While the regulations apply to financial service providers including payment institutions, the update focuses on administrative complaint-handling procedures rather than substantive payments regulation, making it a low-priority match requiring human review.
Acquiring (40%)The regulations could apply to payment processors among other financial service providers, but the update is primarily procedural and administrative rather than payments-specific, warranting low confidence and human review.
The regulations establish mandatory complaint handling procedures, record-keeping requirements, and reporting obligations for financial service providers, which constitute regulatory reporting and data governance obligations.
Data Governance (82%)The rules also require covered persons to maintain complaint records for five years and implement written policies and procedures, which involves internal data governance and record-keeping standards.
CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]
Horizon Scanning Outline.
Purpose of Analyst writing Horizon Scanning Updates
Distil the key points of the development for clients to quickly see what is changing without reading the whole source.
Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes.
Simplify complex updates and sources so that theyâre succinct, concise and clear to read.
Consistently structure and write updates in the same format.
Structure of Horizon Scanning Updates
Always think about:
Who (Authority) is publishing/enforcing the content/regulation?
Where (Jurisdiction)?
What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed?
Who is this update applicable to (credit, e-money institutions, etc.)?
Why is this update noteworthy? What is its significance?
When is the update applicable?
Title
Describe what the update is about.
Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what).
All titles should be written in present tense.
Avoid using acronyms
Approx 10 - 20 words
Example
Turkeyâs Personal Data Protection Authority Publishes Data Protection Guidance
Paragraph 1
Open with the date of the update (When)
Name the authority that released the update (Who)
Summarise the release (What)
Example
On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets.
Paragraph 2
Summarise key points.
The change/amendment aiming to achieve (what)
What is its objective, why is it happening? Why is it significant? (why)
Who does it impact or concern? (Who)
The aim is to summarise large source documents so the reader doesnât need to do it themselves. DO NOT just copy the first few sentences of the document.
Example
SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to:
Study Indian and global best practices.
Prepare the guidelines.
Address the concerns and issues arising from AI/ML usage.
SEBI is consulting on the following principles to develop the guidelines:
Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models.
Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information.
Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results.
Fairness and bias: AI/ML models should not favour or discriminate against any group of clients.
Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security.
Paragraph 3
Acts as a âCall To Actionâ. Provide forward looking context:
What actions need to be taken?
Who needs to take action?
Next steps to the development.
Include any relevant dates (When)
Response dates - should always be provided for consultations
Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted.
Example
The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026.
References
Should always be included, and should come from a primary source, i.e., an authority, not a news source.
General Style Notes:
200-250 words
Active voice
Authorities and companies referenced as a single entity (âItâ, not âtheyâ)
Titles in title case
Internal Vixio vocabulary guide
Content Style Guide
Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content.
A
Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA).
Act - when just referring to âthe actâ, it does not need a capital a.
Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell).
- advice (noun) - give formal suggestions (for example, I gave them advice).
Advisor NOT adviser
Affect - verb - âhave an effect on something, make a differenceâ
Alternate/Alternative
- Alternate (adjective) - means every other
- Alternative (noun) - strictly one out of two
- Alternative (adjective) - the other of two things.
Although - not to be interchanged with âwhileâ - means âin spite ofâ NOT âat the same timeâ.
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
Among/while NOT Amongst/whilst
API - application programming interface
Apostrophes - to be used in possessives, i.e. an operatorâs licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act.
Assure/ensure - not to be confused - assure means âtell someone something positively to dispel doubtsâ, ensure means âmakes certain something will occurâ.
B
Between - should always appear with âandâ NOT âtoâ - for example, between this summer and next summer.
Big tech - two words, breaks convention of other tech words
Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522).
Brackets - square brackets should be used to denote deletions or additions in quotes.
Buy now, pay later - no hyphens
Bullet points - see Lists
C
Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a)
Cardrooms not card rooms
Cases - legal cases should appear in italics, with a v for versus.
Casino-resorts NOT casino resorts or resort-casinos
Chief executive NOT chief executive officer
Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes)
Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000)
Comparisons - compare with (highlighting differences)
- compare to (highlighting similarities)
Companies/organisations - singular entities (it NOT they)
should be followed by âwhich/thatâ rather than âwhoâ
Ltd, not Limited
Complement - to accompany something/add value
Compliment - give praise (complimentary = free)
Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings)
Comprise/comprising - should NOT be followed with âofâ, as it means to âconsist ofâ
Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,)
Continually - if something occurs repeatedly/regularly in the same way
Continuously - if something occurs without interruption or gaps
Contractions - donât, canât, wonât, etc. to be avoided in copy (except in marketing material and depending on tone)
Contrast - by contrast - when comparing one thing to another
- in contrast - simply noting a difference
Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting
Court of Justice of the European Union (CJEU) rather than ECJ
Cryptocurrency - one word, not hyphenated.
ââCrypto-assets - hyphenated
Cybersecurity - one word, not hyphenated
CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism
Currencies - if not using common symbols (ÂŁ, $, âŹ), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar)
m for million, bn for billion, trn for trillion.
D
Date format - Month, Day, Year (e.g., March 7, 2019)
For Insights & Analysis summary text: can just say âtodayâ, e.g., âToday a bill was passed forâŚâ
For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., âOn Wednesday (June 8) a bill was passed...â
For NIBs: always use dates rather than days.
Department for Digital, Culture, Media & Sport - ampersand
Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2)
- try to use widely known titles rather than just numbers to ensure the directives are more easily recognised.
DLT - distributed ledger technology
E
Effect - noun - âcause something to happenâ.
Em dash (â) - should be used as a conjunction, not a hyphen or en dash (â).
Ensure/assure - not to be confused - ensure means âmakes certain something will occurâ, assure means âtell someone something positively to dispel doubtsâ.
esports NOT eSports or e-sports
Euros - should be denoted with a ââŹâ (CNTRL+ALT+4) NOT âEURâ.
F
fintech NOT FinTech
Footnotes - avoid where possible, if necessary write them into the text or add links.
G
GGR - âgross gaming revenuesâ
Government - does not need a capital g.
Governor - should be written out in full, NOT Gov.
Guidance (singular and plural) - does NOT need to be preceded by âaâ (Guide/guides, Guideline/guidelines)
H
Headlines - all words should begin with a capital
Horseracing NOT horse racing
Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if âa fast-tracked applicationâ), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money
- DONâT: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper
I
Impact - should be used as a noun - i.e. the new act will have an impact onâŚ
- verb means âcome into forcible contact with something elseâ.
- using âaffectâ as a verb is more accurate.
J
Judgment - legal decision
Judgement - oneâs own opinion
Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters.
Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive.
OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur
DONâT need capitals unless a figure of importance (i.e., Prime Minister, President)
Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be.
Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team).
K
KYC - know your customer
L
Legislature - does not need a capital l.
Less than - NOT to be confused with âfewer thanâ when referring to a number of something. i.e. fewer than 100 gambling tables.
Licence - noun (UK), i.e. a driverâs licence
License - verb/noun (US)
Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent).
M
MONEYVAL NOT Moneyval
More than - to be used instead of âoverâ. i.e., more than 20 players rather than over 20 players.
N
Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive.
Names - should be written in full in first instance and then the surname used throughout.
Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences.
Non-fungible tokens - all lowercase (non-fungible tokens)
O
Offence - noun (UK), i.e. commit an offence
Offense - noun (US)
Organisations/companies - singular entities (it NOT they)
should be followed by âwhich/thatâ rather than âwhoâ
Oxford comma - (appears before âandâ or âorâ) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one âand/orâ appears).
Over - should not be used as a replacement for âmore thanâ.
P
Parliament - does not need a capital p.
Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act
Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Past/passed - past is a noun/adverb/adjective - âin the pastâ, âpast experienceâ.
- passed is the past tense of âto passâ - âthe law was passed in governmentâ.
Prepaid, not pre-paid
Percentages - numbers should always be written as figures
percent NOT per cent or %
Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent)
Possessives - require an apostrophe and should not be confused with plurals - i.e., an operatorâs licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Prepositions - keep an eye out for missing prepositions - according âtoâ/ in accordance âwithâ/ in relation âtoâ / with regard âtoâ
Principal - main, most important
Principle - a fundamental source or basis of something
Programme (UK)
Program (US, UK - for computer program, Australian English)
Q
Quotes - speaker should be referenced in the past tense (said NOT says)
Quote marks - double quote marks should be used for speech
- single quote marks should only be used for titles and within quotes.
(See Quote reference sheet for more information on how to use quotes.)
R
regtech NOT RegTech
Repetition - avoid using words that mean the same thing (âand alsoâ / âinclude, among othersâ / VLT terminals / ATM machines)
Racetracks not race tracks
S
Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018.
Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act.
Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.)
Sports betting NOT sportsbetting
Sports team names
Storey (pl. storeys) - level of a building (UK English) (story/stories - US English)
T
That defines, which informs
Third person - âyouâ - avoid where possible.
Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a)
Tenses - content should generally be written in past tense
- present tense should be used for something that has just happened and will be continuing into the future.
U
United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC
USA PATRIOT Act - should be kept as such, i.e. with caps, as itâs an acronym for âUniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Actâ)
U.S. Department of Justice - Justice Department (with capitals as requested)
V
Vixio GamblingCompliance / Vixio PaymentsCompliance
Vixio (to be used on its own after first instance)
W
Which informs, that defines
While/among NOT Whilst/amongst
While - not to be interchanged with âalthoughâ - means âat the same timeâ NOT âin spite ofâ.
X
Y
Year quarters - Q1, Q2, H1, H2, etc.
Z
Acronyms
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
API - application programming interface
DLT - distributed ledger technology
Horizon Scanning Outline.
Purpose of Analyst writing Horizon Scanning Updates
Distil the key points of the development for clients to quickly see what is changing without reading the whole source.
Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes.
Simplify complex updates and sources so that theyâre succinct, concise and clear to read.
Consistently structure and write updates in the same format.
Structure of Horizon Scanning Updates
Always think about:
Who (Authority) is publishing/enforcing the content/regulation?
Where (Jurisdiction)?
What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed?
Who is this update applicable to (credit, e-money institutions, etc.)?
Why is this update noteworthy? What is its significance?
When is the update applicable?
Title
Describe what the update is about.
Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what).
All titles should be written in present tense.
Avoid using acronyms
Approx 10 - 20 words
Example
Turkeyâs Personal Data Protection Authority Publishes Data Protection Guidance
Paragraph 1
Open with the date of the update (When)
Name the authority that released the update (Who)
Summarise the release (What)
Example
On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets.
Paragraph 2
Summarise key points.
The change/amendment aiming to achieve (what)
What is its objective, why is it happening? Why is it significant? (why)
Who does it impact or concern? (Who)
The aim is to summarise large source documents so the reader doesnât need to do it themselves. DO NOT just copy the first few sentences of the document.
Example
SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to:
Study Indian and global best practices.
Prepare the guidelines.
Address the concerns and issues arising from AI/ML usage.
SEBI is consulting on the following principles to develop the guidelines:
Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models.
Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information.
Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results.
Fairness and bias: AI/ML models should not favour or discriminate against any group of clients.
Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security.
Paragraph 3
Acts as a âCall To Actionâ. Provide forward looking context:
What actions need to be taken?
Who needs to take action?
Next steps to the development.
Include any relevant dates (When)
Response dates - should always be provided for consultations
Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted.
Example
The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026.
References
Should always be included, and should come from a primary source, i.e., an authority, not a news source.
General Style Notes:
200-250 words
Active voice
Authorities and companies referenced as a single entity (âItâ, not âtheyâ)
Titles in title case
Internal Vixio vocabulary guide
Content Style Guide
Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content.
A
Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA).
Act - when just referring to âthe actâ, it does not need a capital a.
Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell).
- advice (noun) - give formal suggestions (for example, I gave them advice).
Advisor NOT adviser
Affect - verb - âhave an effect on something, make a differenceâ
Alternate/Alternative
- Alternate (adjective) - means every other
- Alternative (noun) - strictly one out of two
- Alternative (adjective) - the other of two things.
Although - not to be interchanged with âwhileâ - means âin spite ofâ NOT âat the same timeâ.
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
Among/while NOT Amongst/whilst
API - application programming interface
Apostrophes - to be used in possessives, i.e. an operatorâs licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act.
Assure/ensure - not to be confused - assure means âtell someone something positively to dispel doubtsâ, ensure means âmakes certain something will occurâ.
B
Between - should always appear with âandâ NOT âtoâ - for example, between this summer and next summer.
Big tech - two words, breaks convention of other tech words
Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522).
Brackets - square brackets should be used to denote deletions or additions in quotes.
Buy now, pay later - no hyphens
Bullet points - see Lists
C
Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a)
Cardrooms not card rooms
Cases - legal cases should appear in italics, with a v for versus.
Casino-resorts NOT casino resorts or resort-casinos
Chief executive NOT chief executive officer
Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes)
Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000)
Comparisons - compare with (highlighting differences)
- compare to (highlighting similarities)
Companies/organisations - singular entities (it NOT they)
should be followed by âwhich/thatâ rather than âwhoâ
Ltd, not Limited
Complement - to accompany something/add value
Compliment - give praise (complimentary = free)
Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings)
Comprise/comprising - should NOT be followed with âofâ, as it means to âconsist ofâ
Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,)
Continually - if something occurs repeatedly/regularly in the same way
Continuously - if something occurs without interruption or gaps
Contractions - donât, canât, wonât, etc. to be avoided in copy (except in marketing material and depending on tone)
Contrast - by contrast - when comparing one thing to another
- in contrast - simply noting a difference
Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting
Court of Justice of the European Union (CJEU) rather than ECJ
Cryptocurrency - one word, not hyphenated.
ââCrypto-assets - hyphenated
Cybersecurity - one word, not hyphenated
CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism
Currencies - if not using common symbols (ÂŁ, $, âŹ), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar)
m for million, bn for billion, trn for trillion.
D
Date format - Month, Day, Year (e.g., March 7, 2019)
For Insights & Analysis summary text: can just say âtodayâ, e.g., âToday a bill was passed forâŚâ
For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., âOn Wednesday (June 8) a bill was passed...â
For NIBs: always use dates rather than days.
Department for Digital, Culture, Media & Sport - ampersand
Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2)
- try to use widely known titles rather than just numbers to ensure the directives are more easily recognised.
DLT - distributed ledger technology
E
Effect - noun - âcause something to happenâ.
Em dash (â) - should be used as a conjunction, not a hyphen or en dash (â).
Ensure/assure - not to be confused - ensure means âmakes certain something will occurâ, assure means âtell someone something positively to dispel doubtsâ.
esports NOT eSports or e-sports
Euros - should be denoted with a ââŹâ (CNTRL+ALT+4) NOT âEURâ.
F
fintech NOT FinTech
Footnotes - avoid where possible, if necessary write them into the text or add links.
G
GGR - âgross gaming revenuesâ
Government - does not need a capital g.
Governor - should be written out in full, NOT Gov.
Guidance (singular and plural) - does NOT need to be preceded by âaâ (Guide/guides, Guideline/guidelines)
H
Headlines - all words should begin with a capital
Horseracing NOT horse racing
Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if âa fast-tracked applicationâ), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money
- DONâT: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper
I
Impact - should be used as a noun - i.e. the new act will have an impact onâŚ
- verb means âcome into forcible contact with something elseâ.
- using âaffectâ as a verb is more accurate.
J
Judgment - legal decision
Judgement - oneâs own opinion
Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters.
Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive.
OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur
DONâT need capitals unless a figure of importance (i.e., Prime Minister, President)
Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be.
Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team).
K
KYC - know your customer
L
Legislature - does not need a capital l.
Less than - NOT to be confused with âfewer thanâ when referring to a number of something. i.e. fewer than 100 gambling tables.
Licence - noun (UK), i.e. a driverâs licence
License - verb/noun (US)
Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent).
M
MONEYVAL NOT Moneyval
More than - to be used instead of âoverâ. i.e., more than 20 players rather than over 20 players.
N
Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive.
Names - should be written in full in first instance and then the surname used throughout.
Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences.
Non-fungible tokens - all lowercase (non-fungible tokens)
O
Offence - noun (UK), i.e. commit an offence
Offense - noun (US)
Organisations/companies - singular entities (it NOT they)
should be followed by âwhich/thatâ rather than âwhoâ
Oxford comma - (appears before âandâ or âorâ) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one âand/orâ appears).
Over - should not be used as a replacement for âmore thanâ.
P
Parliament - does not need a capital p.
Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act
Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Past/passed - past is a noun/adverb/adjective - âin the pastâ, âpast experienceâ.
- passed is the past tense of âto passâ - âthe law was passed in governmentâ.
Prepaid, not pre-paid
Percentages - numbers should always be written as figures
percent NOT per cent or %
Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent)
Possessives - require an apostrophe and should not be confused with plurals - i.e., an operatorâs licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Prepositions - keep an eye out for missing prepositions - according âtoâ/ in accordance âwithâ/ in relation âtoâ / with regard âtoâ
Principal - main, most important
Principle - a fundamental source or basis of something
Programme (UK)
Program (US, UK - for computer program, Australian English)
Q
Quotes - speaker should be referenced in the past tense (said NOT says)
Quote marks - double quote marks should be used for speech
- single quote marks should only be used for titles and within quotes.
(See Quote reference sheet for more information on how to use quotes.)
R
regtech NOT RegTech
Repetition - avoid using words that mean the same thing (âand alsoâ / âinclude, among othersâ / VLT terminals / ATM machines)
Racetracks not race tracks
S
Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018.
Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act.
Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.)
Sports betting NOT sportsbetting
Sports team names
Storey (pl. storeys) - level of a building (UK English) (story/stories - US English)
T
That defines, which informs
Third person - âyouâ - avoid where possible.
Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a)
Tenses - content should generally be written in past tense
- present tense should be used for something that has just happened and will be continuing into the future.
U
United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC
USA PATRIOT Act - should be kept as such, i.e. with caps, as itâs an acronym for âUniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Actâ)
U.S. Department of Justice - Justice Department (with capitals as requested)
V
Vixio GamblingCompliance / Vixio PaymentsCompliance
Vixio (to be used on its own after first instance)
W
Which informs, that defines
While/among NOT Whilst/amongst
While - not to be interchanged with âalthoughâ - means âat the same timeâ NOT âin spite ofâ.
X
Y
Year quarters - Q1, Q2, H1, H2, etc.
Z
Acronyms
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
API - application programming interface
DLT - distributed ledger technology
---
Now, given the above instructions and style guide, please generate a horizon scanning
update based on the following webpage content. Generate the update regardless of the
source language, content type, or level of detail available â this includes administrative
decrees, personnel appointments, institutional changes, and any other official content.
Use whatever information is present.
Page 1 of 13 CCFPL Complaint Regulations, Text Rule 90008.1: Exemption Rules 90008.3, 90008.4, and 90008.5 of this Article shall not apply to a consumer reporting agency as defined by the Fair Credit Reporting Act (15 U.S.C. Sec. 1681a(f)). Rule 90008.2: Definitions. When used in this Article, the terms defined in Section 90005 of the Financial Code shall have the same meanings set forth in that section. In addition, the following definitions shall apply to terms when used in this Article: (a) âComplaintâ means an expression of dissatisfaction from a complainant regarding a financial product or service, a covered person, or a service provider. (b) âComplainantâ means the consumer who filed the complaint, including a representative or other individual with authority to act on the consumerâs behalf. (c) âDenied complaintâ means a complaint for which the covered person has made a final decision to not take any corrective action. (d) âFinal decisionâ means the conclusion that the covered person, after due consideration and any necessary investigation, has reached regarding the complaint, and has communicated to the complainant. (e) âInquiryâ means a question or request for information, interpretation, or clarification about a financial product or service, a covered person, or a service provider. Rule 90008.3: Complaint Processes and Procedures. A covered person shall respond to consumer complaints and shall develop and implement written policies and procedures for responding to complaints, including a process through which a complainant may submit a complaint to the covered person and receive a final decision. The Department may review the complaint process, including records of each complaint received, to assess the effectiveness of the policies and actions taken in responding to complaints. (a) The complaint process shall include the following procedures regarding the initiation of a complaint. (1) The covered person shall prepare a complaint form for its customers to use in submitting written complaints. The complaint form shall be available in Page 2 of 13 CCFPL Complaint Regulations, Text electronic format on the covered person's website and, upon request, in paper format at each physical location of the covered person accessible to its customers. The complaint form shall include, at a minimum, the following: (A) A description of the complaint process, (B) A field for the complainantâs name, (C) A field for the complainantâs telephone number, (D) A field for the complainantâs mailing address, (E) A field for the complainantâs e-mail address, (F) A field for the complainant to explain the nature and details of the complaint, and (G) An opportunity for the complainant to attach supporting documentation. (2) All written communications to each consumer of a financial product or service shall disclose the procedures for filing complaints with the covered person both orally and in writing. In at least 12-point boldface font, the disclosure shall also inform consumers they may submit to the Department any complaints not resolved to their satisfaction using the form available at https://dfpi.ca.gov/file-a-complaint/ and contact the Department with questions at 866-275-2677. (3) The main page of the website for the covered person shall prominently display a link to the complaint form and instructions on how complainants may submit their oral and written complaints, including the telephone number, e-mail address, mailing address, and website for filing a complaint. (4) The covered person shall maintain a toll-free telephone number, which complainants can use to file complaints orally with a live representative during regular business hours. (5) The covered person shall make the complaint process available to the complainant in the language of the consumerâs contract with the covered person and, if supported by the covered person, the complainantâs preferred language. (6) The covered persons shall not impose a time limit for complainants to file a complaint. Page 3 of 13 CCFPL Complaint Regulations, Text (b) For each complaint, the procedures for the complaint process shall require the covered person to provide the complainant with an acknowledgement of receipt advising that the complaint has been received, including the date of receipt, a unique tracking number to identify the complaint in subsequent communications, and the name, telephone number, and email address of the covered personâs representative who may be contacted regarding the complaint. (1) For complaints received via e-mail or the internet, the covered person shall provide via e-mail a written acknowledgement of receipt within three (3) calendar days of receiving the complaint. (2) For complaints received via postal mail, the covered person shall provide via postal mail a written acknowledgement of receipt within five (5) calendar days of receiving the complaint. (3) For complaints received via telephone, the covered person shall orally confirm receipt of the complaint and provide the complainant with a unique tracking number to identify the complaint in subsequent communications. (4) The written acknowledgement may be combined with the issuance of a final decision required by subdivision (e) of this section if the final decision is issued within the required time period for the acknowledgement. (c) The complaint process shall include the following procedures for a covered person to review and evaluate complaints: (1) Each complaint, including the allegations in the complaint form and all supporting materials submitted by the complainant, shall be reviewed by staff of the covered person who are responsible for the services and operations which are the subject of the complaint. This review shall not be delegated to a third party. (A) For complaints that do not require further investigation, the covered person shall document the name of the individual who decided not to investigate and the reason an investigation was not needed. An investigation shall not be necessary if the covered person makes a full and prompt refund to the complainant of the amount at issue. (B) For complaints that require further investigation, the covered person shall ascertain the cause of the issue by conducting a thorough review of all relevant documents and of the individuals involved in the subject of the complaint. Page 4 of 13 CCFPL Complaint Regulations, Text (C) If corrective action is needed, the covered person shall provide an appropriate remedy to the complainant, including an account adjustment, credit, or refund, and take steps to prevent recurrence of the issue, including appropriate policy changes and employee training. (2) For complaints regarding the conduct of a third party, the covered person shall, in addition to performing its own investigation of the alleged conduct, require the third party to also investigate each complaint using the procedure set forth in subdivision (c)(1)(B) of this section and to forward all relevant documents and findings to the covered person. (3) An officer of the covered person shall be designated as having primary responsibility for the complaint process. (A) The officer shall, at least once each month, review the operation of the complaint process to identify any emerging patterns of complaints, provide appropriate remedies to consumers that experience similar issues, and take steps to prevent recurring problems that adversely affect consumers, including problems that have been addressed with a full and prompt refund. (B) The officer shall, at least once each month, review all complaints regarding the conduct of third parties to determine whether the covered personâs standards for vetting and monitoring third parties were met, whether to take appropriate steps to revise those standards, and whether to continue to do business with each third party. (d) The complaint process shall include a procedure for the covered person to track complaints and communicate with the complainant regarding the status of the complaint. (1) The procedure must include a process for recording the status of a complaint and all target dates for further actions, including the issuance of a final decision. (2) The tracking shall be in a format accessible to the Department upon request. (3) If a complainant contacts the covered person for a status update, including through a toll-free telephone number or customer service e-mail address, the covered person shall respond to the complainant within three (3) calendar days. (e) The complaint process shall include the following procedures for a covered person to respond to a complaint: Page 5 of 13 CCFPL Complaint Regulations, Text (1) The covered person shall respond in writing with a final decision on all issues within fifteen (15) calendar days of receiving the complaint. (A) If the covered person needs additional time to obtain information from a third party, the covered person shall, within three (3) calendar days after the initial 15-day period ends, provide the complainant with a written update regarding the status of the complaint, the reason for the delay, and an estimate of the additional time needed to issue a final decision, which shall not be more than fifteen (15) calendar days after the initial 15- day period ends. (B) For any complainant who claims financial hardship, either orally or in writing, the covered person shall, on an expedited basis, respond with a final decision on all issues within seven (7) calendar days of receiving the complaint. (2) The written response shall contain a clear explanation of the covered person's decision in plain language, including the specific reasons for the final decision, a summary of the steps taken to respond to the complaint, any corrective action that will be taken, and the effective date of the corrective action. In at least 12-point boldface font, the response shall also inform complainants they may submit to the Department any complaints not resolved to their satisfaction using the form available at https://dfpi.ca.gov/file-a-complaint/ and contact the Department with questions at 866-275-2677. (3) The covered person shall ensure there is no adverse action taken against a complainant, including cancellation of the contract, due to the filing of a complaint. (f) The complaint process shall require a covered person to maintain a written record of each complaint for at least five (5) years from the time the complaint was initially filed. The written record shall include the following: (1) The unique tracking number associated with the complaint, (2) The name, phone number, mailing address, and e-mail address of the complainant, (3) The name of the financial service or product involved, (4) The name of the covered person or third party identified as the subject of the complaint, (5) The name of the representative who documented the complaint, Page 6 of 13 CCFPL Complaint Regulations, Text (6) The date the complaint was received by the covered person, (7) The date the covered person provided the acknowledgement of receipt, (8) The dates of any investigation by the covered person, (9) The dates of all responses to the complainant, and (10) The nature and details of the complaint, (11) If no investigation was performed, the name of the person who decided not to investigate and the reason an investigation was not needed, (12) The results of any investigation, (13) Any corrective action taken in response to the complaint, (14) A copy of all contracts, correspondence, and other relevant information upon which the covered person relied in reaching its final decision, and (15) A copy of all written responses and summaries of all oral responses, including an explanation of the final decision regarding the complaint. (g) The complaint process shall be administered without discriminating on the basis of the complainantâs race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, veteran or military status, or any other basis prohibited by law. (h) The covered person shall submit to the Department a quarterly complaint report, which shall be made available to the public. The report shall be prepared for the quarters ending March 31, June 30, September 30 and December 31 of each calendar year, verified by an officer authorized to act on behalf of the covered person, and filed with the Consumer Financial Protection Division, no later than thirty (30) calendar days after the end of each quarter. The report shall include for each quarter: (1) The covered person's name, the date, and the reporting quarter, (2) The total number of complaints received, (3) The total number of complaints for which a final decision was issued within fifteen (15) calendar days of receiving the complaint, Page 7 of 13 CCFPL Complaint Regulations, Text (4) The total number of complaints for which a final decision was issued between sixteen (16) and thirty (30) calendar days of receiving the complaint, (5) The total number of complaints for which a final decision was issued more than thirty (30) calendar days after receiving the complaint, (6) The total number of complaints for which a final decision was not issued, (7) The total number of complaints denied, (8) The total number of complaints resulting in a partial refund, (9) The total number of complaints resulting in a full refund, (10) Regarding each complaint for which a final decision was issued more than fifteen (15) calendar days after receipt, an explanation of why the final decision was not issued within fifteen (15) calendar days, (11) Regarding each complaint for which a final decision was not issued, an explanation of why the final decision was not issued, (12) The number of complaints received for each complaint type. Complaint types shall include, but not be limited to, the following: (A) dissatisfaction with the covered person, (B) dissatisfaction with a service provider, (C) dissatisfaction with a third party to whom the covered person referred the consumer, (D) dissatisfaction with a third party who brought the consumer to the covered person through lead generation, (E) attempts to collect debt not owed, (F) trouble during the payment process, (G) dissatisfaction with the taking or threat of taking negative legal action, (H) complaints of false statements or representations, (I) problems closing an account, (J) improper fees or interest, Page 8 of 13 CCFPL Complaint Regulations, Text (K) unauthorized transactions, (L) confusing or missing disclosures, and (M) problems with customer service. (13) Any patterns of complaints identified by the officer responsible for the complaint process and all corrective action taken to provide appropriate remedies to consumers and to prevent recurring problems, and (14) Any steps taken to ensure the complaint process is administered without discriminating on the basis of the complainantâs race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, or veteran or military status. Rule 90008.4: Inquiry Processes and Procedures. A covered person shall respond to inquiries from consumers and develop and implement written policies and procedures for responding to inquiries. The procedures shall include the following: (a) The covered person shall review and evaluate each inquiry to determine whether the inquiry should be handled as a complaint. If the consumer indicates any dissatisfaction with a financial product or service or alleges any mistake or wrongdoing by the covered person or a third party, the inquiry shall be handled as a complaint using the process described in Rule 90008.3. (b) For each inquiry, the procedures shall include the following: (1) The covered person shall respond to all issues raised by the inquiry within three (3) calendar days of receiving the inquiry. If additional time is needed to obtain information from a third party, the covered person shall notify the consumer within three (3) calendar days of receiving the inquiry and provide a response within seven (7) calendar days of receiving the inquiry. The response shall be in the same format in which the inquiry was made. (2) The covered person shall maintain a written record for each inquiry with the following information: (A) The name, phone number, mailing address, and e-mail address of the consumer who made the inquiry, (B) The name of the financial service or product involved, Page 9 of 13 CCFPL Complaint Regulations, Text (C) The name of the covered person or third party identified as the subject of the inquiry, (D) The name of the representative who documented the inquiry, (E) The date the inquiry was received by the covered person, (F) The dates of all responses to the consumer who made the inquiry, (G) The nature and details of the inquiry, (H) A copy of all contracts, correspondence, and other relevant information upon which the covered person relied in responding to the inquiry, and (I) A copy of all written responses to the inquiry and summaries of all oral responses to the inquiry. (c) The covered person shall track and categorize inquiries by product feature, including but not limited to the following, to help determine if there are issues or problems with a financial product or service that may result in customer confusion: (1) Questions regarding fees, (2) Questions regarding the cost of the product or service, (3) Questions regarding how the product or service works. (4) Questions regarding how the consumer can access funds. (d) The process for responding to inquiries shall be administered without discriminating on the basis of the race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, or veteran or military status of the consumer who made the inquiry or any other basis prohibited by law. (e) All covered entities shall submit to the Department an annual report regarding inquiries. The report shall be prepared for each calendar year, verified by an officer authorized to act on behalf of the covered person, and filed with the Consumer Financial Protection Division, no later than thirty (30) days after the end of each calendar year. The report shall include: (1) The covered person's name, the date, and the reporting year, Page 10 of 13 CCFPL Complaint Regulations, Text (2) The total number of inquiries filed, (3) The total number of inquiries for which a response was provided within three (3) calendar days of receiving the inquiry, (4) The total number of inquiries for which a response was provided between three (3) and seven (7) calendar days of receiving the inquiry, (5) The total number of inquiries for which a response was provided more than seven (7) calendar days after receiving the inquiry, (6) The total number of inquiries for which a response was not provided, (7) Regarding each inquiry for which a response was provided more than three (3) calendar days after receipt, a brief explanation of why the response was not provided within three (3) calendar days, (8) Regarding each inquiry for which a response was not provided, a brief explanation of why the response was not provided, and (9) The number of inquiries received for each tracked category, as required by subdivision (c) of this section. Rule 90008.5: Processes and procedures for covered persons to provide a timely response to the Department. (a) Each covered person shall provide the Department with a designated e-mail address for receiving requests from the Department regarding consumer complaints. The designated e-mail address shall be accessible by the officer of the covered person with primary responsibility for the complaint process. In the event of a change to the designated e-mail address, the covered person shall, within three (3) calendar days of the change, provide the Department with the new designated e-mail address. (b) A covered person shall develop and implement written policies and procedures for responding to requests from the Department regarding a consumer complaint, including the following: (1) If a complaint regarding the same subject matter has already been filed with the covered person and a final decision has been issued to the complainant, the covered person shall, within ten (10) calendar days of the Departmentâs request, provide a written response to the Department and attach the complete written record required by Rule 90008.3(f). Page 11 of 13 CCFPL Complaint Regulations, Text (2) In all other cases, the covered person shall, within fifteen (15) calendar days of receiving the Departmentâs request, review and evaluate the complaint using the procedures set forth in Rule 90008.3(c) and provide a written response to the Department with: (A) A clear explanation of the final decision in plain language, including the specific reasons for the decision and a summary of the steps taken to respond to the complaint, (B) The items required in Rule 90008.3(f) for the written record, and (C) Any follow-up actions or planned follow-up actions by the covered person to respond to the complaint. (D) If the covered person needs additional time to obtain information from a third party, the covered person shall, within three (3) calendar days after the initial 15-day period ends, provide the Department with a written update regarding the status of the response, the reason for the delay, and an estimate of the additional time needed to provide the items, which shall not be more than fifteen (15) calendar days after the initial 15- day period ends. (3) The Department may send follow-up requests for information from the covered person after receiving the initial written response required by subdivisions (b)(1) and (b)(2) of this section. The covered person shall, within ten (10) calendar days of each follow-up request, provide a written response to the Department with all requested information. (c) Every covered person shall develop and implement written policies and procedures for responding to requests from the Department regarding a consumer inquiry, including the following: (1) If an inquiry regarding the same subject matter has already been filed with the covered person and a response has been issued to the consumer, the covered person shall, within ten (10) calendar days of the Departmentâs request, provide a written response to the Department and attach the complete written record required by Rule 90008.4(b)(2). (2) In all other cases, the covered person shall, within fifteen (15) calendar days of receiving the Departmentâs request, address all issues raised by the inquiry and provide a written response to the Department with the items required by Rule 90008.4(b)(2). (3) The Department may send follow-up requests for information from the covered person after receiving the initial written response required by Page 12 of 13 CCFPL Complaint Regulations, Text subdivisions (c)(1) and (c)(2) of this section. The covered person shall, within ten (10) calendar days of each follow-up request, provide a written response to the Department with all requested information. Rule 90008.6: Consumer requests for nonpublic or confidential information - Definitions. For purposes of subdivision (d)(2)(D) of Financial Code section 90008, (a) âNonpublic or confidential informationâ means: (1) confidential supervisory information, (2) proprietary information confidentially maintained by the covered person or service provider, including trade secrets, of which the release would be damaging or prejudicial to the business concern, or (3) personal information not publicly available regarding a consumer other than the one making the request for information. (4) âNonpublic or confidential informationâ does not include information contained in records made publicly available by the Department or information that has otherwise been publicly disclosed by an employee or agent of the Department with the authority to do so. (b) âConfidential supervisory informationâ means: (1) any documents, materials, or records, including reports of examination, prepared by, on behalf of, or for the use of the Department or any other federal, state, or foreign government agency in the exercise of regulatory oversight of a covered person or service provider, and any information derived from such documents, materials, or records, (2) any communications between the Department and a covered person or service provider related to the Departmentâs regulatory oversight of the covered person or service provider, and (3) any information provided to the Department by a covered person or service provider for purposes of detecting and assessing risks to consumers and to markets for consumer financial products or services, or to assess whether an entity should be considered a covered person or is subject to the Departmentâs regulatory oversight. (c) âPersonal informationâ means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, Page 13 of 13 CCFPL Complaint Regulations, Text directly or indirectly, with a particular consumer or household. âPersonal informationâ does not include consumer information that is deidentified or aggregated. (d) âPublicly available informationâ means information lawfully made available to the public from federal, state, or local government records.