Dear Affiliate,
This is an extremely important email, which contains action requirements from you that we will need to receive within the next 30 days. Please read it thoroughly and carefully.
In light of recent negative announcements in the sector regarding affiliate marketing, we want to solidify our working relationship and to reassure you of our ongoing commitment to partnering with you. We have no plans to stop our affiliate programme, and it is very important to make clear that we have always and will always continue to honour our payment obligations under the affiliate programme. However, it is essential that we continue to operate in a fair, open and collaborative manner and in accordance with our licences issued by the United Kingdom Gambling Commission (UKGC) and, most recently, by the Malta Gaming Authority (MGA) (together referred to as the “Regulators”).
Compliance is an area that is heavily impacting us and, consequently, our affiliates, and we must all ensure that we are not conducting any activities that are prohibited by the Regulators, the Advertising Standards Agency (“ASA”) or other regulatory bodies. As a result, we have expanded our affiliate team so we can provide more support to you. This will include providing useful marketing updates and guidance as and when needed (for example, updates on ASA rulings and Regulator guidance), a dedicated email contact (affiliatecompliance@fullcreamaffiliates.com) for any marketing or compliance questions you might have or any issues you would like to report regarding the affiliate programme, and monitoring support to help ensure overall compliance.
Marketing Communications
It is now common knowledge that many operators are tightening their controls for marketing communications, which includes much stricter oversight of Affiliate content. As a result of the significant scrutiny of the Regulators and ASA, we are required to take a more direct approach in ensuring that our Affiliates comply with our requirements in regard to marketing, advertising, promotional offers and otherwise. I therefore attach our ‘Marketing Guidelines for Affiliates’. We have reviewed and condensed the applicable law, regulations and codes of practice into this helpful guidance note. Please read this document carefully and ensure that you are fully compliant now and in the future at all times.
From our side, we will conduct audits and online reviews to ensure your continued compliance. Please note that if you do not comply with these guidelines we may be forced to terminate our agreement.
Affiliate Identification and Verification
In accordance with our licensing obligations stipulated by the Regulators, and as already undertaken by many other operators, we are required to ensure that we have complete information on the affiliates that we contract with. I want to assure you that this data is not being collected for any other reason, and will be securely stored and retained in accordance with applicable law and to the highest of standards. These records will also only be viewable by our Legal and Compliance departments, together with Senior Management, as determined necessary. With that in mind, we request the following key information:
For your Company:
A copy of your certificate of incorporation/ registration;
Proof and full details of your registered office;
Details of ALL directors (see below for individual requirements);
Details of any non-director who performs a senior managerial role within the Company (see below for individual requirements); and
Details of any and all shareholder(s) who own more than 25% of the company (see below for individual requirements).
For Individuals:
A reply by email confirming the Individual's Country of residency; and
Full name, with a copy of a valid Government-issued colour document for that individual, such as Passport, ID Card or Driver’s Licence,
If you operate under any other basis, save for a Limited Company (or similar), or as a sole trader/ individual, then please contact us immediately so that we can confirm what documents are required. Please provide us with the above documents as a matter of urgency, and in any case, no later than 30 days from the receipt of this letter. Please send the documents to affiliatecompliance@fullcreamaffiliates.com. Unfortunately, should you fail to reply within this time period, then we may be forced to suspend marketing activity with you and suspend payment of commission owed to you until we receive the information required. Once the necessary documents have been received, any suspended commission payments will then be processed.
I would like to take this opportunity to explain that, as a licenced and regulated operator, we have had to satisfy, (and continue to satisfy) all requirements and requests in regard to a full and detailed disclosure of our legal entities (including our beneficial owners) to the Regulators. Given that we are at the frontline of intensive regulation and the associated requirements of disclosure, we are now required to request this information from you (as per other operators in our industry).
If you have any questions or queries relating to this request, then please feel free to contact me in reply. I will be on hand to answer any questions or resolve any of your queries that you might have.
Many thanks in advance for your understanding and prompt assistance.
Astan Morarji
