The cover of our 'First line of defence' paper.

Leia Clifton, Senior Research Officer, Money and Mental Health; Nikki Bond, Head of Gambling Harms Action Lab, Money and Mental Health

First line of defence

How banks can use transaction data to support customers at risk of or experiencing gambling harm

This policy paper looks at how current account providers can use customers’ transaction data to identify when people may be at risk of, or already experiencing, gambling harms, and step in earlier with support. 

It highlights the large gap between the number of people experiencing problem gambling and those accessing specialist help, with only one in five currently getting support. It makes the case that banks can, and should, play a bigger role in closing that gap. 

Because banks have a unique view of customers’ gambling and wider finances, they can – if they analyse transaction data carefully and responsibly – spot warning signs, and help customers access support in line with their obligations under the FCA’s Consumer Duty.

Current account providers should also draw directly on the insights of those with lived experience of gambling harms, that ensures firms strike the right balance between people’s privacy concerns and the need for support where appropriate. Involving the testimony of those with lived experience is essential to making sure this approach is rolled out responsibly sector wide.

Our recommendations for financial services include:

  1. Use transaction data to identify customers at risk of gambling harms – developing clear spending and behavioural indicators, such as rapidly increasing deposits or gambling through the night, to trigger earlier intervention.
  2. Design and improve systems with people who have lived experience of gambling harms – to balance privacy concerns with offering support at the right time, and to ensure that all communications are non-judgemental and respectful.
  3. Proactively reach out to customers identified as at risk – signposting them to specialist gambling support services and to tools such as gambling blocks, spending limits and budgeting support.
  4. Build on existing transaction monitoring – drawing on approaches already used for fraud prevention and financial resilience, and refining these models over time to better prevent foreseeable harm.

The report has been published as part of Money and Mental Health’s Gambling Harms Action Lab – a three-year programme working directly with financial services firms to explore how they can better support customers experiencing gambling harms. Participating banks, including Barclays, first direct, HSBC UK, Monzo, Nationwide, Starling and Virgin Money, are collaborating to test and improve practical tools and approaches, including the use of transaction data to identify and respond to gambling harms.

This work is funded through a regulatory settlement by the UK Gambling Commission. When the Gambling Commission takes regulatory action against a gambling operator, one of the outcomes of that action can be a payment in lieu of the financial penalty the Commission might otherwise impose for breach of a licence condition. The Gambling Commission regularly reviews proposals for destinations of regulatory settlements and awarded funding for the Gambling Harms Action Lab project in July 2023.