On 3 July 2025, the Gambling Commission (the Commission) announced that it had fined Taichi Tech Ltd (trading as Fafabet) £170,000 for regulatory failings, primarily in relation to the use of unfair terms and conditions (T&Cs). The Commission highlighted a bonus term in a casino promotion which stated “Fafabet has the right at its own discretion to close accounts or forfeit winnings”. The Commission concluded that this term was unfair and non-transparent. Failures were also identified in its AML and customer interaction procedures (for example, high-velocity spend with limited KYC; insufficient follow-up where markers of harm persisted).

Why does this matter?

Operators must ensure their terms and practices are fair, transparent and compliant with consumer protection law under the Licence Conditions and Codes of Practice (LCCP) Condition 7.1.1 and related guidance; the Consumer Rights Act 2015 (CRA 2015) standard on transparency and fairness applies.

Practical steps for operators:

1) Review your terms and conditions immediately. Remove discretionary “catch-all” clauses. Eliminate any terms allowing an operator, at its sole discretion and without clear justification, to close accounts, void or withhold winnings, or alter promotions once a player has opted in. This applies even if such action has not been taken; merely having defective terms is sufficient. Such terms are at high risk of being unfair under the CRA 2015 and contrary to LCCP 7.1.1.

2) Be specific and transparent in bonus terms: If operators must restrict, suspend, or void a bonus, objective, narrow, and evidenced grounds should be set (for example, proven fraud or regulatory requirements) and explain those grounds and the process clearly in the T&Cs.

3) Align with the CRA 2015 and CMA guidance: Review terms against the CMA’s unfair terms guidance – see CMA37 and remove any imbalance of rights, ambiguity, or surprise terms; ensure plain, prominent drafting and accessibility.

4) Promotions: Do not change or withdraw a promotion after a customer has opted in, save for exceptional, clearly defined reasons, which are stated up-front (for example, to prevent fraud or illegality).

5) Customer interaction and AML controls: Where high-velocity or high-risk spend occurs with limited customer information, escalate KYC/SoF/SoW appropriately; if markers of harm persist or communications go unacknowledged, apply further interaction or interventions in line with LCCP customer-interaction requirements.

6) Governance and assurance: Consider periodic external audits of T&Cs, AML and safer-gambling frameworks, particularly following material changes or regulatory updates (including new Gambling Commission enforcement action).

If you’re a gambling operator and have questions or concerns about your T&Cs, please contact Richard Williams.