Tim Miller spent ten years at the UK’s Gambling Commission, leading delivery of the 2023 white paper reforms – from age verification and game design to marketing controls and financial risk checks – and overseeing the launch of the Gambling Survey for Great Britain (GSGB).
His proudest achievement is the National Strategy to Reduce Gambling Harms, which brought the financial services sector into harm prevention and helped prompt challenger banks such as Starling to introduce gambling blocks.
But in June he announced his exit. It was completed last month, and he now runs GamReg Consulting, whose early clients include Gaming Compliance International (GCI), the provider of transaction and market monitoring tools to regulators, and Spectrum Gaming Group. Miller says the reaction since launching, including at G2E in Las Vegas recently, has been “absolutely fantastic”.
Miller’s departure came at a sensitive time for the Commission. Chief executive Andrew Rhodes had stepped down at the end of April, financial risk assessments (FRAs) were confirmed in July and full implementation is still to come.
Ready for the next challenge
Miller insists nothing about the Commission’s direction pushed him out. “I wasn’t looking to escape the Commission, I was just ready for the next challenge.”
Although his name was mentioned as a possible successor to Rhodes, he never considered the role. “If you’re going to do that job, you need to be willing to commit for at least three years or more, and I’d been clear for some time that that wasn’t what I wanted to do,” he says.
He does not read too much into the recent run of senior departures, suggesting “it is just coincidental timing”. The Commission, he points out, is made up of more than 300 people. “As important as individual leaders are, they’re not more important than the whole.”
The black market is not the regulator’s alone
The biggest challenge facing the Commission, Miller says, is the illegal market – and unrealistic expectations of a regulator’s reach. He likens illegal gambling to other organised criminal networks such as the international drugs trade, where “no one would expect a fairly small regulator in Birmingham to be responsible for cracking that by itself”.
Law enforcement, governments and tech companies must play their part too. “If people think a gambling regulator will defeat the illegal market by itself, we’re destined to fail.”
He also defends the GSGB, which parts of the industry have criticised for overstating gambling participation and harm. Some of those critics, he says, “have been notably silent” on the limitations of the Health Survey for England, which they tend to favour for its lower headline rate of problem gambling – even though it is the Health Survey that points to a rising rate, while the GSGB suggests a broadly stable one. “If anybody suggests there’s a single survey or a single piece of data that gives you the absolute definitive picture on an issue, then frankly, they’re kidding you,” Miller says.
FRAs became a lightning rod
No white paper measure drew more industry pushback than FRAs. Miller sees two reasons. The first was branding: opponents labelled them affordability checks, “which are a very different beast to financial risk assessments”. He is no fan of affordability checks himself. “For one thing, I think they’d be quite difficult to achieve.”
The second was money. The pilot, he says, “very clearly identified a cohort of people at risk of potentially quite significant harm who weren’t being picked up by any other tools or methods” – customers who were often generating significant revenue. “Once you’ve got data that identifies those people, you need to do something about it, and that clearly could have a financial impact.”
His argument is based on fewer document requests. “I’m convinced that if financial risk checks are implemented by industry in the right way, and in the way that’s expected, there should be much, much less cause for consumers to share documents with operators,” he says. “If a tool can both help identify consumers who are potentially at risk of harm and remove burdens and friction for the vast majority of consumers, that feels like a win-win to me.”
GC board didn’t delay FRA decision
He also rejects reports that the board delayed its decision on whether to approve financial risk assessments. “Inaccurate,” he says.
The first stage applies only to the largest operators and to customers whose net deposits exceed £5,000 in a rolling 24-hour period (£2,500 for under-25s), with no enforcement action in the early stages. The final thresholds will be £1,000 in 24 hours or £3,000 over 90 days.
Asked what difference the checks will make in practice under those terms, Miller declines to speculate. On future thresholds, he frames it as a question of proportionality, noting only that “where you see evidence of risk coming down, regulatory burdens can come down with it”.
Displacement cuts both ways
On the risk of high-value customers drifting offshore once FRAs are fully implemented, Miller is measured. “There is always a risk of displacement from regulatory requirements. Sometimes that risk is overblown, but it has to be monitored.”
But he turns the argument back on operators, whose own commercial decisions also push players to unlicensed sites. “We heard from consumers all the time – often some of the more successful punters – who were struggling to get a bet on and were being restricted, and their only option was then to go to the illegal market.”
‘Certainly no conflict at all’
Rhodes’ appointment as principal consultant at advisory firm Hawkbridge – also announced in June – drew conflict-of-interest claims. Miller, who now advises a company selling monitoring tools to regulators, rejects any suggestion of the same. “No, not at all. I was very clear that I didn’t want to move into roles that would compromise my independence.”
He accepts that “there will be confidential information I had access to at the Commission that I cannot and will not share”, but argues that his expertise is his own. “I don’t think there’s any industry where you can say somebody can’t make use of the skills they’ve built up.”
That independence, he says, shapes his workload. “My strongest selling point is the independent perspective I’ve always tried to bring as a regulator, and I want to guard that as much as I can.” His focus is on governments, regulators and the tech firms that support them, although he could work with operators on the illegal market where interests align. Initially, all of his work will be outside the UK. “I don’t want to be hanging around like the Ghost of Christmas Past [a character from Charles Dickens’ A Christmas Carol].”
He sets out three priorities: sharing lessons with emerging jurisdictions (particularly in the US), continuing to challenge tech platforms (Meta especially) over illegal gambling advertising and acting as a bridge between developers and regulators. Miller recalls sitting through vendor pitches so full of industry jargon that “I didn’t understand a word of it”. He wants to improve the line of communication, he says.
A toxic debate
Staying out of the UK also means a break from a debate Miller calls “really toxic” at times, with both industry and campaigners letting their language become too personal. “I’ve had situations on social media, for example, where threats have been made against my own family. That is simply unacceptable.”
His parting plea to the sector is therefore: “Keep your passion, but find a way to work with people who have different views.”