have any hosting in the UK; you do not market or advertise to UK residents; none of your team
resides in the UK; and you do not accept any financial or Bitcoin transactions from UK residents. In
relation to your final point, you state that: ‘bitcoin transactions are anonymous and we have no idea
where they come from. As such, we cannot simply turn the switch off from accepting UK-residents'
deposits as we do not know they are UK residents.’
I have below addressed the points you have raised in the hope that this will resolve matters.
You should note that section 33 of the Gambling Act 2005, which makes it a criminal offence to
provide facilities for gambling without an operating licence authorising that activity, applies if remote
gambling equipment is located in Great Britain, or if the facilities are capable of being used in Great
Britain. Consequently, the fact that you do not have any hosting in the UK, do not market or advertise
to UK residents, and that your team do not reside in the UK, does not mean that a licence is not
required.
In response to the final point, it is our view that even if bitcoin transactions are completely anonymous
it is still possible for you to, and you should, implement means to identify if a player using bitcoin is
playing from a UK registered IP address and restrict such access based on the user’s IP address.
We note that you state that you do not accept any financial or bitcoin transactions from UK residents
which indicates to us that you are already able to identify the location of customers from their IP
addresses.
If gambling sites are successfully blocked to those in Great Britain trying to access them, it will
amount to ceasing activity. However, we are aware that IP blocking technology is by no means fool
proof and may be circumvented. As a result IP address blocking alone may not be sufficient to
ensure that consumers in Great Britain are blocked from gambling on the website. To reassure
yourself that you are not at risk of committing an offence, even if you implement IP blocking, you may
wish to consider what other mechanisms you could use in order to prevent the use of your facilities to
gamble by consumers in Great Britain, for example by asking for the country of location at customer
registration.
Details of how you can apply for an operting licence can be found on our website. In answer to your
question, we not accept payment in bitcoin.
If you take immediate steps to remedy the situation, this may avoid the need for the Commission to
take the matter further.
Victoria Square House
Victoria Square
Birmingham B2 4BP
T 0121 230 6666
F 0121 230 6720
www.gamblingcommission.gov.uk
Should you have any queries in relation to the content of this letter please contact me via email at
[email protected] or by telephone on 0121 230 6686.