Social responsibility failures included:
- Setting safer gambling interaction triggers too high and when customers’ spend increased considerably, which can be an indicator of harm, no further safer gambling account review was conducted in a timely manner– one customer was first interacted with when they had deposited £20,700 and lost £10,200 but then the next interaction did not occur until four months later when the customer had deposited £323,715 and lost £69,371.
Anti-money laundering failures included:
- Not fully taking into account the money laundering and terrorist financing (MLTF) risks connected to its business, in particular risks connected to country or geographic area, customers, transactions, and product and services
- Not having appropriate policies, procedures and controls in place to manage and mitigate the MLTF risks, including thresholds that were inadequate, having insufficient information on customers and no evidence of ongoing monitoring prior to initial financial triggers being reached.
- Not ensuring that its policies, procedures and controls were implemented effectively, including not following guidance issued by the Commission and not taking into account any applicable learning or guidelines published by the Commission
- Failing to thoroughly implement the measures described in the Money Laundering Regulations, including failing to identify the MLTF risks to which the business was subject and failing to establish and maintain policies, procedures and controls to manage and mitigate the risks effectively.
- The operator also provided inadequate employee training, failed to scrutinise transactions to ensure that that they were consistent with their knowledge of the customer and their risk profile, and failed to conduct sufficient anti-money laundering, customer due diligence and source of funds checks.