ArticlePDF Available


Financial institutions have corporate social responsibility to assist customers in enhancing their financial well-being, and to make a positive contribution to society given the considerable role that they play in customers’ everyday lives. Financial institutions are involved in gambling through facilitating gambling transactions, including provision of credit to customers potentially experiencing gambling-related harms. As financial institutions have an overview of customers’ income, spending and debt, this potentially allows for the identification of excessive expenditure on specific activities. This article reviewed the role of financial institutions in gambling with the aim of considering ways in which policies and practices could enhance customer well-being. The Australian-focused review found limited evidence of gambling-specific bank policies despite increasing recognition of the impact of gambling-related harms. Behavioral economics and psychological approaches may be promising frameworks to guide the development of policies to assist customers in limiting their gambling to affordable levels. Financial institutions could implement products and resources for customers to enhance management of gambling expenditure. Government and community scrutiny over the role of financial institutions in gambling will likely increase given growing recognition of harms. A proactive effort to enhance customer well-being could have broad positive outcomes for financial institutions’ social licence to operate.
The Role of Financial Institutions in Gambling
Please cite as: Swanton T.B., Gainsbury, S.M., & Blaszczynski, J.T. (2019). The role of financial
institutions in gambling. International Gambling Studies.
Financial institutions incorporate social responsibility to assist customers enhance and
maintain financial wellbeing and make a positive contribution to society given the large role
that they play in customer’s everyday lives, businesses, major events, and future plans.
Financial institutions are involved in gambling through facilitating gambling transactions,
including providing credit to customers including those potentially experiencing gambling-
related harms. They have an overview of income, spending, and debt, making it potentially
possible to identify excessive expenditure on specific activities. This paper reviewed the role
of financial institutions in gambling with the aim of considering ways in which policies and
practices could enhance customer wellbeing. The Australian-focused review found limited
evidence of gambling-specific bank policies despite increases in the recognition of the impact
of gambling-related harms. Behavioural economics and psychological approaches may be
promising frameworks to guide the development of policies to assist customers in limiting
their gambling to affordable levels. Financial institutions could implement customer products
and resources to enhance management of gambling expenditure. Processes could be
established to respond to the disclosure of gambling problems and proactive strategies
developed to detect potentially risky gambling patterns. Government and community scrutiny
over the role of financial institutions in gambling will likely increase given growing
recognition of harms. A proactive effort to enhance customer wellbeing could have broad
positive outcomes for financial institutions social license to operate.
Keywords: gambling, banking, corporate social responsibility, business ethics, consumer
Funding: This work was supported by an Australian Research Council Discovery Early
Career Research Award [DE1060100459] awarded to Dr Sally Gainsbury.
The Role of Financial Institutions in Gambling
Since the 2008 Global Financial Crisis, financial institutions have faced increased
scrutiny over corporate governance and risk management practices (Financial Crisis Inquiry
Commission, 2011; Härle, Havas, Kremer, Rona, & Samandari, 2015). Globally, the crisis
exposed numerous failings in policy and practice that brought about serious consequences at
a macroeconomic and individual consumer levels (Reserve Bank of Australia, 2014). In
Australia, banks have been publicly criticised for neglecting to manage risk appropriately and
failing to meet emerging social expectations. This culminated in a royal commission into the
banking sector (Laughlin, 2018) with discourse related to excessive charges, imprudent
lending practices, inappropriate financial advice, and improper conduct by bank employees.
However, one area of financial institutions’ activity that remains largely unexplored is their
role in gambling. This gap is concerning considering the critical role that financial
institutions play as a conduit for gambling transactions. This is increasingly the case with the
growing popularity of online gambling which almost exclusively relies upon electronic
transactions facilitated by financial institutions (Blaszczynski et al., 2015; Department of
Social Services, 2016; Gainsbury et al., 2011; Griffiths & Barnes, 2008). As intermediaries,
financial institutions have an opportunity to instigate strategies designed to prevent and/or
reduce exposure to burdens for those vulnerable to gambling-related harms.
The prevalence rate of problem gambling is around 1% in most jurisdictions (Abbott,
Romild, & Volberg, 2014; Gainsbury et al., 2014; Wardle, Griffiths, Orford, Moody, &
Volberg, 2012; Welte, Barnes, Tidwell, Hoffman, & Wieczorek, 2015). Around six
additional people (e.g., family and friends) are affected by each problem gambler, with harms
experienced by the broader community including family breakdown, reduced productivity,
bankruptcy, crime, and poor mental health (Goodwin, Browne, Rockloff, & Rose, 2017).
Financial harms, including reduced household net worth, debt, and bankruptcy, are a primary
indicator of problem gambling (Blaszczynski et al., 2015). Reduced savings, doing without
necessities, and debt are among the five most common impacts of gambling in terms of harm
(Shannon, Anjoul, & Blaszczynski, 2017) as is worry and frustration associated with
financial difficulties (Shannon, Anjoul, & Blaszczynski, 2017). In Australia, problem
gamblers were estimated to contribute AUD $6.15 billion to gambling revenue in 2011/12,
with many incurring sizeable debts in proportion to their income (Blaszczynski et al., 2015).
Access to cash through in-venue ATM/EFTPOS facilities and the ability to use credit for
gambling transactions constitute major risk factors contributing to increased accessibility to
funds. Whilst governments have a primary role in regulating gambling environments,
financial institutions are also key stakeholders. In Australia, the four major banks, accounting
for 73.1% of the total lending market, allow gambling transactions on credit cards for most
forms of gambling, excluding electronic gaming machines (PricewaterhouseCoopers, 2016;
Royal Commission into Misconduct in the Banking, Superannuation and Financial Services
Industry, 2018). In contrast, other financial institutions (e.g., American Express, Bank of
Queensland, Citibank, Suncorp Bank, Virgin Money, and Bendigo Bank) prohibit the use of
credit cards for gambling (Bradney-George, 2017; South Australian Financial Counsellors
Association, 2016). Most banks do not appear to have made any public comment about their
rationale for doing so. Several banks, including Bank Australia Limited (2017), are currently
reviewing their policies regarding gambling in view of the negative impacts of problem
gambling. To date, there is little evidence of banks considering similar restrictions relating to
other problematic risk-taking behaviours with potential financial harms (e.g., excessive
shopping), aside from fraudulent or illicit activity. Under the National Consumer Protection
Framework, the Australian Government has prohibited wagering operators from providing
lines of credit to consumers, as implemented in some Canadian jurisdictions (Hincer, 2016).
Direct links from online wagering operators to payday lenders are also prohibited
(Department of Social Services, 2017). Consumer protection advocacy groups are now
calling for complementary bans on financial institutions offering credit for consumer
gambling transactions (Department of Social Services, 2016; Financial Counselling Australia
[FCA], 2017; UCA Funds Management, 2016). Such appeals have also been made in the
United Kingdom amidst a government review into gambling regulation (Etches, 2018;, 2018; Responsible Gambling Strategy Board, 2018).
There is an increasing expectation for financial institutions to conduct business in a
socially responsible manner (Scholtens, 2009). This expectation is driven by a broad range of
factors, including competitive, societal, political, regulatory, media, and ethical influences
(Ali, Frynas, & Mahmood, 2017; Darus, Mad, & Nejati, 2015; Marin, Ruiz, & Rubio, 2009).
In addition to creating stable macroeconomic environments, financial institutions exert
significant influence over the stability and sustainability of the finances and livelihoods
entrusted to them by individuals (Griffiths, 2007). Financial institutions therefore operate in a
highly regulated environment and have a widely recognised responsibility for enhancing
customer wellbeing (Castelo, 2013). Consequently, financial institutions typically devote
considerable resources to corporate social responsibility (CSR) activities. The ethical
implications of CSR for corporations involved in the gambling industry have been the subject
of debate (Leung & Snell, 2017; Lindorff, Prior Jonson, & McGuire, 2012; Miller &
Michelson, 2013; Prior Jonson, Lindorff, & McGuire, 2012). Given the importance of
financial harms as an indicator of problem gambling, and banks’ responsibility to enhance
customer financial wellbeing, there is reason for financial institutions to implement effective
harm-minimisation strategies.
Insights into financial decision-making are useful for understanding consumer
gambling behaviour, given similarities in other decision-making processes (Hurla, Kim,
Singer, & Soman, 2017). Despite extensive research exploring consumer financial decision-
making and mental accounting (Kahneman & Tversky, 1979; Thaler, 1980; Thaler &
Johnson, 1990), there is a paucity of literature applying these findings to financial
institutions’ policy and practice in response to consumer gambling behaviour. Advances in
behavioural economics offer potential avenues for developing more sophisticated theoretical
frameworks for understanding the role of financial institutions in gambling. This includes
considering institutional responsibility in reducing information asymmetries, improving
financial literacy, and establishing environments conducive to informed decision-making
(Altman, 2012).
This scoping review broadly aims to consider the role of financial institutions in
gambling and minimising related harms. We initially reviewed the broad role of financial
institutions as intermediaries in gambling-related transactions, and subsequently, four specific
aims: (i) to examine the role of financial institutions in facilitating gambling-related
transactions by provision of credit, (ii) to investigate the nature of financial institutions
policies on gambling, (iii) to explore financial institutions potential role in regulation of
gambling, and (iv) to consider their responsibility for enhancing customer wellbeing. The
paper is intended to stimulate debate and focused research, and to identify potential targets
for policy and interventions. The findings have implications for policy makers, financial
institutions, consumer advocacy groups, and other relevant stakeholders, and may extend to
other problematic risk-taking behaviours involving potential financial harms for consumers.
For the scoping review, the academic literature (Scopus, Web of Science, PsycINFO,
and the ABI/Inform Collection) was searched using the following keywords: financial
institution; bank; gambl*; policy; wellbeing; financial hardship; credit; sustainability.
Articles relevant to the role of financial institutions in facilitating gambling, or establishing
gambling-related policies were selected from peer-reviewed journals. An environmental scan
was conducted to gain an overview of current policy and practice. The focus was limited to
financial institutions providing services directly to consumers, such as banks and credit
unions. Keywords were used in the environmental scan to search Google for non-academic
reports, newspaper articles, parliamentary submissions, and financial institution policy
documents. Using Google Advanced Search functions the websites of Australia’s four major
banks (Australia and New Zealand Banking Group Limited [ANZ], Commonwealth Bank of
Australia [CBA], National Australia Bank Limited [NAB], and Westpac Banking
Corporation [Westpac]) were searched for publicly available information. The environmental
scan was not exhaustive; documentation not publicly available, such as internal policies,
standards, or procedural documents of financial institutions were inaccessible. Searches were
conducted between November 2017 and October 2018.
Role of financial institutions as intermediaries in gambling transactions
The present-day ubiquity of electronic funds transfer means that financial institutions
are key participants in the majority of transactions. Gambling-related electronic transactions
can be identified by a financial Merchant Category Code (MCC), a standardised four-digit
classification allocated to a merchant based on their primary business type. In an online credit
card transaction, five parties are usually involved: cardholder, card issuer (e.g., bank), card
payment system (e.g., Visa, MasterCard), acquirer (e.g., bank receiving funds on behalf of
merchants), and merchant (e.g., online gambling provider) (iBus Media Limited, 2011). The
Reserve Bank of Australia (RBA; 2018) reported that, as of November 2017, there were 16.7
million credit and charge card accounts in Australia with a total outstanding balance of AUD
$52.2 billion, and total credit limit of AUD $152.6 billion. The trend from cash and cheque to
debit and credit card payments continues to grow amongst Australians. Debit and
credit/charge cards accounted for 52% of total payments in 2016 (up from 26% in 2007) from
over 1,500 participants surveyed (Doyle, Fisher, Tellez, & Yadav, 2017). Card payments for
online transactions accounted for 6% of total payments in 2016. Internationally, global non-
cash transactions grew 11.2% during 2014-15 to a total of USD $433.1 billion, with
continued increases predicted (Capgemini & BNP Paribas, 2017). Credit cards are a primary
means of payment for online gambling transactions, amongst more than 170 different
payment methods available, including a range of third-party e-wallets (e.g., Neteller and
Skrill) (Gainsbury, 2012;, 2018).
Financial institutions also play a role in ‘offline gambling transactions. Land-based
gambling transactions are not as easily identifiable as are online transactions. Consumers are
able to make offline gambling transactions via debit or credit cards, or using cash withdrawn
from in-venue ATM/EFTPOS facilities (Australian Transaction Reports and Analysis Centre,
2011; Productivity Commission, 2010a). In some instances, transactions are not clearly
identified as gambling as consumers may use funds to purchase non-gambling goods and
services within licensed gambling venues. Nonetheless, there are restrictions in several
jurisdictions (e.g., Australia, Canada, Singapore), such as requirements for ATM facilities to
be placed outside the gambling floor and restrictions on the daily number or value of
ATM/EFTPOS transactions permitted. Evidence strongly linking ATM/EFTPOS facilities
and gambling-related harms has supported recommendations for restrictions (Productivity
Commission, 2010a).
If restrictions on gambling transactions were introduced using the MCC as an
identifier, safeguards would be necessary to prevent gambling operators circumventing such
measures by altering their primary business type (Miller, 2008). Overall, however, the
relative ease of identifying electronic gambling transactions, as opposed to cash payments,
makes such transactions a more feasible targeted intervention.
The role of financial institutions in facilitating gambling-related transactions by
provision of credit
The provision of credit cards, personal loans, and overdrafts are primary means by
which financial institutions facilitate consumer gambling-related transactions (Farnsworth &
Selvaratnam, 2018; Kratzke & Depperschmidt, 2006). In doing so, gamblers are able to fund
gambling levels beyond affordable levels. Gambling-related transactions are commonly
treated as cash advances by card issuers (ANZ, 2017b; CBA, 2017b; NAB, 2016;
Responsible Gambling Strategy Board, 2018; Westpac, 2017). A Queensland household
survey of 15,000 adults in 2008/09 found credit card use to access cash advances for
gambling to be more common amongst problem (27.1%) compared to low-risk gamblers
(6.6%) (Productivity Commission, 2010a). Use of credit appears a moderating factor in the
experience of gambling-related harms. Cash advances attract high interest rates, additional
fees, and do not include interest-free periods (Bradney-George, 2017). For example, for
credit card gambling transactions, CBA (2017a) charges a cash advance fee of AUD $2.50 or
2.00% of the transaction amount (whichever is greater), and interest accrues at a rate of
21.24% p.a. from the transaction date. Hypothetically, a customer using a credit card to place
a total of AUD $2,500 with an online wagering operator and making minimum monthly
repayments would pay a total of AUD $12,813 over 39 years (assuming the opening balance
was $0 and the only transaction made). As stated by the UK’s Responsible Gambling
Strategy Board (2018), [t]he cost of gambling with a credit card is so high that it is hard to
envisage why consumers would choose to pay in that way, unless it was to gamble with
money not otherwise available to them (p. 3). Using credit cards to finance gambling
activities could inevitably become problematic for consumers lacking financial resources to
repay outstanding balances.
For this reason, provision of credit for gambling has been a major concern for
consumer advocacy groups. Financial Counselling Australia (FCA) (2017) has argued that
there may be ‘increased reliance on credit cards as a means of fuelling gambling addictions
(p. 3) following the ban on Australian gambling operators offering credit to consumers. To
date, little empirical attention has been given to the true extent of credit provision for
gambling, or to the prevalence of harms associated with this practice. FCA (2017) reports
that financial counsellors frequently encounter clients acquiring multiple credit cards, often
with debt running into the tens of thousands of dollars, largely as a result of gambling. They
argue that consumer credit protection measures are inadequate. Consumers only need to
demonstrate capacity to make the 2% minimum monthly repayments, with no limit to
amounts able to be gambled in any session (subject to card limit). After conducting a survey
on the attitudes of an online sample of 1,002 Australians towards institutional lending
practices, Fear and O’Brien (2009) found 72% of respondents agreed with the statement, ‘it is
too easy for banks to lend money to people who can’t afford the repayments.’ This is
consistent with gambling industry sources suggesting that customers with multiple cards are
at greater risk of harm, indicating that this might be an appropriate target for intervention
(Labour calls, 2018).
Financial institutions have faced extensive public criticism over their lending
practices, with FCA accusing banks of ‘wilful blindness (Farnsworth & Selvaratnam, 2018,
para. 23). In one example cited by Farnsworth and Selvaratnam (2018), a major bank
approved a personal loan of AUD $25,000 to a customer with minimal savings and whose
transaction history revealed his expenditure of hundreds of dollars a day with online
gambling operators. Under the National Consumer Credit Protection Act 2009 (Cth),
financial institutions have an obligation to assess the unsuitability of a credit contract given a
consumer’s financial circumstances and to prevent them from entering into an unsuitable
contract. The Australian Prudential Regulation Authority, which oversees the industry, has
suggested that whilst strong responsible lending policies may be in place, actual compliance
may be lacking in practice (Byres, 2017).
Some banks have introduced measures restricting the use of credit products for
gambling in an effort to promote responsible gambling. CBA (2003) does not permit credit
card cash advance transactions on in-venue ATMs to limit cash availability. More recently,
the four major banks have suggested they will be introducing further measures to protect
customers in financial hardship, including options for customers to block credit card use for
online transactions (Farnsworth & Selvaratnam, 2018). CBA’s former Chief Executive
Officer, Ian Narev (2017), indicated that the bank is considering whether to cease permitting
credit card use for online gambling transactions. Brian Hartzer (2017), Westpac’s Chief
Executive Officer, reported that whilst the bank does not have a specific policy regarding
credit provision for online gambling, what I can certainly assure you of is: we are not
supporters of the idea of customers using credit cards to gamble (p. 18). Credit card scheme
regulations were cited as a complicating factor in advancing this issue.
Despite this, numerous gambling industry stakeholders have argued that proposed
consumer protection measures are insufficient. They advocate that at the core of the problem,
there is ‘a clear difference between allowing a person to use money from their cheque or
savings accounts to gamble as they see fit, and allowing a person to gamble on credit, where
losses can be much higher’ (Clubs Australia, 2009, as cited in Productivity Commission,
2010, p. 580). This statement summarises an emerging issue for financial institutions in
relation to responsible lending. Regulations already restrict use of credit in Australian land-
based gambling venues, but credit cards remain a primary payment method for online
gambling. Evidence suggests that moderate risk and problem gamblers use credit to fund
gambling activity more frequently than other gamblers (Productivity Commission, 2010a).
This creates tension between bankslending decisions and their social responsibilities to
Financial institutions’ policies on gambling
The environmental scan revealed that very few financial institutions appear to have
detailed gambling-specific policies or position statements. Many banks set out their
overarching positions relating to CSR in sustainability statements; however, only a small
number make reference to gambling.
Of the four major Australian banks, none have position statements specific to
gambling (ANZ, 2015; CBA, 2018b; NAB, 2017a; Westpac, n.d.-a). In their most recent
sustainability reports, however, gambling was identified by NAB as both an area of
engagement with consumer advocacy organisations and an issue of interest for shareholders,
particularly with regard to ‘provision of credit cards for use in gambling transactions’, and
exposure to companies with a negative social impact (i.e., gambling, fossil fuels, tobacco)
(NAB, 2017b, p. 79). Gambling addiction (NAB, 2017b, p. 18) was also identified as a
personal issue for some financially vulnerable customers. ANZ (2017a) reported piloting a
hardship assistance program for customers with gambling-associated debt. No reference was
made to gambling by CBA (2017c) or Westpac (2017). Internationally, Standard Chartered
(n.d.) was one of few major financial institutions having a gambling-specific position
statement. The banks stated concern is the associations of gambling with fostering organised
crime, prostitution, facilitating money laundering, and problem gambling and personal
bankruptcy (p. 2). Overall, the statement’s content predominantly concerns the bank’s
activities in corporate finance, setting out lending criteria for gambling sector clients, rather
than detailing policy regarding consumers experiencing gambling-related financial hardship.
Gambling is recognised by several smaller Australian banks as an issue relevant to
their sustainability framework. Many of these corporations, however, similarly appear to lack
a comprehensive consumer-focused gambling-specific position statement. Bank Australia
Limited (2017) has invited customers to participate in an online survey to give their opinions
on credit provision for consumer gambling transactions. Along with other industries seen to
have adverse social impacts, the gambling industry is identified in the responsible investment
strategy of many banks as one with which they avoid involvement (Bank of Queensland
Limited, n.d.-a; Bendigo and Adelaide Bank Limited, 2016). A number, including NAB,
Westpac, Bank of Queensland, Bank of Melbourne, and St. George Bank, state that they will
not sponsor activities relating to gambling (Bank of Melbourne, n.d.; Bank of Queensland
Limited, n.d.-b; NAB, n.d.; St. George Bank, n.d.; Westpac, n.d.-b).
As an advocate for the banking industry, the Australian Bankers’ Association (ABA)
stated support for encouraging socially responsible programs and effective and workable
strategies for addressing problem gambling (Münchenberg, 2011, p. 1). The ABA’s Policy
Director stated that the ABA and member banks believes gambling has serious detrimental
consequences, not only for those who experience financial and emotional deterioration
through a gambling addiction, but also on society in general (Hossack, 2012, p. 1). In this
letter, the ABA summarised measures employed by the four major banks to assist customers
experiencing gambling-related financial hardship. The measures surveyed included whether
the bank had a financial literacy program, a financial hardship policy, restrictions on in-venue
credit card cash withdrawals, and whether customers can adjust maximum credit limits.
However, only yes/no answers were made to each item, with no detailed evaluation provided
about the appropriateness of existing measures. Based on this superficial survey, the ABA
concluded that banks have consistent measures which would be useful in assisting those
people and families battling gambling addiction (Hossack, 2012, p. 1).
Overall, gambling does appear to be at least somewhat a consideration for policy
makers within the banking industry. However, it seems that their focus is more on risk
mitigation for corporate lending and reputation, rather than on customers. The latter issue
looks to be attracting more attention from banks, especially with trends towards a stricter
regulatory environment and following increasing calls from advocacy groups to ban credit
provision for gambling transactions.
The role of financial institutions in regulation of gambling
In Australia, the Interactive Gambling Act 2001 (Cth) (IGA) stipulates that the
Government may establish regulations providing that an agreement allowing for the exchange
of a monetary payment for the supply of an illegal online gambling service will have no
effect to that extent. This provision could implicate financial institutions in regulating online
gambling transactions, but such regulations have not been introduced to date (OECD, 2011).
A review of the IGA by the Department of Communications, Information Technology and
the Arts (2004, cited in The Allen Consulting Group, 2009) suggested that doing so could
expose Australian card-issuing financial institutions to litigation over dishonoured gambling-
related debts (e.g., repudiation of gambling debts incurred by consumers). The review
suggested that this could potentially result in financial institutions deciding to block all
gambling-related transactions. In Germany, financial institutions have been implicated in the
identification and blocking of illegal online gambling transactions following a recent court
ruling in favour of customers not having to repay credit card debts accumulated with
unlicensed operators, dependant on the bank’s awareness of the nature of the transaction
(Conneller, 2018).
A subsequent review of the IGA by the Department of Broadband, Communications,
and the Digital Economy (DBCDE; 2012) concluded that blocking of illegal gambling
transactions may be possible if the Government maintained a register of unlicensed online
gambling operators. However, this approach has not been pursued thus far (Australian
Communications and Media Authority, 2018). Hampering its feasibility are concerns relating
to the cost and complexity of implementation within payment systems, and the relative ease
of circumvention (e.g., by using overseas-based payment methods). The ABA has voiced
these concerns, suggesting that ‘new systems and processes for all electronic transactions
would be operationally complicated, administratively costly, and legally convoluted’
(Münchenberg, 2011, p. 4; Tate, 2016).
International attempts to regulate illegal online gambling using financial transaction
blocking demonstrate the existence of such obstacles. In the United States, the Unlawful
Internet Gambling Enforcement Act of 2006 (UIGEA) targets financial institutions as a
means for regulation. The Act prohibits financial institutions from accepting payments for
unlawful online gambling transactions (OECD, 2011). However, the legal implications for
financial institutions are unclear, given that an explicit definition of what constitutes illegal
activity is lacking (Fidelie, 2009; Marconi & McQuaid, 2007). The ease of circumventing
transaction-blocking mechanisms is a major criticism of this approach (DBCDE, 2012). For
example, third-party payment providers and cryptocurrencies are widely accepted by many
offshore gambling sites (Gainsbury & Blaszczynski, 2017). Third-party providers may
operate as intermediaries to disguise gambling-related credit card transactions (Fidelie, 2009;
Leonard, 2008; U.S. Department of Justice, 2007). Prohibition approaches appear to create an
impetus for consumers to move away from larger legitimate gambling providers to smaller
unregulated offshore operators (The Allen Consulting Group, 2009). Fidelie’s (2009) review
of Internet gambling regulation strategies concluded that aiming to regulate online gambling
solely through financial institutions is not a comprehensive strategy.
The responsibility of financial institutions in enhancing customer wellbeing
The role financial institutions play in customers’ financial wellbeing has implications
for customers’ wellbeing more broadly. Indebtedness, for example, has been linked to poor
mental health outcomes (Drentea & Reynolds, 2012; Fitch, Chaplin, Trend, & Collard, 2007).
Shah, Mullainathan, and Shafir (2012) provided evidence that having little (financially) can
lead to attentional biases which manifest in behaviours such as over-borrowing. The role of
financial sectors in consumer mental health and wellbeing has received limited academic
inquiry. However, these concepts have emerged as key community concerns.
Consequentially, many financial institutions engage in marketing based around commitments
to enhancing customer wellbeing. ANZ (2017a) states, ‘our purpose is to shape a world
where people and communities thrive’ (p. ii). The bank also acknowledges the importance of
financial wellbeing in the broader context, stating ‘it is widely accepted that financial
wellbeing contributes significantly to overall health and wellbeing and community
connectedness, leading to greater economic and social participation’ (p. 46). Despite such
commitments, a 2013 US Gallup web survey of over 11,800 adults found that only 25% of
customers strongly agree with the statement, ‘My bank looks out for my financial well-being’
(Riffkin & Jalajel, 2015).
Currently, financial institutions primarily seek to enhance customer wellbeing by
providing financial hardship assistance. Institutions typically define financial hardship as a
period of difficulty where customers are unable to meet current financial obligations (e.g.,
mortgage or credit card repayments), despite intentions to do so (ABA, 2016). Period of
financial hardship may be short-term, involving a temporary measure to assist customers
(e.g., payment deferral, or late/default fee waiver), or sustained, requiring formal assistance
(e.g., agreeing on a new repayment plan, loan refinancing, or bankruptcy arrangements).
Banks generally offer customers financial literacy information and tools for budgeting and
expenditure tracking, and referrals to free financial counselling services (CBA, 2018c). The
number of customers provided with hardship assistance during 2017, reported by each of
Australia’s four major banks, ranged from 19,652 to over 72,000 (ANZ, 2017a; CBA, 2017c;
NAB, 2017b; Westpac, 2017). The ABA (2016) sets industry guidelines for hardship
assistance to provide a framework for consistent decision-making; however, each bank has its
own policies and procedures. This means that the solutions offered differ depending on the
financial institution and personal circumstances.
Although many banks invest substantial resources in hardship assistance programs,
few list gambling as a risk factor in their policies. This is despite well-documented financial
harms associated with problem gambling. Financial institutions typically describe
circumstances or events precipitating hardship as ‘unforeseen or unexpected (ABA, 2016).
Commonly cited examples include job loss, relationship breakdown, illness, or natural
disaster. Based on most banks’ financial hardship policy documents, it is not clear how banks
would respond to requests for assistance from customers reporting gambling-related hardship.
Despite that, some banks provide links to problem gambling support services on their
websites. For customers seeking to proactively manage their gambling activity, banks
generally offer the ability to block international transactions, contactless card payments, and
ATM cash advances on credit cards, as well as options to set transaction and overall
expenditure limits (e.g., CBA, 2018a). Some Australian financial institutions (e.g., ANZ,
2002; Westpac, n.d.-c) offer credit cardholders the option to block gambling transactions
registered under the MCC ‘Betting/Casino Gambling’. In June 2018, Starling Bank Limited
announced that they were “the first UK bank” (para. 7) to enable customers to block card-
based gambling-related transactions. This option is now also offered by Barclays Bank UK
PLC (n.d.) and Monzo Bank Limited (2018). Within the first four months of Monzo Bank
making the option available, more than 25,000 customers were reported to opt-in, of which
about 8,000 reported a history of gambling (Whitworth & Beazley, 2018). Monzo Bank has
reported a 70% reduction in the gambling transactions of these customers (Whitworth &
Beazley, 2018).
The behavioural economics perspective
What should the role of financial institutions be in gambling? Who is primarily responsible
for consumer gambling debt: lenders, regulators, or the consumers themselves? Issues such as
these remain contentious, particularly in the public discourse between banks and consumer
protection advocates. Financial institutions currently appear to take an individual-focused
approach to consumer gambling behaviour. Fear and O’Brien (2009) suggest that financial
institutions are typically of the view that individuals must shoulder the consequences of their
own choices’ (p. 4). Most banks rely upon the individual customer to request financial
hardship assistance, rather than proactively identifying financially vulnerable customers and
offering assistance (CBA, n.d.). This approach, which relies on individuals taking action
themselves to resolve their problems, tends to align with the ‘addiction model of gambling.
This model conceptualises problem gambling similarly to substance abuse disorders.
Behavioural economics presents an alternative by framing gambling behaviour as a public
health issue. This alternative provides a theoretical basis for government and institutions to
develop policy at the population level with potentially preventative effects.
Altman (2012) has argued for the value of behavioural economics over conventional
economic theory for public policy relating to financial literacy. Financial literacy involves
possessing the competencies required to make responsible financial decisions (Altman,
2012). This subject has received very little direct attention within the context of gambling.
Altman (2012) draws upon the work of Kahneman and Tversky (1984) and Simon (1978) to
demonstrate the limitations of conventional economic wisdom in assuming human rationality
in decision-making. Assuming the individual’s capacity for optimal decision-making, the
conventional approach sees little theoretical basis for government or institutional
interventions. However, this approach lacks consistency with real-world human decision-
making. In reality, humans often have incomplete or poor information to work with and make
decisions with less rationality than ascribed by conventional theory. The behavioural
economics model posits that humans are systematically biased or error-prone in their
decision-making as a result of heuristics, or cognitive decision-making short-cuts. To
compensate for these biases, which can lead to sub-optimal decisions, behavioural economics
proposes a greater role for government and institutions in creating environments that nudge
individuals towards better decisions (Thaler & Sunstein, 2008). Altman argues that policy
interventions are critical for reducing the information asymmetries that often exist with
financial products. Credit card interest rate policies, for instance, should be written in plain
language easily understood and used by consumers to make informed decisions.
There is a need for further discourse around the application of this same logic to
financial institutions’ policies regarding consumer gambling behaviour. For example,
customers are currently offered the option of reducing ATM withdrawal limits, but banks
require an explicit instruction from the customer to do so (Productivity Commission, 2010a).
A survey of approximately 200 problem gamblers by the Productivity Commission (2010b)
found that 86% of respondents had never contacted their financial institution to lower their
ATM withdrawal limit. Only 18% nearly always or often left their ATM or credit cards at
home as a self-control strategy. This suggests that the current reactive approach, relying on
customers with gambling problems to manage their expenditure and request financial
hardship assistance, may be largely ineffective in promoting customer wellbeing.
Furthermore, the ABA’s (2016) guidelines on financial hardship state that customers are
usually already in arrears when banks become aware of their financial hardship, yet they also
acknowledge that customers may be reluctant to seek assistance from banks. This reluctance
may be driven by factors such as embarrassment, guilt, shame, fear, denial, or concern that
the disclosure would affect credit ratings. The tension between banks’ practices relating to
initiation of financial hardship assistance and the reality of customers’ personal
circumstances appears to thwart customers’ ability to access support. Banks may be
neglecting their ability to initiate contact with customers identified as experiencing financial
hardship under clause 28.4 of the Code of Banking Practice (2013). The ABA guidelines
state that ‘ultimately, customers are best placed to know whether they are struggling
financially (p. 14). However, given the complexity and information asymmetry that
characterise many financial products, behavioural economics would suggest it is not so
simple. Hurla et al. (2017) have provided a thorough review of findings from financial
literacy programs to draw implications for strategic interventions promoting responsible
gambling. Interventions are recommended to target three key behaviours associated with
responsible gambling: setting limits, tracking behaviour, and impulse control. Setting and
adhering to limits is a common method of self-regulation amongst gamblers. As gambling
involves distributed choice, tracking a series of decisions to gamble over time and making the
aggregate expenditure salient to the customer can help them evaluate the extent of their
spending. Targeting problem gamblers’ impulses to repeatedly choose immediate rewards
despite their combined sub-optimal value over time is also fundamental to promoting
responsible gambling choices. Key to these three strategies is their timing, which rests
theoretically on the importance of context in framing a choice between various options, such
as whether to continue gambling or to pursue a different activity (Tversky & Kahneman,
1981). Smartphone apps are a promising avenue for financial institutions to integrate
responsible gambling intervention strategies that assist customers in making more prudent
decisions. Tools such as CBA’s Spend Tracker utilise customer behavioural data to provide
real-time personalised feedback to engage customers in better managing their finances (Hurla
et al., 2017). Customers could be prompted to set a limit, as well as receive real-time alerts
and track overall expenditure tied to gambling-related transactions. A randomised controlled
experiment by Stewart and Wohl (2013) demonstrated the effectiveness of pop-up reminders
in facilitating adherence to monetary limits pre-set by slot machine players. Ninety percent of
participants receiving reminders stayed within their limit, contrasted to only 43% of
participants not receiving the reminders. Hurla et al. suggest sending gamblers notifications
centred around tangible items of equivalent value to their gambling losses could aid
visualisation of alternatives to gambling (e.g., “You just lost the equivalent of buying a new
laptop”). Whilst a financial institution’s app could not feasibly report a gambler’s losses,
notifications could focus on gambling expenditure in relation to pre-set limits. Hurla et al.
suggest that social influences could also be used to drive responsible gambling behaviour.
Customers with joint bank accounts could be given the option for their partner to receive
alerts triggered by in-venue ATM withdrawals and gambling-related transactions could be
made more apparent on credit card statements. Real-time app-based strategies overcome
concerns around the ineffectiveness of financial literacy education programs due to memory
decay. However, Shefrin and Nicols (2014) finding that 25% of credit cardholders report
low confidence in managing their finances using online technologies indicates that apps may
not be used by all consumers. Nonetheless, this strategy presents an opportunity to nudge
customers engaging in gambling activity towards responsible gambling behaviour. Doing so
is in the interests of financial institutions, acting as a preventive measure against customers
falling into financial difficulty, and is part of their corporate responsibility.
Another key opportunity for change is financial institutions’ policy on credit
provision for gambling-related transactions. From a behavioural economics standpoint,
permitting problem gamblers to use credit to fund gambling transactions is risky. Gambling
decisions are intertemporal in nature, as are credit card transactions (Chan, Soman, &
Cheema, 2011; Loewenstein & Thaler, 1989). The financial consequences of a consumer’s
choice to enjoy the immediate gratification of a gamble are delayed in time from their
original decision. As humans are typically myopic in their preferences, it is not surprising
that problem gamblers commonly have credit card debt running into the tens of thousands of
dollars (FCA, 2017; Hurla et al., 2017). Ali, McRae, and Ramsay (2012) suggest that
consumers, especially those vulnerable to financial hardship, may exhibit behavioural biases
in relation to optimism and imperfect self-control resulting in underestimations of their
capacity to meet repayment obligations. Provision of targeted consumer-specific information
over existing disclosure-based regulation is suggested to assist vulnerable customers in
making prudent financial decisions.
Financial institutions should also have policies to guide responses to customers self-
disclosing gambling problems. This would involve creating action plans for customer-facing
staff (e.g., telephone support staff, branch staff) to identify specific trigger words and respond
appropriately. Responses may include referral to specially-trained financial assistance staff
and gambling treatment and support services. Disclosures should be communicated
throughout the various bank departments, for example, to ensure that the customer does not
receive marketing communications offering credit limit increases. Policies should be
established for addressing disclosures made by concerned family members. Appropriate
training regarding gambling and related harms for customer-facing bank staff and
management would assist in developing a culture that is responsive to gambling harms.
Finally, financial institutions may follow the lead of some wagering operators by
developing algorithms to detect potentially risky gambling transactions. Casinos Austria AG
(2016), for example, uses a behavioural tracking tool to monitor indicators of risky gambling
activity, such as the frequency and amount of monetary transactions. If particular risk
thresholds are met, the operator obtains a credit report for the customer, who is invited to
meet with specially-trained casino staff to review their gambling activity. Development of
machine learning approaches may involve working with gambling researchers to identify
specific behavioural indicators, such as repeated and increasing transactions with gambling
operators, accessing credit on multiple occasions, instances of failing to make appropriate
repayments or repeatedly making the minimum repayment, and fees from other merchants
indicating failure to pay bills. Evaluation would be needed to verify the accuracy of any
algorithm and detection systems. Policies would need to be developed to guide action when
suspected risky gambling is detected, which would likely involve contacting the customer.
Initial work completed by the gambling industry may be helpful to guide these developments.
Limitations and future directions
As it was not possible to review banks’ internal policies and practices relating to consumer
gambling activity, this paper is limited in its scope for evaluating the status quo within the
industry. This review provides an overall picture of the discourse to date within both the
academic and public domains. The findings have implications for policy makers within
government and institutional settings. In-depth case studies would be valuable in providing
insight into the interpretation and implementation of CSR strategies relating to consumer
gambling activity within specific financial institutions. Qualitative methodologies, such as
interviews and focus groups, could be useful to gain a better understanding of the underlying
issues concerning both financial institutions and consumers. For example, it would be useful
to understand specific barriers to customers disclosing gambling-related problems to financial
institutions, as well as the confidence of bank staff in handling such disclosures. The
prevalence of consumers who fall into debt as a result of using credit to fund their gambling
activity requires further investigation, including credit provided by financial institutions,
gambling operators, and payday lenders. Future research should focus on developing
effective interventions that assist financially vulnerable customers in making better decisions
related to gambling for their long-term interests, whilst not obstructing the freedoms of those
who use credit and gamble responsibly. The use of customer behavioural data for such
interventions is a promising avenue warranting in-depth investigation.
Financial institutions play a fundamental role in consumer gambling activity, whether
through providing access to cash for offline gambling transactions, or via electronic funds
transfer for online gambling. This presents an opportunity for financial institutions to
implement harm-minimisation strategies, complementing interventions provided by industry
and regulators. Currently, most financial institutions appear to lack policies on gambling,
including strategies to identify and assist financially vulnerable consumers with gambling
problems. Financial institutions appear to be largely of the view that they have little business
in how customers spend their money (excluding fraud and other illicit activity), regardless of
whether customers are spending their own savings or using credit. This view seems to align
with public expectations and banks’ regulatory obligations, especially in relation to consumer
privacy standards. From a public health standpoint, however, banks do have a certain level of
responsibility for how customers use their money. Financial institutions are able to
compensate for bias in decision-making, which is fundamental to problem gambling
behaviour. A measured approach is needed that enables customers to engage in gambling at
an appropriate level, whilst providing those experiencing gambling-related harms with
options that do not rely solely on self-enactment by such customers.
Abbott, M. W., Romild, U., & Volberg, R. A. (2014). Gambling and problem gambling in
Sweden: Changes between 1998 and 2009. Journal of Gambling Studies, 30(4), 985
Ali, P., McRae, C., & Ramsay, I. (2012). Consumer credit reform and behavioural
economics: Regulating Australia’s credit card industry. Australian Business Law
Review, 40(2), 126133.
Ali, W., Frynas, J. G., & Mahmood, Z. (2017). Determinants of corporate social
responsibility (CSR) disclosure in developed and developing countries: A literature
review. Corporate Social Responsibility and Environmental Management, 24(4),
Altman, M. (2012). Implications of behavioural economics for financial literacy and public
policy. The Journal of Socio-Economics, 41(5), 677690.
Australia and New Zealand Banking Group Limited. (2002). Commercial cards Merchant
Category Code controls. Retrieved from
Australia and New Zealand Banking Group Limited. (2015). ANZ policies. Retrieved from
Australia and New Zealand Banking Group Limited. (2017a). 2017 corporate sustainability
review. Retrieved from
Australia and New Zealand Banking Group Limited. (2017b). ANZ credit cards: Conditions
of use. Retrieved from
Australian Bankers’ Association Inc. (2016). Promoting understanding about banks’
financial hardship programs. Retrieved from
Australian Communications and Media Authority. (2018). Interactive Gambling Act reforms.
Retrieved from
Australian Transaction Reports and Analysis Centre. (2011). Money laundering in Australia
2011. Retrieved from
Bank Australia Limited. (2017). Have your say - credit cards and online gambling. Retrieved
Bank of Melbourne. (n.d.). Partnerships. Retrieved from
Bank of Queensland Limited. (n.d.-a). Approach to sustainable lending. Retrieved from
Bank of Queensland Limited. (n.d.-b). Sponsorships. Retrieved from
Barclays Bank UK PLC. (n.d.). Coping with gambling addiction: Is your gambling out of
control? Retrieved from
Bendigo and Adelaide Bank Limited. (2016). Bendigo Socially Responsible Growth Fund.
Retrieved from
Blaszczynski, A., Anjoul, F., Shannon, K., Keen, B., Pickering, D., & Wieczorek, M. (2015).
Gambling harm minimisation report (No. DTIRIS 13/23). The University of Sydney.
Retrieved from
Bradney-George, A. (2017, October 27). Gambling transactions using your credit card.
Retrieved from
Byres, W. (2017, September). Key issues for the year ahead: Bank capital and the
approaching BEAR. Presented at the ‘The Regulators’ Finsia event, Sydney.
Retrieved from
Capgemini, & BNP Paribas. (2017). World payments report 2017. Retrieved from
Casinos Austria AG. (2016). Recipes for success: Annual report 2016. Retrieved from
Castelo, B. M. (2013). Banks and CSR. In Encyclopedia of Corporate Social Responsibility
(pp. 141148). Springer. Retrieved from
Chan, E. Y., Soman, D., & Cheema, A. (2011). Understanding consumer psychology to avoid
abuse of credit cards. In Transformative consumer research for personal and
collective well-being (pp. 423444). Retrieved from
Commonwealth Bank of Australia. (2003). ATMs located in gambling venues. Retrieved
Commonwealth Bank of Australia. (2017a). An easy guide to our credit card fees and
charges. Retrieved from
Commonwealth Bank of Australia. (2017b). Commbank credit card conditions of use.
Retrieved from
Commonwealth Bank of Australia. (2017c). Corporate responsibility report 2017. Retrieved
Commonwealth Bank of Australia. (2018a). Control the things you can with Lock, Block,
Limit®. Retrieved from
Commonwealth Bank of Australia. (2018b). Policies and practices. Retrieved from
Commonwealth Bank of Australia. (2018c). Spend tracker and insights. Retrieved from
Commonwealth Bank of Australia. Financial hardship arrangements, § Standing Committee
on Economics. Retrieved from
Conneller, P. (2018). German gamblers not required to repay credit card transactions used
for illegal gambling, court rules. Retreived from
Darus, F., Mad, S., & Nejati, M. (2015). Ethical and social responsibility of financial
institutions: Influence of internal and external pressure. Procedia Economics and
Finance, 28, 183189.
Department of Broadband, Communications and the Digital Economy. (2012). Final report
2012: Review of the Interactive Gambling Act 2001. Retrieved from
Department of Social Services. (2016). Government response to the 2015 Review of the
Impact of Illegal Offshore Wagering. Retrieved from
Department of Social Services. (2017). A national consumer protection framework for online
wagering in Australia: Regulation impact statement for consultation (No. DSS
2128.05.17). Retrieved from
Doyle, M.-A., Fisher, C., Tellez, E., & Yadav, A. (2017). How Australians pay: New survey
evidence (Bulletin) (pp. 5965). Reserve Bank of Australia. Retrieved from
Drentea, P., & Reynolds, J. R. (2012). Neither a borrower nor a lender be: The relative
importance of debt and SES for mental health among older adults. Journal of Aging
and Health, 24(4), 673695.
Etches, M. W. (2018, January 22). Consultation on proposals for changes to Gaming
Machines and Social Responsibility Measures. Retrieved from
Farnsworth, S., & Selvaratnam, N. (2018, February 11). Should banks offer credit to problem
gamblers? Royal commission urged to investigate. Australian Broadcasting
Corporation. Retrieved from
Fear, J., & O’Brien, J. (2009). Where does the buck stop? Community attitudes to over-
lending and over-spending. Australasian Accounting, Business and Finance Journal,
3(1), 311.
Fidelie, L. W. (2009). Internet gambling: Innocent activity or cybercrime? International
Journal of Cyber Criminology, 3(1), 476491.
Financial Counselling Australia. (2017). An inquiry into consumer protection in the banking,
insurance and financial sector: Submission 91. Retrieved from
Financial Crisis Inquiry Commission. (2011). The Financial Crisis Inquiry Report: Final
report of the National Commission on the Causes of the Financial and Economic
Crisis in the United States. Retrieved from
Fitch, C., Chaplin, R., Trend, C., & Collard, S. (2007). Debt and mental health: The role of
psychiatrists. Advances in Psychiatric Treatment, 13(3), 194202.
Gainsbury, S. (2012, June 25). Response to the Interim Report of the review of the Interactive
Gambling Act 2001. Retrieved from
Gainsbury, S., & Blaszczynski, A. (2017). How blockchain and cryptocurrency technology
could revolutionize online gambling. Gaming Law Review, 21(7), 482492.
Gainsbury, S., Hing, N., Blaszczynski, A., & Wood, R. (2011). An investigation of internet
gambling in Australia. Southern Cross University. Retrieved from
Gainsbury, S., Russell, A., Hing, N., Wood, R., Lubman, D. I., & Blaszczynski, A. (2014).
The prevalence and determinants of problem gambling in Australia: Assessing the
impact of interactive gambling and new technologies. Psychology of Addictive
Behaviours, 28(3), 769779.
Goodwin, B. C., Browne, M., Rockloff, M., & Rose, J. (2017). A typical problem gambler
affects six others. International Gambling Studies, 17(2), 276289.
Griffiths, M. (2007). Consumer debt in Australia: Why banks will not turn their backs on
profit. International Journal of Consumer Studies, 31(3), 230236.
Griffiths, Mark, & Barnes, A. (2008). Internet gambling: An online empirical study among
student gamblers. International Journal of Mental Health and Addiction, 6(2), 194
Härle, P., Havas, A., Kremer, A., Rona, D., & Samandari, H. (2015). The future of bank risk
management. Retrieved from
Hartzer, B. Review of Australia’s four major banks, § Standing Committee on Economics
(2017). Canberra, Australia. Retrieved from
Hincer, I. (2016). Gaming in Canada: Overview. Retrieved from
Hossack, N. (2012, December 6). Inquiry into the prevention and treatment of problem
gambling. Retrieved from
Hurla, R., Kim, M., Singer, E., & Soman, D. (2017). Applying findings from financial
literacy to encourage responsible gambling (Behavioural Economics in Action).
University of Toronto. Retrieved from
iBus Media Limited. (2011). Joint Select Committee on Gambling Reform: Inquiry into the
Interactive Gambling and Broadcasting Amendment (Online Transactions and Other
Measures) Bill 2011. Retrieved from
Kahneman, D., & Tversky, A. (1979). Prospect theory: An analysis of decision under risk.
Econometrica, 47(2), 263291.
Kahneman, D., & Tversky, A. (1984). Choices, values, and frames. American Psychologist,
39(4), 341350.
Kratzke, N., & Depperschmidt, T. (2006). Credit card advances: The impact on gambling
bankruptcies. Gaming Law Review, 2(3), 257265.
Labour calls for ban on gambling ads during live events. (2018, September 20). BBC.
Retrieved from
Laughlin, I. (2018). Social risks - for a financial services business. Actuaries Institute.
Retrieved from
Leonard, B. M. (2008). Highlighting the drawbacks of the UIGEA: Proposed rules reveal
heavy burdens. Drake Law Review, 57(2), 515545.
Leung, T. C. H., & Snell, R. S. (2017). Attraction or distraction? Corporate social
responsibility in Macao’s gambling industry. Journal of Business Ethics, 145(3), 637
Lindorff, M., Prior Jonson, E., & McGuire, L. (2012). Strategic corporate social
responsibility in controversial industry sectors: The social value of harm
minimisation. Journal of Business Ethics, 110(4), 457467.
Loewenstein, G., & Thaler, R. (1989). Anomalies: Intertemporal choice. The Journal of
Economic Perspectives, 3(4), 181193.
Marconi, A. L., & McQuaid, B. M. (2007). Betting and buying: The legality of facilitating
financial payments for Internet gambling. Banking Law Journal, 124(6), 483511.
Marin, L., Ruiz, S., & Rubio, A. (2009). The role of identity salience in the effects of
corporate social responsibility on consumer behavior. Journal of Business Ethics,
84(1), 6578.
Miller, J. A. (2008). Don’t bet on this legislation: The Unlawful Internet Gambling
Enforcement Act places a bigger burden on financial institutions than Internet
gambling. North Carolina Banking Institute, 12(1), 185220.
Miller, R., & Michelson, G. (2013). Fixing the game? Legitimacy, morality policy and
research in gambling. Journal of Business Ethics, 116(3), 601614.
Monzo Bank Limited. (2018). Block gambling transactions from your Monzo account.
Retrieved from
Münchenberg, S. (2011, May 9). Inquiry into the Interactive Gambling and Broadcasting
Amendment (Online Transactions and Other Measures) Bill. Retrieved from
Narev, I. Review of Australia’s four major banks, § Standing Committee on Economics
(2017). Canberra, Australia. Retrieved from
National Australia Bank Limited. (2016). NAB credit cards. Retrieved from
National Australia Bank Limited. (2017a). Corporate responsibility. Retrieved from
National Australia Bank Limited. (2017b). Sustainability report 2017. Retrieved from
National Australia Bank Limited. (n.d.). NAB Group sponsorship guidelines. Retrieved from
OECD. (2011). Illegal Internet gambling. In The role of Internet intermediaries in advancing
public policy objectives (pp. 133142). Paris: OECD Publishing. (2018, January 28). UK charity calls for ban on online credit card
deposits. Retrieved from
PricewaterhouseCoopers. (2016). Banking matters: Major banks analysis. Retrieved from
Prior Jonson, E., Lindorff, M., & McGuire, L. (2012). Paternalism and the pokies:
Unjustified state interference or justifiable intervention? Journal of Business Ethics,
110(3), 259268.
Productivity Commission. (2010a). Gambling: Productivity Commission inquiry report
(Volume 1). Retrieved from
Productivity Commission. (2010b). Gambling: Productivity Commission inquiry report
(Volume 2). Retrieved from
Reserve Bank of Australia. (2014). Submission to the Financial System Inquiry. Retrieved
Reserve Bank of Australia. (2018). Statistical table C1: Credit and charge card statistics.
Retrieved from
Responsible Gambling Strategy Board. (2018). RGSB advice on remote gambling. Retrieved
Riffkin, R., & Jalajel, A. (2015). Customers want banks to improve their financial well-being.
Retrieved from
Royal Commission into Misconduct in the Banking, Superannuation and Financial Services
Industry. (2018). Some features of the Australian banking industry. Retrieved from
Scholtens, B. (2009). Corporate social responsibility in the international banking industry.
Journal of Business Ethics, 86(2), 159175.
Shah, A. K., Mullainathan, S., & Shafir, E. (2012). Some consequences of having too little.
Science, 338(6107), 682-685.
Shannon, K., Anjoul, F., & Blaszczynski, A. (2017). Mapping the proportional distribution of
gambling-related harms in a clinical and community sample. International Gambling
Studies, 17(3), 366385.
Shefrin, H., & Nicols, C. M. (2014). Credit card behavior, financial styles, and heuristics.
Journal of Business Research, 67(8), 16791687.
Simon, H. A. (1978). Rationality as process and as product of thought. The American
Economic Review, 68(2), 116.
South Australian Financial Counsellors Association. (2016, February 12). Big four banks
profiting from problem gambling. Retrieved 28 November 2017, from
St. George Bank. (n.d.). How to apply for sponsorship. Retrieved from
Standard Chartered. (n.d.). Standard Chartered position statement: Gambling. Retrieved
Starling Bank Limited. (2018). Introducing: Merchant blocking for gambling and betting.
Retrieved from
Stewart, M., & Wohl, M. (2013). Pop-up messages, dissocation, and craving: How monetary
limit reminders facilitate adherence in a session of slot machine gambling.
Psychology of Addictive Behaviors, 27(1), 268273.
Tate, D. (2016). Inquiry into the Interactive Gambling Amendment (Sports Betting Reform)
Bill 2015. Retrieved from
Thaler, R. (1980). Toward a positive theory of consumer choice. Journal of Economic
Behavior and Organization, 1(1), 3960.
Thaler, R., & Johnson, E. (1990). Gambling with the house money and trying to break even:
The effects of prior outcomes on risky choice. Management Science, 36(6), 643660.
Thaler, R., & Sunstein, C. (2008). Nudge: Improving decisions about health, wealth, and
happiness. New York: Penguin Books.
The Allen Consulting Group. (2009). Review of current and future trends in interactive
gambling activity and regulation. Retrieved from
Tversky, A., & Kahneman, D. (1981). The framing of decisions and the psychology of
choice. Science, 211(4481), 453458.
UCA Funds Management. (2016, January 12). Big four banks profiting from problem
gambling. Retrieved from
U.S. Department of Justice. (2007). Seven individuals and four companies indicted for
operating illegal credit card transaction, processing business; Defendents allegedly
provided services to disguise credit card charges for internet gambling. PR Newswire.
Retrieved from
Wardle, H., Griffiths, M. D., Orford, J., Moody, A., & Volberg, R. A. (2012). Gambling in
Britain: A time of change? Health implications from the British Gambling Prevalence
Survey 2010. International Journal of Mental Health and Addiction, 10(2), 273277.
Welte, J. W., Barnes, G. M., Tidwell, M.-C. O., Hoffman, J. H., & Wieczorek, W. F. (2015).
Gambling and problem gambling in the United States: Changes between 1999 and
2013. Journal of Gambling Studies, 31(3), 695715.
Westpac Banking Corporation. (2017). Combined conditions of use and credit guide.
Retrieved from
Westpac Banking Corporation. (n.d.-a). Our positions and perspectives. Retrieved from
Westpac Banking Corporation. (n.d.-b). Sponsorship guidelines and opportunities. Retrieved
Westpac Banking Corporation. (n.d.-c). Gambling preference. Retrieved from
Westpac Group. (2017). 2017 Westpac Group annual review and sustainability report.
Retrieved from
Whitworth, D., & Beazley, O. (2018, October 5). Gambling: 'A banking app helped me beat
my addiction'. BBC. Retrieved from
... Payment gateways are tech-based gobetween payment providers used by merchants to process online financial transactions and purchases. A body of literature suggested that 'payment institutions with gambling customers lack compressive policies and strategies' to assist financially vulnerable users (Swanton et al. 2019;Hurla et al., 2017). Even though a broader, strategy-level implementation of intervention tools has started to gain some traction (Collins et al., 2015;Hansen & Rossow, 2008;Lund, 2008), there exists scant research that explores the implementation of "non-operator based" harm-minimization tools. ...
... This can create an environment where small and often times unregulated payment gateways filling the gap as a conduit for betting and payouts for gambling activities. (Marconi & McQuaid, 2007;Swanton et al., 2019). Nonetheless, individuals' financial well being based on their gambling activities is hardly considered as an issue as long as the activity in itself is deemed 'legal'. ...
... Second, when it comes to gambling, the current trend suggests that economic incentives take preceding over strict regulations for financial institutions. Despite a wellestablished evidence of financial harm, the financial sector seems to be more concerned with 'mitigating corporate risks and reputation than individual's financial hardship' that results from gambling (Swanton et al., 2019). In addition, governmental institutions routinely pass bills for an establishment of gambling facilities to boost tourism and local economies (Watanapongvanich et al., 2020). ...
Full-text available
Traditional approaches that seek to study Responsible Gambling (RG) mainly focus on evaluating platform-based intervention tools applied on gambling operator sites. This paper reports on the implementation, at the payment-solution level, of an intervention tool that gambling customers used to deposit their bets. The approach pre-commits customers to set a single-point spending limit on their payment gateway account, effectively enabling them to apply their budget setting on all gambling platforms on which they choose to play. Ten users who have used the provision for at least six months and on two different gambling platforms were selected for an in-depth interview. Based on the findings from content analysis, the article argues that payment-level intervention approach can potentially (1) provide the overall gambling population with better financial literacy regarding their gambling habits, which promotes responsible spending behaviour, (2) elevate the strain on users to set up intervention tools on every individual platform, and (3) serve as a preventive measure regardless of the existence or absence of intervention tools at gambling sites. Furthermore, the results affirm a gap in existing research and a need for comprehensive guidelines and strategies for financial institutions to positively contribute towards the agenda of RG. The findings of this study highlight the need for revisiting theoretical and philosophical foundations of intervention tool studies and gambling policymaking as well as calls for reassessing how we problematised harmful gambling. The paper contributes to the research on gambling intervention tools.
... If the problem instead is located within the individual consumer as incapable, irresponsible and lacking in selfcontrol, the responsibility and accountability is thereby assigned to the gambler him-/herself. This responsibilization process has the potential consequence that the gambler internalizes the blame (Alexius, 2017), without taking into consideration the gambling industry's role in designing and selling harmful products (i.e., Orford, 2019), the banking sector's inclination to offer fast loans with high interest (i.e., Swanton, Gainsbury, & Blaszczynski, 2019), and the failure of the government to regulate the gambling market to prevent harm on the population level (i.e., Adams & Rossen, 2012). Excessive gambling habits and the negative consequences that follow are often associated with feelings of shame and guilt and stigma. ...
... But rather than directing responsible gambling measures toward individual gamblers, there is still a clear need for increased population-level prevention of gambling problems in Japan. Such universal measures could include limiting access to gambling opportunities and restricting marketing, credits, and loans (see Swanton et al., 2019), or imposing demands of identification (see, e.g., Sulkunen et al., 2019). Support and treatment for gamblers and their significant others should be easily available, but it is the gambling products and the gambling market that should be regarded as the main problems, rather than the individual gamblers. ...
Full-text available
Japan has one of the highest rates of severe gambling problems in the world. However, the gambling forms that cause the most harm—pachinko and pachislot—are not recognized as gambling in the key legislation. They are understood as entertainment. On the basis of two group interviews with those who have experienced problems with gambling, this study explores how they have dealt with the shame, guilt, and stigma of pachinko-related gambling problems. The narrative analysis shows that the participants carry self-stigma as a result of self-reproach and others’ condemnation of their behavior. Feelings of shame, guilt, and fear of being stigmatized have distinctly hindered the process of seeking help. The participants describe how their gambling, which they had attempted to limit, had led to isolation from normal life. The isolation and the failures to control the gambling increased their feelings of shame and destructive behavior. Considering the characteristics of the zone, the loss of self, and the shame, guilt and stigma of failing to control excessive pachinko gambling, it is unreasonable to place the main responsibility on the individual gambler. To reduce gambling harms in Japan and the stigma associated with pachinko and pachislot problems, these gambling forms need to be acknowledged as public health concerns and categorized as gambling in the legislation.
... Some concepts from gambling surveillance might also apply the other way around (see Griffiths, 2015, 2021). Financial institutions that process transactions from gambling are also in a key position to monitor irregular spending that might result from problematic gambling behavior (Swanton et al., 2019). Nevertheless, such practices will only enter the market if some level of regulation is present. ...
Full-text available
This article discusses similarities between the finance industry and the gambling industry. It considers empirical studies from both fields and compares both industries with regard to possible substitution effects. Afterwards, the current regulatory approach to gambling and financial markets is discussed. Based on this literature review, the author points out that regulators need to acknowledge the fact that both markets possess addictive properties and attract certain risk-seeking individuals. Moreover, the regulators need to find a way to align their fundamentally different objectives to find common solutions to cross-industry problems. Finally, an increased cooperation between (state) authorities is necessary. This cooperation could help to protect traders from developing gambling-related problems, provide significant insights for industry-wide and product-specific regulation and lead to a more informed use of technology for harm prevention purposes. The most important similarities and differences of both markets and the resulting regulatory implications are briefly summarized.
... The four major Australian banks, accounting for almost 75% of all lending in the country, allow most gambling transactions on credit cards. In addition, banks regularly provide credit cards, personal loans, and overdrafts to known gamblers (Swanton et al., 2019), with several prominent cases featured in mainstream media. 6 Against this backdrop, one of the four major banks recently implemented a gambling-reduction program-a variety of measures aimed at curbing gambling behavior among a small group of "problem gamblers." ...
Algorithmic decision-making systems (ADMS) are increasingly being used by public and private organizations to enact decisions traditionally made by human beings across a broad range of domains, including business, law enforcement, education, and healthcare. Their growing prevalence engenders profound ethical challenges, which, we maintain, should be examined in a structured and theoretically informed fashion. However, much of the ethical exploration of ADMS within the IS field draws upon an atheoretical application of ethics. In this paper, we argue that the “big three” ethical theories of consequentialism, deontology, and virtue ethics can inform a structured comparative analysis of the ethical significance of ADMS. We demonstrate the value of such an approach through an illustrative case study of an ADMS in use by an Australian bank. Building upon this analysis, we address four characteristics of ADMS from the three theoretical perspectives, provide guidance on the contexts within which the application of each theory might be particularly fruitful, and highlight the advantages of theoretically grounded ethical analyses of ADMS.
... Credit card transactions utilize credit from a financial institution that is repaid with incurred interest, typically through monthly statements. Gambling transactions on a credit card may be processed as cash withdrawals, which can incur higher interest rates (Swanton et al., 2019). ...
Full-text available
Gambling involves monetary bets and prizes, but the money can take a range of formats, including cash, chips, ticket-in ticket-out vouchers, and digital options including banking cards. As societies move toward cashless payment for many goods, the question arises of how emerging payment technologies might impact gambling-related harms. We performed a scoping review following PRISMA guidelines to identify research testing the effects of monetary format in gambling. Our eligibility criteria focused on controlled experimental manipulations, to best establish the causal impact of monetary format. We sought to characterize different types of monetary manipulations that have been studied in a gambling context. We identified 19 eligible articles, comprising 23 individual experiments. These experiments were organized according to four distinct manipulations. The most common design (12 experiments), compared gambling under the presence or absence of money. Smaller numbers of experiments were identified manipulating monetary salience, testing Responsible Gambling tools, and testing the impact of promotional inducements. We identified no studies that compared gambling using cash against digital payment forms. Our review highlights a paucity of research testing the possible impact of digital and cashless payment options on gambling related harms, using experimental designs that would permit causal conclusions to be drawn.
... There has also been increased interest in the extent to which financial institutions can add a valuable source of gambling-related data due to the ability to track expenditure across multiple types of gambling (e.g., online and casino). Swanton et al. (2019) have suggested that financial institutions could take a more active role in informing customers about their gambling expenditure, and our findings support the value of this strategy. ...
Objectives: The ability to accurately recall past gambling behavior and outcomes is essential for making informed decisions about future gambling. We aimed to determine whether online gambling customers can accurately recall their recent gambling outcomes and betting frequency. Method: An online survey was distributed to 40,000 customers of an Australian sports and race wagering website which asked participants to recall their past 30-day net outcome (i.e., total amount won or lost) and number of bets. We compared responses to these questions with participants' actual outcomes as provided by the online site. Results: Among the 514 participants who reported their net outcome, only 21 (4.09%) were accurate within a 10% margin of their actual outcome. Participants were most likely to underestimate their losses (N = 333, 64.79%). Lower actual net losses were associated with greater underestimation and overestimation of losses. Of the 652 participants who reported their gambling frequency, 48 (7.36%) were accurate within a 10% margin of their actual frequency. Most participants underestimated their number of bets (N = 454, 69.63%). Higher actual betting frequencies were associated with underestimating betting and lower actual frequencies with overestimating betting. Conclusions: The poor recall accuracy we observed suggests public health approaches to gambling harm minimization that assume people make informed decisions about their future bets based on past outcomes and available funds should be reconsidered. Findings also question the reliability of research outcomes predicated on self-reported gambling behavior. Research is needed to determine the best methods of increasing people's awareness of their actual expenditure and outcomes. (PsycInfo Database Record (c) 2021 APA, all rights reserved).
... identify problematic gambling patterns Swanton et al., 2019). Debt size affects gambling behaviour (Crewe-Brown et al., 2014), and gamblers who find themselves unable to meet their financial obligations consequently experience higher psychological distress (Oksanen et al., 2018). ...
Full-text available
Online gambling has significantly altered the situational and structural characteristics of gambling products, to the extent that online gamblers might be substantially different from traditional offline gamblers. A growing body of literature has identified the evolving features of online gambling and the individuals who engage in it. However, beyond understanding the individual characteristics of this subgroup, relatively less effort has been made to examine whether existing cognitive-behavioural therapy (CBT) approaches are still entirely relevant for online problem gamblers, or whether changes are needed to adapt according to gambling mode of access. To understand what kind of challenges online gambling poses to mental health professionals dealing with disordered gamblers, four focus groups comprising 28 Spanish participants were carried out. All the treatment providers had ongoing experience with online gamblers undergoing treatment, and included clinical psychologists, mental health social workers, and a medical doctor. The data were examined using thematic analysis. The analysis identified five main themes that characterised online gamblers: (1) being of younger age, (2) lack of conflicts at home and at work/educational centre, rarely presenting violent or aggressive behaviour, (3) gambling disorder only being identified by overdue debt, (4) co-occurring conditions with technology-related abuse rather than other substance-related addictions, and (5) skill-based gambling. The study highlights mental health workers’ perceived insecurities about how to best treat online gamblers, and discusses the specific characteristics that CBT for gambling disorder might need to incorporate to adjust for this particular group of gamblers.
... Two Australian reviews investigated the role of financial institutions in supporting people with gambling problems (Swanton & Gainsbury, 2020;Swanton, Gainsbury, & Blaszczynski, 2019). These reviews reported that there was very limited investigation of consumer credit use by gamblers, despite this being a core criterion for diagnosis of problem gambling. ...
Technical Report
Full-text available
This review builds on the 2018 NSW gap analysis by reviewing recent Australian and, where relevant, international gambling research to identify areas in which evidence and/or knowledge is minimal or lacking. The findings of the current review will inform the Responsible Gambling Fund’s prioritisation of research projects for their 2020-2021 research plan. The methodology included a rapid literature review of 198 peer-reviewed articles and 17 grey literature reports published between 1 October 2018 and 23 April 2020. Key findings (i) The research on emerging technologies is limited, although there are consistent findings that gaming and gambling are increasingly converging, and of an association between in-game purchases and gambling problems (ii) There is sufficient evidence of the associations between advertising and gambling behaviours to support gambling advertising being a priority for policy and regulation (iii) The evidence base on the effects of prevention and harm reduction intervention is dominated by evaluations of individual-level initiatives, with a paucity of research on supply reduction interventions (iv) There was disagreement in the literature on the definition, conceptualisation and measurement of harm. Further gambling harm measurement tools are needed to support the design and measurement of prevention, harm minimisation and treatment research. (v) Vulnerable groups were consistently found to have lower gambling participation but higher rates of gambling problems.Vulnerable groups were identified as young people, people from culturally and linguistically diverse communities, Aboriginal people, at-risk professions, and groups susceptible to family violence and other co-morbidities.
Full-text available
Nuo 2017 metų įsigaliojus ES Direktyvai 2014/95/EU, kai kurioms ES įmonėms socialinės atsakomybės atskleidimas tapo privalomas, tad aktualu ištirti, kaip įmonės, taip pat ir bankai, laikosi šio reguliavimo ir nuo ko jis priklauso. Straipsnio tikslas – ištirti privalomo Lietuvos bankų socialinės atsakomybės atskleidimo 2015–2019 metais lygį ir veiksnius. Taikyta atliktų empirinių tyrimų apžvalga, palyginamoji analizė, tyrimui atlikti – statistinė analizė, koreliacija, regresija. Sukūrus socialinės atskaitomybės atskleidimo indeksą, atlikta penkių didžiausių Lietuvos bankų socialinės atsakomybės ataskaitų turinio analizė. Bankai 2015–2016 metais savanoriškai atskleidė socialinę atsakomybę, tačiau nuo 2017 metų kai kuriuose bankuose atskleidimas buvo nepakankamas. Bankai pateikė daugiau informacijos bendromis, o ne konkretaus bankų sektoriaus temomis. Hipotezės dėl banko turto ir ataskaitų puslapių skaičiaus poveikio socialinės atsakomybės atskleidimui pasitvirtino, tuo tarpu hipotezės dėl banko pelningumo ir kapitalo pakankamumo santykio poveikio socialinės atsakomybės atskleidimui nepasitvirtino.
Full-text available
Background Gamblers engage in a range of “soft” financial options to limit access to money or cash for gambling (e.g., family looks after cash). Such barriers are easily overturned, resulting in a demand for financial systems and tools that offer “hard” restrictions on access to money and cash in a gambling context. The aim of this scoping review was to determine the attitudes and preferences of gamblers and their families on systems or tools to restrict access to money and cash, as well as the effectiveness of systems and tools that can be used to accomplish that goal. Methods A systematic search of articles related to financial restrictions and gambling was conducted. Eligibility criteria included samples of gamblers or affected others and interventions targeted at money or cash restrictions in a gambling context. Soft financial barriers such as family involvement were excluded, as were limit-setting systems which focused on gambling expenditure in gambling venues. Results Nine studies met the eligibility criteria, with three focused on financial systems (e.g., ban on credit betting) and six focused on removal of cash machines from gambling venues. The included literature was generally of low quality, with just two pre-post studies and seven cross-sectional or qualitative ones. Conclusions The included studies provided strong support for financial mechanisms to support gamblers and their families. Future studies need to involve multiple stakeholders to provide this type of support as well as to evaluate the holistic impact that such hard barriers can have on gambling and gambling-related harms.
Full-text available
While the financial and psychological burden on problem gamblers can be severe, at least some of the ill effects are also passed on to family or other close social ties. The present study estimated the number of affected-others for the typical problem gambler. Australian members of an online panel with gambling problems (N = 3076) and panel members who indicated that they had been affected by someone else’s gambling (N = 2129) were asked to estimate the number of other people who were negatively affected by their gambling. Using robust statistics to analyse this data, the study found lower estimates made by problem gamblers (four affected people) compared to estimates made by affected others (six affected people, including the respondent). It was concluded that a point-estimate of six people affected is a more accurate figure since it does not suffer from self-presentation effects of problem gamblers. Low-risk and moderate-risk gamblers, unsurprisingly, affected far fewer other people (one and three, respectively). Both gamblers and affected-others most often identified close family members, including spouses and children, as the people impacted by others’ gambling problems. These results provide an approximate measure of the number of people affected, per problem gambler, to facilitate accurate accounting of the harms accruing from gambling problems.
Full-text available
Financial institutions are expected to embed sustainable business practices as part of their ethical approach in conducting their businesses. This study examines the role of internal and external pressures in encouraging corporate social responsibility (CSR) reporting among financial institutions in Malaysia. The sample for the study comprised of 20 financial institutions in Malaysia over a four-year period from 2008 – 2011. Content analyses of annual and sustainability reports were undertaken to measure the quality of ethical and social responsibility reporting among the financial institutions. An un-weighted CSR quality disclosure index was developed to measure the quality of information reported. The findings of the study revealed that the quality of CSR information disclosed improved over the four-year period. This is a positive development suggesting that the financial institutions are becoming more socially responsible. The results of the study also revealed that it is the external pressure in the form of concentrated ownership and customers’ pressure that can either inhibit or motivate the quality of CSR reporting while the internal pressure prove not to be a significant driver in promoting the quality of CSR reporting.
Full-text available
This paper attempts to investigate how and why organisations in Macao’s gambling industry engage in corporate social responsibility (CSR). It is based on an in-depth investigation of Macao’s gambling industry with 49 semi-structured interviews, conducted in 2011. We found that firms within the industry were emphasising pragmatic legitimacy based on both economic and non-economic contributions, in order to project positive images of the industry, while glossing over two domains of adverse externalities: problem gambling among visitors, and the pollution and despoliation of the environment. By engaging symbolically rather than substantively in CSR, the gambling firms were diverting attention away from issues of moral legitimacy, in order to be allowed to continue to pursue “business as usual” as a means of obtaining substantial financial returns in a social, cultural and socio-political context that was exerting relatively little public pressure to improve corporate social and environmental performance. We conjecture that the gambling firms were feeding on borrowed time.
Excessive gambling results in a range of diverse harms experienced by individuals and their family members. However, little consideration has been given to specifically assessing such harms. Despite recent attempts to comprehensively ‘list’ and describe the ‘wide net’ of specific harms, what remains particularly unclear is the best way to measure the presence of harm and quantify its relationship to gambling. This article proposes a two-step method for quantifying gambling-related harm. From the literature, 104 questions assessing 48 items of harm were categorized into seven domains. Items were administered to 391 clinical and 151 community gamblers. Results suggest that while high-impact harms such as suicide and divorce are commonly associated with problem gambling, the reported frequency is low. Most gamblers sustain low-impact harms such as reduced savings and worry. This study presents the evaluation of specific gambling-related harms distributed in a clinical and community sample taking into account severity and its relationship to gambling behaviours. It is concluded that gambling-related harms negatively impact on quality of life with a minority suffering more severe harms. It is argued that the proposed two-step methodology provides a basis for developing a psychometrically valid measure of gambling-related harm.
Based on a survey and content analysis of 76 empirical research articles, this article reviews the factors driving Corporate Social Responsibility (CSR) disclosure in both developed and developing countries. We find that firm characteristics such as company size, industry sector, profitability, and corporate governance mechanisms predominantly appear to drive the CSR reporting agenda. Furthermore, political, social, and cultural factors influence the CSR disclosure agenda. We find crucial differences between the determinants of CSR disclosure in developed and developing countries. In developed countries, the concerns of specific stakeholders, for example, regulators, shareholders, creditors, investors, environmentalists and the media are considered very important in disclosing CSR information. In developing countries, CSR reporting is more heavily influenced by the external forces/powerful stakeholders such as international buyers, foreign investors, international media and international regulatory bodies (e.g. the World Bank). Furthermore, in contrast to developed countries, firms in developing countries perceive relatively little pressure from the public with regards to CSR disclosure. Copyright © 2017 John Wiley & Sons, Ltd and ERP Environment
This article is intended to give an overview of the burgeoning Internet gambling industry and its particular impact on the financial institutions and financial transaction providers who facilitate funding for Internet gambling operations. In recent years, the Internet gambling industry has become a target of federal and state regulation. As most Internet casinos operate off-shore, the government's attention has largely been focused on restricting financial entities' ability to facilitate payment transactions on behalf of Internet gambling operators. Until recently the government's efforts in this regard have been largely futile, although expensive for many entities who have had to defend against the government's unwarranted claims of unlawful conduct, because the myriad of federal and state laws intended to regulate gambling and financial entities' ability to process related payment transactions fall far short of their intent due to vague language and inconsistent application. In October 2006, however, the tide changed when President Bush signed into law the Safe Accountability for Every Port Act (the "SAFE Port Act"), which includes the Unlawful Internet Gambling Enforcement Act of 2006. This Act makes it plain, for the first time, that federal law prohibits Internet gambling and restricts financial trans-action providers and electronic payment systems that are based in the United States from accepting, distributing or otherwise honoring Internet gamblingrelated transactions. The UIGEA represents the culmination of years of attempts by the federal government to cut the heart out of the Internet gambling industry Regulations and procedures which financial entities must implement will be implemented by July 10, 2007. Therefore, this is an emerging area of the law that financial entities must be aware of in order to ensure compliance with the Act. This article, thus, analyzes the UIGEA, as well as other laws which may be interpreted to regulate Internet gambling and their particular impact on financial institutions and financial transaction providers. The article also discusses measures that financial entities should take to insulate themselves from potential liability.
This book presents a comprehensive view of Internet intermediaries, their economic and social function, development and prospects, benefits and costs, and roles and responsibilities. Divided into three parts, Part I, The Economic and Social Role of Internet Intermediaries, develops a common definition and understanding of what Internet intermediaries are, of their economic function and economic models, of recent market developments, and discusses the economic and social uses that these actors satisfy. Part II, The Role of Internet Intermediaries in Advancing Public Policy Objectives, examines the roles and responsibilities of Internet intermediaries in advancing public policy objectives, as well as the costs and benefits of their involvement through a series of case studies. Part III provides a summary of an experts workshop that identified lessons learned and best practices from the experience to date of Internet intermediaries in advancing public policy objectives.