General Betting
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Looks like the answer is a big NO:
http://www.hblb.org.uk/document.php?id=404
http://www.hblb.org.uk/document.php?id=404
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9. In particular, the term 'effecting betting transactions' is to be understood as
meaning making arrangements for betting transactions to happen,
facilitating such transactions, bringing them about or causing them to
happen.
10. Traditional bookmakers meet this test since they facilitate or arrange
betting transactions. Likewise, betting exchanges meet this test since they
arrange the bet by matching backers and layers together. However,
customers of betting exchanges do not meet this test since they do not
facilitate, arrange or bring about the bet or betting transaction; instead they
rely on the betting exchange to provide that service.
9. In particular, the term 'effecting betting transactions' is to be understood as
meaning making arrangements for betting transactions to happen,
facilitating such transactions, bringing them about or causing them to
happen.
10. Traditional bookmakers meet this test since they facilitate or arrange
betting transactions. Likewise, betting exchanges meet this test since they
arrange the bet by matching backers and layers together. However,
customers of betting exchanges do not meet this test since they do not
facilitate, arrange or bring about the bet or betting transaction; instead they
rely on the betting exchange to provide that service.
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