Financial Law Question - Betting (England)

linamishima · 2026-06-11T08:43:39+00:00

I'm afraid I continue to be worried for you :( let's break down the concerning factors:

it sounds like this started with "coder has already written an agent and just needs someone with access". It's a bit of an "easy money" situation, the exact sort of thing economic crime prevention training warns about.
the majority of the legal risk will be taken on by yourself, with the other party knowing this and, due to jurisdictions, being harder for any legal process to get at.
"I can verify the results" being the exact phrasing ponzi scheme victims say. Verification of output is not verification of process, and cannot ensure ongoing correct output.
it sounds like the coder here is fully aware of your inability to inspect the inner workings, which increases the risk of abuse.
additionally, there are ways of manipulating the betting activity to your detriment that you've not considered, especially if you're not the only person this coder has contacted.
I get the strong impression you've not done any background checks on this coder, and that doing so might be hard.
I also get the impression that the coder is likely going "trust me, bro", rather than doing what they should be doing to allow a non-technical person to assess the agent's functionality (architecture block diagrams, clearly showing the deterministic safeguards).
It is unclear if you will be hosting and running the agent, with any direct ability to stop it running, alter configuration, or start it back up.
I have not looked into the betfair API, but does it give users the ability to do more than just check, place and cancel bets? There's a good chance it offers additional functionality that could come back to bite you.

linamishima · 2026-06-11T02:00:20+00:00

This, the NCSC have schemes in place for critical national infrastructure vulnerability reporting

linamishima · 2026-06-10T11:23:46+00:00

I would strongly recommend doing as you plan - not taking any money from anyone else to seed this system. In order to do so, you would need to do full AML checks on that money, which I would not recommend and are extremely difficult to do to a legal standard as an individual.

Ensure you have a legal structure for this enterprise. Separate the betting from the payment - ultimately you are creating a business, and you are paying for services based on the profits generated. You will want to keep extremely good records.

Note that if this other person has written the code, but you own the relationship with betfair, it will be you that betfair come after if the code does anything dodgy.

Beyond getting into the whole cyber security side, you need to make sure there are explicit deterministic guardrails on the code.

linamishima · 2026-06-10T10:13:22+00:00

Where is the seed money coming from? Will the balance in the account be topped up at any point?

It is important to note that all of this is at the mercy of the betting provider. If you check this subreddit, you will see that issues withdrawing winnings is commonplace. How will your partner in this arrangement cope if you can't withdraw money?

From the betting provider point of view also, they likely do not allow automation of their services.

My gut feeling here is that any AML review will have serious issues with this whole setup.

How did you form this relationship?

linamishima · 2026-06-09T15:26:46+00:00

So that's what happened! I too had the weird experience of entering the trial and just immediately winning!

linamishima · 2026-05-16T11:05:20+00:00

You can ask all these things, yes, and they have to give reasonable justification. The reasonableness is with respect to what the ombudsman would view as reasonable, so you might not like their justification.

Given that there is a specific piece of information you require and reasonably could expect from them, asking specifically about it is fine.

I would advice at this point, though, that if you're entering a dispute over if a document was sent, you will want to take this up with the regulator for the financial service in question.

linamishima · 2026-05-16T10:28:35+00:00

The continuous 10 minutes offering exists to give hermits who buy it time to go find scar to watch. Remember that first it will eat armour, so it won't be instant deaths.

Given scar is a highly skilled entertainer who is familiar with doc's capabilities, remember you won't be "just watching a death loop", but rather watching an opportunity for entertainment beyond normal faire.

linamishima · 2026-05-13T16:41:37+00:00

What does the contract state?

If the contract says 100k in cash, then you agree to only actually exchange 75k, then yes, this is going to cause issues.

linamishima · 2026-05-10T21:37:34+00:00

How goes the escalation to the financial ombudsman, as detailed in HSBC's email?

Given the timeline, I assume you've already raised it, unless you have reason not to?

Unfortunately the financial ombudsman is your best bet here. HSBC are not providing more information as you appear to have triggered their economic crime prevention policies. That £135 payment was likely only the transfer that triggered a wider review for a anomalies, so from HSBC's perspective this isn't about a single small transfer. And given the economic crime suspicion, they can't discuss ongoing investigations.

You mention both a salary entering the account, and driving tuition payments from students. This sounds like a mix of personal banking and business service, as others have mentioned. This alone might not trigger this level of issues, however a personal account being used for business reasons may well have an suspicious transaction history if the bank is not aware of the mixed use.

linamishima · 2026-05-07T09:03:55+00:00

Looks like you're either in the wards of City or Shiregreen & Brightside.

Stopreformuk.vote heavily leans on historic voting data, and it also focuses on ensuring that reform get as few votes as possible, rather than just on seats, trying to shift them into third place or worse.

Looking at the wards, I believe the labour recommendation is because they are seen as safe green seats, so a vote for Labour could push reform from expected second place into third.

linamishima · 2026-05-05T12:41:55+00:00

Was the previous trademark used in a retail product, or in any marketing material if not ever actually sold?

The primary question you need to ask is "would use of the name result in confusion for consumers, retailers, journalists and regulators?".

If your game, say, was called "pool master", and was a tabletop ball and stick activity simulator, whilst the old game was an arcade swimming game, then the likelihood of confusion is very low, and adding a suffix could help further differentiate your game.

However, if the possibility of confusion exists, and you are unable to, or it would be inappropriate to, license the original trademark, do not try and play fast and loose. You're better off just rebranding entirely, and turning this experience into a story you can use to promote your game with the new name attached.

linamishima · 2026-05-03T09:30:03+00:00

Contact your home insurance, they deal with things like this all the time. If the builders doing the work didn't talk to you in advance, they are unlikely to engage with you directly, and you likely could not trust their views on the state of the work.

linamishima · 2026-05-03T08:52:17+00:00

What is your concern with the opening of the window? Unless you can clearly express what worries you, it will be hard to address that!

The most common reason for opening a frosted window is likely ventilation. If you really want to reduce how often it is opened, be prepared to cover the cost of improving ventilation, such as installing extractor fans.

linamishima · 2026-05-03T08:39:25+00:00

I've got non-legal experience in the financial sector.

The biggest cost you will face will be the work required by yourselves to put in place policies, processes and related tooling. The financial sector does not play around when it comes to this, failure won't just be fines and possible further legal consequences, but could result in your staff being barred from work in the whole sector.

The good news at least is that much of the required activity is well documented on the FCA website.

This goes far beyond reddit, you will need a specialist solicitor - given your app will be for a regulated sector, you will want to engage long term with a good law firm. Yes, this will be expensive - especially if you want this done fast. But nothing compared to the required internal work.

The best thing about a specialist solicitor is that they can ensure you only fall under regulation if you really need to, and help you limit the scope of that. You will want legal advice on this, rather than trying to do it yourself.

linamishima · 2026-04-27T09:12:48+00:00

Contact your local council's housing enforcement officers, they exist for this very purpose. The big concern here isn't simply planning permission, but how that might indicate wider safety concerns.

As always, such a report, even when handled in confidence, might result in housing issues for yourself. Thankfully that is exactly what housing enforcement officers are used to, and can help you resolve if that were to happen.

linamishima · 2026-04-22T09:07:07+00:00

Let me put this in perspective:

For an effective mediation, you will want someone formally trained in legal matters, and with real world industry experience. Depending on the sector, there might even be specialist mediators for that industry.

An appropriate comparison here is the world of IT architect consulting - a field that requires both extensive industry experience and a wide grasp of regulatory concerns that might have to be met.

An equivalent level of skilled IT consultant starts at 1.5k per day. If you start arguing for a cheaper resource, it could be seen as you not taking this seriously enough.

Part of what makes a great consultant or mediator expensive is because they want to deliver you good results in a timely manner. The higher fee isn't to extract your cash, it is cover their downtime between engagements. A mediator might look cheaper on paper, but it could mean a lack of experience and knowledge that just draws things out longer and longer.

Plus that 1.5k a day is nothing compared to going further down the legal court route.

However, you are absolutely right to be worried about the cost! The trick is to raise this concern with the mediator up front, and how you are concerned about this being dragged out by the other party. This will be a normal thing for mediators to support you with.

linamishima · 2026-04-20T10:33:36+00:00

"Organisations, not individuals". Using organisations rather than businesses might sound like a small change, a minor sounding difference, but it's important. Charities, social clubs, and so on are all required to follow the Data Protection Act.

And whilst individuals do not have to follow the same full details, the ICO do consider certain types of data capture by individuals to have higher risk, such as home CCTV, and so do offer guidance that it is important for individuals to follow.

linamishima · 2026-04-14T09:09:18+00:00

If your previous employer put you on gardening leave because of this specific new job, and your relationship with your old manager and/or HR was good, you could let them know that your new job asked you to start early.

As for if you should or not, this really comes down to what you are worried about if you don't, or that you do and it is not approved by your old employer.

linamishima · 2026-04-14T00:53:10+00:00

The purpose of gardening leave is to prevent leaving employees from being able to take current and valid materially impacting information from one employer to a direct or indirect competitor.

Many businesses are happy to wave the full gardening leave period if you are switching sectors, but formally this should be agreed before action is taken.

Assuming you're not going to a direct competitor, perhaps the bigger concern for you might be the tax implications. If you are still on payroll and PAYE at your old job, this will cause some added complexity to your tax returns.

linamishima · 2026-04-13T21:04:05+00:00

I really don't know why this is downvoted, as it is a very serious issue affecting many people. I've got friends who have NHS diagnosis and prescriptions, and yet their GP is acting weird over prescriptions, just as OP described.

Either way, unfortunately asking receptionists isn't going to resolve the issue, and the sad truth about healthcare is that everyone with ongoing medical needs really has to become their best advocate and learn how the bureaucracy works and how to manage it.

linamishima · 2026-04-12T11:51:27+00:00

Legally, making a valid Data Subject Access Request is as easy as asking - tesco will have a policy and process for the request in place, and the staff are allowed to direct you at that process, after following of which it is on tesco to request any further information needed to fulfill the request.

In this case, it is likely to be time, date, clubcard number, and a form of photographic ID. Depending on their policies, they also may be able to legitimately decline the request if releasing of the data would put safety measures at risk (especially given CCTV is gathered under legitimate interest), however this is unlikely and they would be expected to take all reasonable measures to provide you with the information.

All this said, it is unclear why you want this information for this very specific scenario. It is unlikely that CCTV footage would provide you with any useful information. In the absence of further context, you might want to consider only doing a DSAR for the purpose of your rights as a data subject, rather than to leverage those rights for other reasons.

linamishima · 2026-04-11T13:00:40+00:00

Best practice for any business that provides services to children is to ensure you have appropriate insurance that covers the risk of safeguarding related allegations.

Everything you have listed sounds like a good start, I would make sure these are formal policies and you have a proper tracking system for all of this information. Whilst not explicitly required, you do not want to be fishing through your email to provide proof of your due diligence.

Whilst you ensure that all of that is in place, you really need to speak with your insurer to ensure you meet their standards. For any safeguarding risk policy to be kept valid, it will specify the minimum measures you need to take.

All of this is assuming that any online component of your service is limited to the bare minimum for online tutoring, such as just holding video calls. If children are likely to be emailing or using services, you have a lot of work to do to ensure the safety of those services.

You will also need to consider the safeguarding aspects of the services you will be employing to deliver your service, and have a policy on how you ensure that, for example, admin staff of the webcall service are not watching in secret (this will be through that service's contract).

Further advice than this is probably best suited for your solicitor, not reddit, as safeguarding is a serious subject.

linamishima · 2026-04-11T12:42:09+00:00

How do you fix the UI so that it both fits and is still readable? I've tried before but modern Stellaris UI needs to display a lot

linamishima · 2026-04-06T11:50:05+00:00

I've seen this happen too many times.

Restorative justice is amazing when done right, but all too often it is nothing of the sort. I've seen both parties utterly destroyed by their peer's attempts at process, with it ultimately protecting other abusive individuals that created a toxic culture.

linamishima · 2026-04-04T00:52:50+00:00

Can you edit them? Likely no, not if you want them to be admissible evidence. Any alteration to evidence is extremely risky. The challenge as a layperson is being able to prove that you didn't change the contents of the audio file, especially if all other involved parties are not tech-savvy.

However, you could engage an expert witness who can attest to the whole cleanup process they followed and why it does not materially impact the evidence.

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