Greentube Alderney Limited Findings
A Commission compliance assessment and subsequent regulatory review found:
Breach of Paragraph 3 of Licence Condition 12.1.1
LCCP 12.1.1(3) requires:
"Licensees must ensure that such policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time."
We found that, on occasion, Greentube Alderney Limited did not ensure that its policies, procedures and controls were effectively implemented.
Specifically, Greentube Alderney Limited did not always:
scrutinise available information upon receipt, or in a timely manner, leading to an avoidable delay in the identification and potential escalation of money laundering/terrorist financing risk(s). For example, after registering an online account, a customer provided a bank statement as proof of address. The bank statement showed complex and unusual transactions, including over £100,000 being transferred in and out of the account (in multiple transactions), and a negative closing balance. It was only when the ML risk increased, as the customer’s spend reached a designated threshold four months later, that the bank statement was scrutinised, and the matter escalated to the Money Laundering Reporting Officer (MLRO) in accordance with its policy.
fully investigate and escalate accounts showing apparent links to other accounts in a timely manner. Greentube Alderney Limited’s policy does not permit duplicate accounts. Whilst some of its controls were effective Officials saw examples where pertinent information regarding potential links between accounts was received by the Licensee but not fully considered and acted upon, until a financial trigger had been reached. This led to an avoidable delay in investigation, escalation and actions taken to mitigate potential ML/TF risks of accounts being potentially funded or controlled by a different account holder. Officials saw one example where potential links (address and surname) to an individual with previous convictions for the supply of class A drugs were not fully considered and escalated in a timely manner.
follow its policy regarding what it refers to as “risky occupations”. Although its controls considered risks posed by the industry in which the customer is employed, there were certain circumstances which resulted in insufficient consideration being given to the risk posed by persons who had access to third-party funds which could have been misappropriated and used to fund the person’s gambling. For example, in one case the potential increased risk posed by a ‘finance manager’ was not recognised or built into the customer’s risk profile, and no steps were taken to mitigate the increased risk.
follow its recycled winnings policy. Greentube Alderney’s policy specified a time period for accepting ‘recycled winnings’ (winnings which have been withdrawn and redeposited) after which the customer’s source of funds would be requested. This is to mitigate the potential ML/TF risks associated with money subsequently deposited being from a different source to that previously won and withdrawn. However, the operator did not always follow that policy. In one example, following a large win and withdrawal, a customer was allowed to continue depositing funds from different payment methods long after the specified time period without the operator requesting source of funds information. In total over £70,000 was deposited without the customer being asked to evidence their source of funds.
The Commission’s review of the specific customers identified during the compliance assessment found no evidence of money laundering or criminal spend with the Licensee.
Failure to comply with paragraphs 1 and 8 of SRCP 3.4.3
Compliance with a SRCP is a condition of the licence by virtue of section 82(1) of the Act.
SRCP 3.4.3 paragraph 1 requires:
"Licensees must implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. These systems and processes must embed the three elements of customer interaction – identify, act and evaluate – and which reflect that customer interaction is an ongoing process as explained in the Commission’s guidance (see paragraph 2)."
We found that on occasion Greentube Alderney Limited had not ensured that its policies, procedures and controls had been effectively implemented.
Specifically, Greentube Alderney Limited:
failed to fully and effectively implement its policy regarding big/high winners.
The operator had a policy aimed at ensuring customer limits are based on regular, sustainable income - as opposed to one-off or irregular forms of income. The Commission saw one customer example where, following a withdrawal of significant winnings, a customer was permitted to deposit significant sums for a period greatly in excess to that specified in its policy. The deposits were made without any evidence being provided by the customer confirming the source of the further deposits were the original withdrawn winnings.did not always fully and effectively implement its processes regarding the legitimacy of documents. Despite its agents receiving training on fraudulent documents, it was found that agents did not always apply their training.
did not fully and effectively implement its controls to identify indicators of vulnerability/potential harm in a timely manner.
Officials saw examples where documentation provided by customers – which indicated potential financial vulnerability – was either not reviewed at all or was not reviewed or escalated until a financial trigger was hit or a concerning comment made. As a result, customers were allowed to deposit at higher limits despite Greentube Alderney Limited being in possession of documentation showing issues such as low account balances, overdrafts, transactions to other gambling operators, deposits disproportionate to salary, and social/housing benefits. For example, one customer supplied a bank statement (as proof of address) that had a negative opening and closing balance and included numerous transactions to another gambling operator. There was no evidence that the bank statement had been considered, and the potential vulnerabilities identified from a social responsibility perspective, four months later when the account was blocked for AML reasons. Over £4,000 had been deposited during this period.
SRCP 3.4.3 paragraph 8 requires:
"Licensees must take appropriate action in a timely manner when they have identified the risk of harm."
We found that, on occasion, Greentube Alderney Limited did not always take appropriate action in a timely manner when the risk of harm was identified.
In some accounts reviewed, although risk indicators/markers of harm were present in a customer’s journey and a phone interaction was deemed appropriate, the calls were not performed promptly, rather they were postponed whilst further monitoring took place and/or until a further/higher trigger had been hit or other behaviour prompted it.
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Last updated: 9 January 2025
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