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Public statement

Maple International Ventures Limited Public Statement

Published:
17 September 2025
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Our public statements make reference to breaches of the Licence Conditions and Codes of Practice (LCCP) requirements which were in effect at the time of the breach. In some cases, the requirements have since been updated.

Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.

Introduction

Licensed gambling operators have a legal duty to ensure their gambling facilities are provided in compliance with the Gambling Act 2005 (opens in new tab)(the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

  • prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime
  • ensure that gambling is conducted in a fair, safe and open way
  • protect children and other vulnerable people from being harmed or exploited by gambling.

Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.

Maple International Ventures Limited Executive Summary

A section 116 (of the Act) regulatory review was commenced following a compliance assessment (conducted in June 2024) of the remote operating licence of Maple International Ventures Limited (licence number 051833-R-329042-007).

The review found failings in Maple International Ventures Limited’s Anti-Money Laundering / Counter Terrorism Financing (AML/CTF) and Social Responsibility (SR) controls.

Maple International Ventures Limited failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

In line with our Statement of Principles for Licensing and regulation, Maple International Ventures Limited will make a payment in lieu of a financial penalty of £360,000. Details of this are set out under the heading Regulatory Settlement.

Maple International Ventures Limited Findings

A Commission compliance assessment and subsequent regulatory review found:

Breach of paragraphs 1, 2 and 3 of Licence Condition 12.1.1

LCCP 12.1.1(1) requires:

"Licensees must conduct an assessment of the risks of their business being used for money laundering and terrorist financing. Such risk assessment must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic or any other material changes, and in any event reviewed at least annually."

We found that Maple International Ventures Limited’s risk assessment was not appropriate between June 2023 and July 2024.

Some key risks were omitted from the Licensee’s risk assessment (for example, organised crime gangs and mule accounts) and it was lacking in sufficient detail. In addition, there was no evidence that it had been updated to take into account current or historical versions on the Commission’s Risk Assessment, AML Guidance or Emerging Risks publications.

LCCP 12.1.1(2) requires:

"Following completion of and having regard to the risk assessment, and any review of the assessment, licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing."

We found that, between May and October 2024, Maple International Ventures Limited failed to ensure it had appropriate policies, procedures and controls to prevent money laundering and terrorist financing.

We found the controls for detecting and taking action regarding duplicate and linked accounts were not always effective.

For example, a customer was able to evade the Licensee’s automated controls by switching the order of one of their first names (they had two ‘first’ names) and their surname. The account was only identified the following day after significant deposits and losses had already been made.

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, between May and October 2024, Maple International Ventures Limited failed to ensure its policies, procedures and controls to prevent money laundering and terrorist financing were implemented effectively.

We found the time delay between a Money Laundering (ML) risk being identified and action being taken meant customers could transact beyond some intended thresholds.

For example, customers whose identities had not been fully verified were able to continue transacting beyond the financial threshold that had been set for undertaking Customer Due Diligence checks.

The Commission’s review of the specific customers identified during the compliance assessment found no evidence of criminal spend with the Licensee or the acceptance of funds from persons subject to financial sanctions.

Failure to comply with paragraphs 1, 4, 5 (a-d) and 11 of SRCP 3.4.3

Compliance with a SRCP is a condition of the licence by virtue of section 82(1) of the Act.

We found that between May and October 2024 Maple International Ventures failed to comply with the following requirements relating to remote customer interaction.

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)."

Maple International Ventures Limited had not always ensured that its policies, procedures and controls had been effectively implemented.

SRCP 3.4.3 paragraph 4 requires:

"Licensees must have in place effective systems and processes to monitor customer activity to identify harm or potential harm associated with gambling, from the point when an account is opened."

The processes for monitoring customer activity from the point an account was opened were not always effective as there were weaknesses in systems designed to identify duplicate and linked accounts.

For example, although the Licensee only permitted one account per customer, one customer was able to evade the duplicate account controls and open a second account (almost one year after the first) and make significant deposits before the second account was identified.

SRCP 3.4.3 paragraph 5 (a-d) requires:

"Licensees must use a range of indicators relevant to their customer and the nature of the gambling facilities provided in order to identify harm or potential harm associated with gambling. These must include:

a. customer spend b. patterns of spend c. time spent gambling d. gambling behaviour indicators"

The controls for identifying potential harms were inadequate in relation to ‘binges’, ‘spikes’, overnight play and large wins which are followed by high-staking.

SRCP 3.4.3 paragraph 11 requires:

"Licensees must ensure that strong indicators of harm, as defined within the licensee’s processes, are acted on in a timely manner by implementing automated processes. Where such automated processes are applied, the licensee must manually review their operation in each individual customer’s case and the licensee must allow the customer the opportunity to contest any automated decision which affects them."

The Licensee’s policies did not adequately define what it considered to be strong indicators of harm and there were no associated automated actions.

Maple International Ventures Limited Regulatory Settlement

This regulatory settlement consists of:

  • a payment in lieu of a financial penalty of £360,000, which includes a divestment of £50,000. 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

  • although Maple International Ventures Limited had been aware that customers could surpass its financial threshold for full customer due diligence checks and was working to remedy this by the time the Commission’s assessment began, an effective fix was only implemented after discussions held during the assessment
  • the Commission has previously issued public statements regarding similar issues which it has observed in relation to other operators.

Mitigating factors

Maple International Ventures Limited:

  • has an unblemished regulatory history
  • 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 ensure that your ML/TF risk assessment is reviewed as necessary and at least annually? Does it include all of the risks relevant to the licensed activities?
  • are your AML/CTF financial thresholds automated hard-stops? When a threshold is reached, do you act swiftly enough to review accounts and mitigate risks or can customers continue to make significant transactions after they exceed the thresholds?
  • do you have adequate checks (both automated and manual) to identify duplicate or linked accounts? Are your controls broad and robust enough to detect similarities or do they rely on certain key fields to be identical? Could a customer evade them by changing just one or two details?
  • would your safer gambling controls identify all of the potential indicators of harm, as required by SRCP 3.4.3?
  • if you use an algorithm as part of your safer gambling controls, how have you chosen the levels which raise a flag or alert? How do you test that your algorithm is adequately detecting potential harms?
  • can you demonstrate that you assess the impact of your customer interactions?
  • do your safer gambling policies and procedures clearly define what you consider to be a strong indicator of harm? Do you have automated controls to act on these indicators in a timely manner?
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