Andrew Tait
Consultant Solicitor
Gibraltar
T +350 20068450
AndrewTait@incegd.com
Expertise Gambling law and compliance Department Regulatory solutions, Gaming & betting Qualified England & Wales, Gibraltar and Republic of Ireland

Andrew joined the firm in 2017. He has over 20 years’ specialist expertise in betting & gaming, regulation & compliance, intellectual property and commercial contracts. Much of his experience, including 10 years as General Counsel & Chief Compliance Officer at Mansion Group, comes from industry. He is therefore able to provide workable and pragmatic solutions to the issues that his clients face.
Andrew joined the firm in 2017 and his key specialisms are gambling law and regulation, compliance, governance and risk management, AML policies and procedures, IT contracts and technology licensing, entertainment and media contracts, as well as copyright licensing, sports sponsorship agreements, e-commerce and internet law.
Quote
"Andrew is very knowledgeable with gaming regulations of various jurisdictions and we found his advice on some niche requirements to be very practical and cost effective." - Ryan Lazarus, Revolver Gaming
Professional Associations & Memberships
- IMGL (International Masters of Gaming Law)
- GBGA (Gibraltar Betting & Gaming Association)
- ICA (International Compliance Association)
What you may now know about Andrew
Andrew is a keen swimmer, sailor and generally a big fan of all water sports.
Accolades:
Legal 500
My matter highlights
- Advising a major online sports betting and casino gambling operator on restructuring of their entire business to realign their operations with specific regional risk profiles, then assisting in implementation of the agreed restructure plan.
- Advising a large investment group on designing a lottery product and associated services capable of international coverage, whilst mitigating various regulatory and tax risks.
- Providing consulting services for a number of online and land based gambling operators on AML Risk Assessments, and general AML compliance related services across various jurisdictions.
- Advising a number of B2B and B2C operators on their application for British remote gambling licences, including restructuring and source of funds related advice.
- Assisting a Gibraltar based B2B and B2C remote gambling operator on the drafting of a template suite of commercial contracts and then ongoing assistance with individual negotiations
- Advising an eSports start-up on the application of any British gambling regulations and general consumer law to their offering.
- Creating and updating a global gambling regulatory report for a number of existing clients, detailing regulatory regimes and trends in over 70 countries.
- Providing consulting services for a number of Malta based B2B and B2C operators on general gambling compliance assessments, producing gap analysis and remedial plans to bring their compliance regimes up to standard.
- Assisting an individual client on recovering a large sum frozen by a major UK bank, due to AML concerns. Successful reimbursement of the full balance, plus compensation and all costs.
- Overseeing of a skilled person report commissioned by the Gibraltar financial services regulator into potential AML failings of a Gibraltar based electronic money institution.
My testimonials and accolades
My recent publications
News / ACAMS Money Laundering: To Combat Gambling Epidemic, Britain Turns to AML Rulebook
23-09-2021 / Gaming & Betting
“Both the frequency and severity of enforcement is increasing all the time,” Tait told ACAMS moneylaundering.com. “Operators are struggling to keep pace with … new regulations and rigid enforcement, and having to divert more and more resources to try and stem the tide.”

Insights / Remote customer interaction
09-11-2020 / Gaming & Betting
The Gambling Commission has published a consultation for the remote sector to improve standards of Customer Interaction.

Insights / VIP Schemes Deadline 31st October 2020 – Are you ready?
08-10-2020 / Gaming & Betting
From 31 October 2020 gambling operators in the UK must adhere to strict guidance relating to High Value Customer or “VIP” schemes.

Insights / Common market how similar regulatory failings are colouring UK legislation
22-06-2020 /
Andrew Tait and Michelle Walsh discuss how‘common regulatory vulnerabilities’ among operators are shaping the UKGC’s approach to regulation.

Insights / Globalisation vs AML Regulation in the Gambling Industry
28-11-2019 / Gaming & Betting
This article was first published in the ICLG to: Gambling 2020 We are pleased to share that Andrew Tait and Michelle Walsh recently contributed to a chapter on 'Globalisation vs. AML Regulation' in the sixth edition of the ICLG (International Comparative Legal Guides) Gambling 2020 guide. The guide covers common issues in gambling laws and regulations – including relevant authorities and legislation, application for a licence, licence restrictions, digital media, enforcement and liability across 39 jurisdictions.

News / Upping the stakes on responsible gambling
10-04-2019 / Gaming & Betting
This article was first published in EGR Compliance, April 2019. Now that the anti-gambling lobby has won the battle over reduced stakes on FOBTs, attention has turned back to the online sector. Despite the rates of problem gambling remaining static at 0.8% of the UK population, this still leaves us with 340,000 or so problem gamblers. Therefore, as identified by Tracey Crouch, the then DCMS minister, in her May 2018 review, the next area of focus is the online sector

Insights / AML Compliance and Enforcement Seminar, brought to you by Ince Gordon Dadds & iGaming Academy
03-01-2019 / Gaming & Betting
AML Compliance and Enforcement Seminar, brought to you by Ince Gordon Dadds & iGaming Academy. Tuesday 15 January 2019, Intercontinental Hotel Malta – 1.00pm – 8.00pm.

News / Betting & Gaming sector update November 2018
27-11-2018 / Gaming & Betting
Malta Update: Like many other EU jurisdictions, Malta was late in updating its AML regulations in line with the 4th Money Laundering Directive, only doing so on the 21 December 2017, well past the 26 June 2017 deadline. However it’s not alone with countries such as Ireland still without updated regulations.

News / Unregulated gaming: is the noose closing?
12-11-2018 / Gaming & Betting
Unregulated gaming covers a wide remit of products, including esports, fantasy sports, house raffles, social casinos, prize competitions and many more constructions to bring them outside the legal definition of gambling, comprising games of chance, betting and lotteries. The advantages of being outside the regulatory net are substantial in the form of reduced costs, no gaming duty and freedom from regulatory compliance.

News / UK Gambling Commission enforcement: a blessing in disguise?
12-09-2018 / Gaming & Betting
This article was first published in EGR Compliance September 2018. Earlier this week Andrew Tait debated whether the Commission’s uplift in enforcement activity could be perceived as perhaps a step too far; click here to see the article. Today he discusses the flip side, with the question: is it actually a blessing in disguise?

News / UK Gambling Commission enforcement: a step too far?
12-09-2018 / Gaming & Betting
This article was first published in EGR Compliance September 2018. The UK Gambling Commission’s stance on regulatory enforcement since 2015 has significantly changed from one relying on the letter of the law to one focused on the spirit of the law. The Licence Conditions and Codes of Practice (LCCP) have evolved to enshrine this change, with the emphasis now on operators to apply the licensing objectives in a more subjective manner.

News / Converging Compliance, the increasing harmonisation of the gambling industry
22-05-2018 / Gaming & Betting
Andrew Tait's article was first published by Gambling Insider on 14 May 2018 Regulation and compliance is becoming increasingly holistic in the gaming industry. Both in the UK and across Europe, new regulations are bringing the industry together in terms of process and protection for its players and operators. European jurisdictions are aligning their focus and in particular on three key issues; the General Data Protection Regulation (“GDPR”) Money Laundering and Problem Gambling. What we’re currently witnessing is the convergence of compliance in the gaming industry at an international level.

News / News and Regulatory Updates in the Betting and Gaming sector
01-05-2018 / Gaming & Betting
With so much happening in the sector recently, our betting and gaming team has put together a succinct overview of the pertinent developments, alongside practical suggestions to help operators stay ahead of the curve

News / The GB Gambling Commission surveys the exposure of children to gambling
28-02-2018 / Gaming & Betting
The report: In December 2017, the GB Gambling Commission (‘GC’) published the results of its annual survey which studies the exposure of children in Britain to gambling. Andrew Tait, partner at Ince Gordon Dadds, analyses the results of this survey, and considers the possible incitements to children to gamble, and what action might be taken about it.

News / The GB Gambling Commission's enforcement strategy changes and implications for industry
20-09-2017 / Gaming & Betting
Andrew Tait and Andrew Cotton's article was first published by Online Gambling Lawyer in August 2017Following its consultation which ran from January until April 2017, the GB Gambling Commission (Commission') has this summer implemented its revised enforcement regime This carries some major changes, such as around the presumption of settlementsnbspHere, Andrew Tait and Andrew Cotton of Ince Gordon Dadds analyse the important changes and also the implications for operators, drawing upon the lessons learnt from recent Commission enforcement action such as that involving BGO and Lottoland

News / The GB Gambling Commission’s enforcement strategy: changes and implications for industry
20-09-2017 / Gaming & Betting
Following its consultation which ran from January until April 2017, the GB Gambling Commission (‘Commission’) has this summer implemented its revised enforcement regime. This carries some major changes, such as around the presumption of settlements. Here, Andrew Tait and Andrew Cotton of Ince Gordon Dadds analyse the important changes and also the implications for operators, drawing upon the lessons learnt from recent Commission enforcement action such as that involving BGO and Lottoland.

News / UK – Legal firm warns of risk to remote gambling licences
02-08-2017 / Gaming & Betting
This article was first published in G3 Newswire, August 2017ince, a legal and professional services firm, is urging the British licensed remote gambling sector to prepare for the latest proposed changes to the Commission’s Licence Conditions and Codes of Practice (LCCP) or risk a licence review.

News / Wayne Shaw pie-eating incident shines spotlight on emerging risks of novelty bets
22-06-2017 / Gaming & Betting
Andrew Tait's article was published by and appeared in Online Gaming Lawyer, March 2017As widely reported in the national press, a recent FA Cup tie saw Wayne Shaw, at the time a reserve goalkeeper for Sutton United, eat a pie on the touchline during his team's match against Arsenal FC The incident has led to both Shaw and operator Sun Bets being investigated by the Football Association and the British Gambling Commission after it emerged that Sun Bets was offering 81 odds that Shaw would eat a pie during the match, and Shaw admitting that he was aware of the specific bet being offered The investigation will look at matters of betting integrity involved in the incident, and serves as a test case for the area of novelty bets, which has previously been the focus of regulatory attention last year the Commission warned operators of the risks of offering bets in novelty markets Andrew Tait of Ince Gordon Dadds discusses the case and the possible consequences for Sun Bets, and the lessons to be drawn for operators

Insights / UPDATE: How the 4AMLD will affect the gambling industry
20-06-2017 / Gaming & Betting
UK Government Treasury published its draft Money Laundering Regulations 2017 on 15 March 2017. This draft factored in the outcome of a National AML Risk Assessment which sought to identify areas of high risk across the multitude of Regulated Industries subject to the 4AMLD. This determination between high and low risk is key as it allows national regulators to exempt low risk elements from the ambit of the 4AMLD. The draft was open to further consultation and comments with a deadline of 12 April 2017. The results of this consultation have not yet been published as of the 20 June, just a week before the 4AMLD is supposed to be transposed into UK law.

News / Implication of UK Gambling Commission’s updated LCCP reporting requirements on Grey market activity
09-06-2017 / Gaming & Betting
The UK Gambling Commission expect their B2C licensees to carry out their own legal and regulatory due diligence on targeted territories they provide facilities for gambling to, and which generate revenues of 3% or more of their total (or 10% where global revenues are less than £5M). The test is not proscriptive but does require an assessment of the risks associated with each territory to determine if on balance, the decision to continue taking businesses from there is based on “reasonable assumptions and a coherent rationale”. Similarly B2B licensees will also need to justify where their revenues are coming from, and to specify controls they have in place to ensure that their B2C customers are not using their technologies and services to generate revenues from “grey” or especially “black” markets.
