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Greentube Alderney Limited Regulatory Settlement

This regulatory settlement consists of:

  • a payment of £1,000,000 in lieu of a financial penalty, this includes a divestment of £22,113. The money will be directed to socially responsible purposes
  • agreement to the publication of a statement of facts in relation to this case
  • payment towards the Commission’s costs of investigating the case.

In considering an appropriate resolution to this investigation, the Commission has had regard to the following aggravating and mitigating factors:

Aggravating factors

  • the failings were serious and potentially impacted on the licensing objectives
  • in 2021 the Commission accepted a regulatory settlement from Greentube Alderney Limited for historical failings in relation to AML/CTF and SR controls
  • the breach arose in circumstances that were similar to previous cases the Commission has dealt with which resulted in the publication of lessons learned for the wider industry.

Mitigating factors

Greentube Alderney Limited:

  • swiftly put in place an action plan designed to remedy the failings and provided updates
  • fully co-operated with the investigation and provided information by agreed deadlines
  • accepted the failings at an appropriately early stage in the investigation.

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions and take remedial action where required:

  • do you have effective processes in place to test and assess whether your policies, procedures and controls are being effectively implemented by staff? Is this recorded and demonstrable?
  • do you have set turnaround times for manual reviews, actions, processes, etc? Are these routinely met?
  • have staff received adequate initial and refresher training? Is this recorded and demonstrable?
  • do you have an effective method to disseminate feedback, good practice and lessons learned to your staff?
  • do you fully consider the risks associated with customers who may have access to third-party funds which could be misappropriated?
  • do you fully investigate accounts and mitigate risks when links are identified?
  • are you fully scrutinising all customer information available to you in a timely manner, properly assessing and taking steps to mitigating potential ML/TF and SR risks?
  • do you have a good system for cross-departmental sharing of information and concerns? For example, would your Fraud/AML agents alert your social responsibility agents if a bank statement showing financial vulnerability was received?
  • do you act quickly enough when customers display potential markers of harm? Do your procedures specify appropriate timescales for actions and interactions?
  • if you deviate from your policies and procedures, are you able to justify this and do you fully document those decisions and the rationale?
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Greentube Alderney Limited Findings

Last updated: 9 January 2025

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