Licensed gambling companies are mandated to promote responsible gambling. When gamblers experience severe problems, companies then face lawsuits and accusations that they did not do enough to prevent the escalation. Often, they are accused of actively encouraging gamblers to go beyond their means. But, how should they identify those at risk?
Tracy Schrans, President and CEO of Focal, has been conducting gambling research since 1989. The company has developed the Focal Adult Gambling Screen (FLAGS) to identify an individual’s risk for harmful consequences from gambling prior to the onset of actual problems.
I spoke with Schrans to understand how the tool differs from other industry measures and what she has learned from her decades of research on safer gambling technology and player protection.
Flagging Early Risk
One of the main differentiators between FLAGS and other problem gambling screening assessments is that it identifies early risk, Schrans told me.
“FLAGS was developed in 2011 in response to a public health shift towards prevention,” she said. “Unlike traditional screens such as PGSI, which are stronger at identifying problems once they are already established, FLAGS was designed to detect risk earlier and explain the beliefs, motivations, and behaviors that sit behind it.”
The 61-item screening tool has now been administered to more than 70,000 regular players across five countries. Schrans said it provides “practical insights to support strategies that reduce gambling risk and harm. It has also been linked to player data to help build sophisticated algorithms that detect risky play patterns and support better player outcomes.”
“It measures not just consequences, but also the beliefs, motivations, behaviors, and traits that sit behind them, allowing risk to be classified more accurately across the full spectrum.”
“The real advantage is prevention. It is easier, less costly, and less stigmatizing to help people before harm develops or escalates than to respond after the fact. Sometimes a gentle nudge or timely interruption is enough to support a better decision in the moment, making safer gambling interactions more about connecting with customers than correcting them.”
Affordability Checks Beyond Simple Spending
In the UK, there has recently been a heated debate about the use of affordability checks, or, as the Gambling Commission calls them, financial risk assessments.
“Affordability is one of the most important — and most difficult — issues in reducing gambling-related harm,” Schrans says. “Simple affordability checks or universal spend limits are hard to apply fairly at scale because people’s financial circumstances vary so widely.”
Instead, Focal has developed the Affordability Index, a seven-item measure designed to identify people who may be spending beyond their means even when they show few obvious warning signs.
“In Focal’s research, the Affordability Index proved to be a valid and reliable way to detect ‘overspenders’ — a high-risk group associated with both problem gambling and financial harm, including gambling with misappropriated funds,” Schrans said.
Items on the index include asking gamblers if they are gambling with borrowed money or if they have done things that may not be legal because of their gambling.
The problem may be whether gamblers complete such an assessment and whether they do so honestly. It is difficult to balance checks with accurately assessing a gambler’s risk and being overly intrusive.
“More intensive or intrusive financial scrutiny can also push consumers toward less regulated, lower-friction options,” Schrans admits. However, she says that the results of using the tool “have been very encouraging. Our research shows that the Affordability Index is a valid and reliable way to identify regular players who may be spending beyond their means.”
“Across an international research program involving more than 10,000 regular electronic gaming machine players, we found that those at high risk of overspending often spend less and play less than other regular players, even though they are more likely to experience gambling-related harm.
“In practice, this can mean they are exhausting easily available resources. To an observer, they may appear to be improving, when in fact they may be at their most vulnerable to taking on debt or using money they cannot afford to lose.”
Users are also not as adverse to completing the assessments as one may think, Schrans says. “On average, 85%+ of member customers in land-based or online operations complete both sections even though they are only offered low-value incentives for taking part, such as $5-$10 value in food and beverage vouchers or player points.”
No Tool Should Stand Alone
In addition to using assessment tools such as FLAGS and the Affordability Index, it is important for operators to use the player data they have to identify those at risk.
“No tool should stand alone,” Schrans said. “It works best as part of a broader harm-reduction framework that supports timely, informed interaction — not just compliance.”
“Simple rule-based checks are also easy for people to figure out. People often adapt their play to avoid detection, which means these systems may detect some risk, but rarely the full picture.”
“A better approach is to look at behavior in context — it then becomes about how someone plays and not how much. This lets us capture those who are overspending across all the expenditure tiers.”
Focal uses AI and data analytics to identify play patterns unique to specific target groups that may signal early risk.
“Once these play patterns are confirmed and tested on an independent hold-out sample, we can then apply them to an operator’s database. These models are constantly scanning the datasets and then alert operators when a known risky pattern, event, or outcome is triggered so they can proactively check in with a customer to provide relevant information, tools, referrals, or assistance depending on the context.”
Responsibility of Operators to Intervene
“Operators are in a unique position to see patterns of play, escalation, intensity, and other behaviors that may point to risk, and with that visibility comes a duty to act responsibly,” Schrans adds.
In the UK, Betfair and bet365 have been accused of not intervening early enough in two high-profile cases where a gambler eventually committed suicide as a result of unsustained losses on the platforms.
Betfair is currently in court defending a lawsuit brought by Luke Ashton‘s widow. A coroner ruled in 2023 that Betfair “did not intervene or interact with Luke, in any meaningful way, between 2019 and the date of Luke’s death (April 2021), when more efforts to intervene or interact should have been made.”
The UK Gambling Commission opened an investigation into Betfair’s actions but found no wrongdoing. Ashton’s family has also brought legal action against the Commission, claiming it is a “dereliction of duty” not to impose any penalties on the company.
Scharns says that by using Focal’s tools, operators and regulators can be clearer about when intervention is appropriate.
“This is in strong contrast to waiting until you are certain someone is experiencing harm before acting,” she says. “Using our technology means we can see these patterns sooner, sometimes before harm has occurred or escalated. This is a method for reaching out to the right person, at the right time, with the right message, making it more likely to result in improved outcomes. It takes the guesswork out of knowing when to reach out to a customer, directing an operator’s resources to those most likely to benefit from support at a time when it will be relevant. “
Early Intervention Can Make a Huge Difference
In another case against Betfair, a judge dismissed a claim brought by gambler Lee Gibson. Gibson argued the company should have intervened sooner to prevent him from losing over $2 million on the platform. A judge ruled that he was determined to gamble, and if Betfair had stopped him, he would have done so elsewhere.
Schrans disagrees.
“In a multi-year study across 16 UK casinos, Focal examined the impact of safer gambling interactions triggered by its risk-detection algorithms. We tracked customer play for six months after the first interaction and compared it with a baseline control group. The results were encouraging,” she explains.
And, unlike the judge’s ruling that Gibson would have gambled elsewhere, she says evidence suggests otherwise.
“These interactions did not drive defection to other providers, and customers who received two or more interactions showed meaningful reductions in risky play patterns, still visible six months later, leading to a reduction in their overall losses that was 42% lower than in the control group.”
“So, while I would not comment on an individual judgment, I do not think it is reasonable to assume intervention makes no difference simply because someone might have gambled elsewhere. The evidence suggests the opposite: timely, evidence-based interactions can reduce risky and harmful play and may also strengthen player loyalty.”
In the end, operators do not want to bankrupt their customers; that is bad for business. Early intervention to encourage controlled, responsible play can keep players using the platforms for longer, rather than quickly exhausting all available funding and going bust. It also brings bad press and lawsuits if players go way beyond their means and experience severe harm, such as in the cases of Gibson and Ashton.
Is Advertising to Blame?
Advertising is often blamed for normalizing gambling and encouraging users to play beyond their means. In the UK, there have been increased calls for a ban, similar to that on tobacco. UK gambling companies spent around £2 billion ($2.62 billion) on advertising in 2024.
Is a ban the answer to help prevent problem gambling?
“Advertising can normalize gambling and shape risky beliefs,” Schrans admits. “Although operators often present gambling as entertainment, much advertising still centers on winning. That can reinforce the idea that gambling is a reasonable way to make money — a belief our Affordability research clearly links to elevated risk, particularly when people see gambling as a way to solve financial problems.”
“That matters because it can encourage people to gamble more heavily in the hope of recovering losses, covering shortfalls, or securing future stability. In some cases, this creates a harmful cycle in which people divert essential funds, borrow money, or use money that is not theirs in an effort to chase a win.”
“So, the issue is not only how much advertising people see, but also what the advertising communicates. Tools such as FLAGS can help identify where messaging may be reinforcing risky beliefs and where it needs to change.”
“More broadly, simply telling people to gamble responsibly does not explain how to change behavior. Public health messages can define the goal, but behavioral research is needed to design practical strategies that help people act differently. Used well, gambling advertising could also reinforce safer play practices in ways that are clear, practical, and meaningful.”
A Complex Issue Needs a Coordinated Response
In the case where a Bet365 user committed suicide after gambling excessively on the platform, the healthcare system was also blamed for its lack of intervention. Arthur Soames sought help from his doctor as his mental health deteriorated, but despite revealing his struggles with gambling addiction, little was done to help.
“Health professionals do play an important role in recognizing a gambling disorder and helping people access effective support,” Schrans said.
“At the same time, I would be cautious about placing the onus on any one sector. Gambling harm is a complex issue that cuts across healthcare, regulation, industry practice, and community support, so responsibility is shared.”
“The most effective response is a coordinated one: Identifying risk early in different settings and connecting people with the right help at the right time. But we cannot wait until we are certain someone is harmed before we intervene.”
“That is the thinking behind Focal Prevent, our real-time risk detection system, as well as FLAGS and the Affordability Model. These tools are designed to help operators identify emerging risk, respond with timely, evidence-based support, and then measure whether those actions are actually reducing risk and harm.”
“No single solution will solve problem gambling. What matters is a coordinated, research-informed response that combines player tools, staff training, thoughtful regulation, accessible treatment, and a shared commitment across the industry to sustainable policy and practice.”
Evaluate as Systems Evolve
The gambling industry is in constant flux, particularly in the US, as states regulate markets or prohibit certain products. The emergence of new platforms such as sweepstakes casinos and prediction markets creates new challenges for organizations such as Focal that aim to prevent gambling harms.
Kalshi became the first prediction market operator to sign up to the National Council on Problem Gambling, and getting more companies and regulators onside is key, says Schrans.
“Some regulators are now using operator data and analytics to assess how safe gambling environments really are, including whether marketing practices and product design may be contributing to harm.”
“Focal recently helped a regulator develop a set of analytics that combined multiple measures to grade operators on the safety of their environments. We would encourage wider use of this kind of data, along with testing the likely impact of regulations before and after they are imposed.”
The important thing is to identify harmful systems before they cause harm. Too often, responses are reactive to problems, such as the Public Health Advisory Institute (PHAI) suing gambling companies over their use of microbetting.
By working with regulators and operators, Focal can help create safer platforms for gamblers.
“Surveillance and evaluation need to be built into safer gambling as a normal part of the process, not treated as an afterthought,” Schrans adds. “The priority should be to define the outcomes we want to achieve, measure whether interventions are delivering them, and adjust as evidence emerges.”
“This shifts the conversation from asking, ‘What should we do to asking how well are we achieving our objectives?’ In practice, that moves safer gambling from a reactive response to a responsive system built on continuous assessment, learning, and improvement.”
