Commission publishes conclusion of investigation into IMME Ltd

22 December 2021

The Commission has published the conclusion of an investigation into gambling business International Multi-Media Entertainments Limited (IMME).

IMME had provided facilities for the betting on the outcome of international lotteries under a real event betting licence, obtaining custom by calling consumers and hosting its website lotteries.com.

IMME also currently run a lottery syndicate business which does not require a licence. This side to IMME’s business is reliant on staff calling consumers and using the thelotterycentre.com website for its digital marketing.

Following concerns raised about the way the business was conducted the Commission suspended IMME’s operating licence and launched an investigation.

This revealed significant suitability, social responsibility and money laundering failures.

Suitability concerns included:

• customers complaining of being called repeatedly by IMME sales agents, including one customer in her 90s who was called several times a week. Another complainant stated that a Lotteries.com customer was called every 30-40 minutes, five or six times until the phone was answered
• 75% of its customers were over 60 years old and 20% were over 80 years old. This demographic seems disproportionately focused on older people and IMME had not considered the potential vulnerabilities of their customer base
• multiple complaints by consumers to the police and Action Fraud about IMME’s products
• call centre staff using aliases which raises the question as to why a staff member might be told to or choose to be dishonest about their real name.

Social Responsibility failings included:

• IMME was unable to evidence adequate safer gambling interactions with its customers to the Commission
• there were no records of interactions with a customer (78 years old) who spent £63,951 in just over three months
• one customer (74 years old) was allowed to deposit £9,379 in eight days without an adequate responsible gambling interaction.

Money laundering failures included:

• one customer, who was 100 years old at the time the Commission review was started, bet £23,839 in just five months. His deposits more than doubled from £2,992 in September 2018 to £6,090 in October 2018 and continued to rise but IMME did not obtain source of funds evidence
• IMME knew that two of its top depositors were retired postmen but allowed one to bet £20,345 in five months and other to bet £16,207 in six months without obtaining further information to support that level of spend.

Helen Venn, Commission Executive Director, said:

“We will not tolerate gambling businesses behaving in the way IMME did.

“Gambling operators in Britain must follow our social responsibility and anti-money laundering rules, and a failure to do this will lead to us taking tough action.

“We suspended IMME’s licence following initial concerns and - having delved even deeper into the business’s activities - discovered failures that would have inevitably led to complete licence revocation had the operator not surrendered it.

“There is no room in Britain’s gambling industry for operators who fail in the way IMME have.”

Public statements

International Multi-Media Entertainments Limited (IMME)

Published: 22 December 2021

Read the public statement

Note to editors

Journalists can contact our press office on 0121 230 6700 or email: communications@gamblingcommission.gov.uk

For all media enquiries, please contact the Gambling Commission press office.

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Last updated: 22 December 2021

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