Tim Miller has concluded a decade at the UK’s Gambling Commission, where he played a vital role in implementing the 2023 white paper reforms. His work encompassed a wide range of areas including age verification, game design, marketing controls, and financial risk checks. He also oversaw the initiation of the Gambling Survey for Great Britain (GSGB).
Among his accomplishments, Miller cites the National Strategy to Reduce Gambling Harms as his most significant achievement. This strategy successfully integrated the financial services sector into harm prevention, encouraging challenger banks like Starling to adopt gambling blocks for their customers.
However, in June, he announced his departure, which officially took place last month. He has since launched GamReg Consulting, already attracting early clients such as Gaming Compliance International (GCI), known for providing transaction and market monitoring tools to regulators, and Spectrum Gaming Group. Miller expressed enthusiasm about the response to his new venture, especially after attending the G2E event in Las Vegas, where feedback was "absolutely fantastic."
His exit from the Commission occurred at a particularly sensitive juncture. Chief Executive Andrew Rhodes stepped down in late April, financial risk assessments (FRAs) were confirmed in July, and the full implementation of these measures is still in progress.
Miller underscores that his decision to leave was not driven by issues within the Commission. "I wasn't looking to escape the Commission, I was just ready for the next challenge," he stated. Though he was mentioned as a potential successor to Rhodes, he dismissed that possibility, explaining that leading the Commission requires a commitment of at least three years, which he was not prepared to make.
He downplays the recent senior departures from the Commission, suggesting it's merely coincidental. With more than 300 employees, he believes that while individual leaders matter, they do not overshadow the organization as a whole.
Miller identifies the illegal gambling market as the Commission’s most pressing challenge, emphasizing the unrealistic expectations some have regarding the regulator's influence. He draws parallels between illegal gambling operations and organized criminal activities, such as the drug trade, noting that it is unreasonable to expect a small regulator to manage these complex issues alone. He insists that law enforcement, governments, and tech companies share the responsibility in combating illegal gambling.
He also defends the GSGB against criticisms from industry players who argue that it exaggerates gambling participation and harm. Miller points out that critics who prefer the Health Survey for England often ignore its limitations, which reveal a rising problem gambling rate, while the GSGB indicates a more stable situation. "If anyone suggests there's a single survey or a single piece of data that gives you the absolute definitive picture, then frankly, they're kidding you," he said.
Among the white paper's measures, financial risk assessments attracted the most backlash. Miller attributes this pushback to two main factors: branding and financial concerns. Opponents dubbed them "affordability checks," a term he feels misrepresents their purpose. He expressed his own reservations about affordability checks, believing they would be hard to implement.
Additionally, Miller revealed that the pilot for FRAs clearly identified a segment of at-risk customers, often significant revenue generators, who were not being adequately monitored by existing methods. Addressing these individuals is essential, even if it poses potential financial repercussions for operators. He argues that efficient implementation of financial risk checks could reduce the burden on the majority of consumers, noting, "If a tool can help identify consumers at risk and ease the process for most, that feels like a win-win."
Miller disputes claims that the Gambling Commission board delayed its decision on financial risk assessments, labeling those assertions as "inaccurate."
He clarified that the initial phase of FRAs will focus solely on the largest operators, targeting customers whose net deposits exceed £5,000 in a 24-hour period (or £2,500 for under-25s). He indicated that there will be no enforcement action during the early stages, and final thresholds will eventually drop to £1,000 in 24 hours or £3,000 over 90 days.
When asked about the practical impact of these checks under such conditions, Miller refrained from speculation. He discussed future thresholds in terms of proportionality, stating, "Where you see evidence of risk coming down, regulatory burdens can come down with it."
Regarding the concern that high-value clients might turn to offshore options with the full implementation of FRAs, Miller recognized the potential for displacement due to regulatory requirements, while cautioning that this concern can sometimes be overstated. He redirected the discussion to operators, whose commercial choices may also lead customers to unregulated sites. “We hear from consumers all the time—especially successful bettors—who struggle to place bets due to restrictions, leaving them no option but to seek out the illegal market,” he said.
With Rhodes transitioning to a role as principal consultant at advisory firm Hawkbridge, conflicts of interest have been scrutinized. Miller, now advising a company that supplies monitoring tools to regulators, rejected any implications of conflicts, asserting, "No, not at all. I was clear that I didn't want to move into roles that would compromise my independence."
While acknowledging that some confidential information from his time at the Commission cannot be shared, he stressed that his expertise remains his own. Miller stated, "I don't think there's any industry where you can say somebody can't make use of the skills they've built up."
His independence informs his consulting approach, as Miller aims to leverage his perspective as a former regulator. He plans to focus on advising governments, regulatory bodies, and the technological firms that assist them, while maintaining openness to collaborating with operators on issues that align with mutual interests. Initially, he will work primarily outside the UK.
Miller emphasized his desire to avoid lingering in the UK’s contentious landscape, describing the ongoing debate as sometimes "really toxic," noting personal threats received via social media. His final message to the industry: "Keep your passion, but find a way to work with people who have different views."
