Response to Call for Views on Reducing Offending and Reoffending Strategy

‍ ‍The Department of Justice is currently developing a new strategy to reduce offending and reoffending in Northern Ireland. The All Party Group on Reducing Harm Related to Gambling submitted a response to the Call for Views on the new strategy, following engagement with the Justice Minister. See our response below.

2a. Which of the following factors do you consider contribute to, or increase the risk of, offending in Northern Ireland today? (Please select all that apply)‍ ‍

Other: gambling addiction

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2c. Please provide examples/references/evidence links from Northern Ireland or elsewhere or through lived experience that supports your views in 2a & 2b.

There is a significant link between gambling behaviour and crimes such as fraud, theft, and embezzlement. According to the most recent Gambling Survey for Great Britain, 18.8% of adults in GB with a Problem Gambling Severity Index (PGSI) score of 8 or higher, indicating “problem gambling”, say they have committed a crime in order to finance gambling or to pay gambling debts.1 ‍

While official figures for Northern Ireland (NI) are lacking, NI has a higher rate of problem gambling than GB (3% compared to 2.4%).2

Research indicates that as addiction escalates, often worsened by loyalty schemes, individuals resort to “financial misappropriation,” such as taking loans they intend to repay with winnings.3 These offenders are typically first-time offenders unlikely to have a “criminal lifestyle”.4 ‍

In R v Archie Musgrove, the Court of Appeal recorded the expert evidence of Dr Matt Gaskell, Clinical Lead at the NHS Northern Gambling Clinic. Dr Gaskell's opinion was that the appellant “had a severe gambling disorder at the time of his offences. A gambling disorder significantly alters thinking, attention, decision making and behaviour. In my opinion, and from the available evidence, it is the main cause of his index offences. Without the gambling disorder I do not believe that he would have committed the offences.”5

‍1 Gambling Commission (2026). Gambling Survey for Great Britain 2025 [see Table D.16 of annual report]

2 Department for Communities (2025). Prevlance of Gambling in Northern Ireland 2024. Compared to Gambling Survey for Great Britain. 

‍3 Smith, G. and Simpson, R. (2014). Gambling Addiction Defence on Trial: Canadian Expert Witness Perspectives

‍4 Binde, P., Cisneros Örnberg, J., & Forsström, D. (2022). Criminogenic problem gambling: a study of verdicts by Swedish courts

‍ ‍5 Rex v Archie Musgrove, 17 Jun 2025 [2025] EWCA Crim 1202, CA

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3b. Please list any other factors that you consider might contribute to, or increase the risk of, reoffending in Northern Ireland today.

Data from the Probation Board for Northern Ireland (PBNI) shows that gambling was linked to reoffending for 2-3% of service users between 2016 and 2018,1 while 4% of its 2023 caseload self-declared gambling as a problem.2

1 PBNI ACE (Assessment, Case Management and Evaluation System) Risk and Needs Profiles for 2016/17 and 2017/18

2 PBNI (2023), Gambling Addicts at Higher Risk During the Festive Season

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4a. In your experience, which approaches, support or services do you believe help prevent people coming into contact with, or entering, the criminal justice system for the first time?

A public health approach to tackling gambling-related harm would help prevent people from entering the criminal justice system for the first time as a result of gambling addiction. A public health approach, as outlined in the APG on Reducing Harm Related to Gambling’s 2024 inquiry report,1 involves taking actions that affect the whole population to prevent and reduce gambling harm. This includes regulating gambling products, restricting advertising, and educating people about the risks associated with gambling.

Gambling laws must be properly enforced, to ensure that consumers are protected from gambling-related harms. Reports compiled by investigative services firm FACT shows that prior to the enactment of the Gaming (Variation of Monetary Limits) Order (NI) 2025, gaming machines in licenced gambling premises offered stake and prize limits far in excess of the legal maximums; and, following the enactment of the 2025 Order, licenced gambling premises have continued to have more than the maximum of two machines. 2

Gambling support and treatment services, including debt advice services, may allow individuals experiencing gambling harms to address issues before they are in a position where they are driven to commit crime to further fund their gambling addiction or pay off debts.

1 APG on Reducing Harm Related to Gambling (2024). Public Health Approaches to Tackling Gambling-Related Harms in NI‍ ‍

2FACT Investigation Report: Fixed Odds Betting Terminals – Northern Ireland (1 August 2024 and 29 July 2025). These reports were shared with Minister for Justice Naomi Long MLA on 25 February 2026.

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4b. Please provide examples/references/evidence links from Northern Ireland or elsewhere or lived experience that supports your views in 4a.

‍ Evidence gathered by the Commission on Crime and Gambling Related Harms found that “constraints in the availability of existing services and the lack of awareness and/or proactivity of potential signposters and supporters… puts the prospect of accessing timely, appropriate support and treatment which might prevent crime out of reach”. 1

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1 1The Commission on Crime and Gambling Related Harms (2023). Final report

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5a. Which types of support or services help people to stop reoffending?

‍ People who enter the criminal justice system due to crimes associated with their gambling addiction should be directed into gambling treatment services. The Commission on Crime and Gambling Related Harms recommended that supports are “aligned to suspended sentences, community penalties and sentences, and prison sentences”.1

‍1 The Commission on Crime and Gambling Related Harms (2023). Final report

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5b. Please provide examples/references/evidence links from Northern Ireland or elsewhere or lived experience that supports your views in 5a.

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In written evidence submitted to the DCMS Select Committee call for written evidence on the UK Government's White Paper on Gambling Reform, researchers from the Research Centre for Crime, Justice and Security at Staffordshire University stated that “when gambling ceases for someone addicted to gambling, gambling-related crime reduces and eventually ceases”.1‍ ‍

1Research Centre for Crime, Justice and Security, Staffordshire University (2023). Written evidence submitted by Sarah Page (Associate Professor in Social Justice and Social Learning), Lucy Pointon (Lecturer in Criminology), Associate Professor Dr Jo Turner (Head of Department in the School of Justice, Security and Sustainability and Associate Professor in Criminology) and Sarah Plimley (Lecturer in Policing).

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In terms of the new reducing offending and reoffending strategy, do you agree with the suggested:

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8a. Strategic Aim 1 - To reduce offending through prevention and early intervention by: - addressing the underlying drivers of harm, and - supporting people at the earliest possible stage, before they enter the criminal justice system.

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YES

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8b. Strategic Aim 2 - To reduce offending by strengthening deterrence, rehabilitation and resettlement by supporting those who come into the contact with the criminal justice system to: - address offending behaviour, - stabilise their lives, and - move away from further harm.

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YES

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8c. Strategic Vision: A safer, fairer Northern Ireland where opportunity, support and partnership working, prevents harm and reduces offending and reoffending. 'Working together to create better life chances and choices.'

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YES

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8d. Themes, outcomes and priorities:

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YES

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8e. Please provide any further comments or evidence in relation to your response to questions 8a, 8b, 8c and 8d.

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Theme and Outcome 1 – Health & Wellbeing

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We strongly support a “public-health model of prevention and early intervention”, and believe this approach should be applied to gambling-related harm and crime. Gambling addiction should be recognised as pathway into offending, and should be addressed through proactive, needs informed and evidence-based intervention.

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Early intervention can help prevent gambling-related harm. Recent research commissioned by the Gambling Regulatory Authority of Ireland found that those who gambled as a child were almost twice as likely to suffer from problem gambling in adulthood, and having a parent who gambled increased the likelihood of problem gambling in adulthood by one third.1

‍Gambling addiction is often present alongside other addictions, including alcohol and drugs. Delivering person-centred, integrated support is the best way to enable recovery.

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Theme and Outcome 2 – Community & Inclusion‍ ‍

Physical environments can have a crime-producing impact. Recent research by the University of Essex found that in England and Wales gambling outlets are significantly and positively associated with different types of crime even when controlling for other businesses, the areas’ demographic and socio-economic characteristics.2 ‍ ‍

It is also important to acknowledge that gambling premises are disproportionately clustered in the most deprived areas.

We support efforts to promote pro-social identity and collective wellbeing among children and young people, for example through sport. Steps should be taken to ensure young people are not bombarded with gambling advertising while participating in these activities.

‍Consideration should be given to a ban on gambling advertising and marketing at events likely to be attended by children, as has been introduced in the Republic of Ireland under the Gambling Regulation Act 2024.  ‍

Consideration should be given to the proximity of betting shops and adult gaming centres to schools and other places where children are present when issuing licences.

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1 Ó Ceallaigh, D., Timmons, S., Robertson, D. and Lunn, P. (2026). Childhood gambling experiences and adult problem gambling

‍ 2 Demivera, N., & Iacono, S. L. (2024). Gambling outlets as agents of local area disorganization: Crime and local institutions, the case of the UK

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September 2025: APG Response to Gambling Related Harm APPG inquiry on The Future of Gambling Regulation in the UK