158. In jurisdictions that allow businesses located outside the country to operate within their regulatory perimeter (for example, provision of services online), or certain functions of an entity are located in different locations (e.g. where an organisation operates as a group), on-site inspections are challenging and resource intensive. External factors (current global pandemic) can also make it difficult for on-site inspections to go ahead.

159. Strategies to address this challenge:

• Utilise tools such as video-conferencing to simulate the types of testing that would occur at an on-site inspection, ensuring adequate vigour and spontaneity. For example, the UK Gambling Commission supervisors online casinos that offer services in the UK and it has used various tools to undertake effective supervision including: Microsoft Teams assessments over a number of days with key individuals and the ability to view real time data and interrogation of their systems. Prior to the Microsoft Teams assessment, materials are requested and reviewed (including, the entity's risk assessment, policies, procedures and controls) and the initial findings assist to steer the assessment and it is only during the live assessment that we usually specifically advise operators which customer accounts will be assessed. Additionally, the Gambling Commission requires annual assurance statements from highest impact operators that cover around 90% of the market and asks entities to complete 'calls for information'.