drawing upon my experience of delivering much of the UK's Gambling White Paper to support reforms in other jurisdictions.  

Successful regulatory systems cannot be built on simplistic, blunt approaches like ever-increasing tax hikes or blanket prohibitions. 

Tomorrow’s best-in-class regulation will be evidence-led, outcomes-focused and technology-driven. My work will be about facilitating regulatory approaches that give consumers strong incentives to remain in the licensed market, where protections are real and enforceable. 

In your expert opinion, what are the biggest regulatory challenges in today's landscape? 

The regulatory challenges vary from country to country, but the one that will unite all jurisdictions is the threat of the illegal market. No legitimate, licensed market is safe from being targeted by unscrupulous, criminal operators. In the same way that global authorities come together to tackle trans-national crimes like human trafficking, all of those with an interest in ensuring safe, fair and crime-free gambling markets need to collaborate on this international challenge. 

It impacts all of us - it makes enforcement more challenging for regulators; it steals revenue from licensed operators; it harms vulnerable consumers; and it places a further burden on hardworking taxpayers. This was something that I was especially passionate about addressing in my last year at the Gambling Commission and is something that I will continue to drive forward through GamReg Consulting. 

 What do you see as some of the benefits of going from the public sector to the private sector? 

I have always been a public servant, so I didn't completely know what to expect when I left the public sector. Probably the biggest benefit I have felt so far is the sense of freedom. When I was at the Commission, I always tried to be as open and candid as possible when talking to stakeholders or giving a speech or media interview.  

But the reality is, when you are part of a public body, even one at arm’s length from government, there will always be a limit to what you can say. You may not be a political appointee, but you can't escape from the fact that you work in a highly political environment. Now, when I speak publicly in my new role, I'll only have to worry about what my daughters think! 

What are your thoughts on the UK Department for Culture, Media and Sport's consultation regarding the introduction of a ban on sponsorships by unlicensed gambling operators? 

The proposed ban is really welcomed. It can't be right that our domestic football teams are used as a shop window for companies that do not show a commitment to the regulatory standards we expect here in the UK, some of which have shown questionable business practices across a number of jurisdictions. 

Coming from a decade of working in the Gambling Commission, how would you respond to sceptics who believe you may be able to leverage your regulatory background to help clients find ways around the system? 

GamReg Consulting will be working with regulators, governments and those who support the delivery of effective regulatory frameworks. We won't be providing compliance advice to operators.  
 
I will, however, be unashamedly leveraging my regulatory background to help drive regulatory reforms that protect consumers, command industry confidence and work in the real world. One of my strengths after 25 years as a regulator is the independent voice that I bring. I will ensure that I only work with those who will allow me to protect that independent perspective. 

The press release mentions addressing the risks posed by illegal gambling operators, but also mentions supporting governments and regulators; how do you plan on toeing the line between clients' interests and upholding responsible gaming protections? 

For me, there is no line to toe. If you don't support upholding responsible gaming protections, then GamReg Consulting won't work with you. My clients will be those that are building regulatory frameworks or supporting the delivery of them. My clients’ interests, and the interests of GamReg Consulting, will always be aligned with effective, proportionate and evidence-based regulatory approaches. 

Too many people present regulation as a binary choice that requires either an overly restrictive approach to ensure consumer protection or an overly permissive approach to deliver commercial success. I don't consider either extreme is desirable, or effective. I will be working with jurisdictions around the world to deliver practical, credible approaches that keep players safe while supporting a compelling consumer offer.

GamReg Consulting is just starting up; what are your plans for the next 12 months? 

I'm already working with some key partners in the US, and this will likely expand to other jurisdictions pretty rapidly. I'm delighted to have been asked to deliver the keynote at Regulating the Game in Sydney next year and will be part of the judging panel for their regulatory awards. That will be a great opportunity to work with other regulators from around the world and from other sectors like financial services. 

I will also continue working to tackle the risks from the illegal market. This will include looking at how governments and regulators can make better use of technology to strengthen their intelligence and enforcement functions.  
 
I'm planning to continue putting pressure on social media companies to take a more proactive role in reducing the visibility of illegal sites on their platforms;  whether that's through supporting governments to develop new legislative obligations on those platforms or by working directly with the platforms themselves.