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Raising Standards for consumers - Compliance and Enforcement report 2020 to 2021

The Gambling Commission's report on Compliance and Enforcement action 2020 to 2021

  1. Contents
  2. Case studies

Case studies

During a compliance assessment, Anti-money laundering (AML) policies and procedures and safer gambling control deficiencies were identified. The licensee was considered suitable for special measures; they accepted the failings, demonstrated immediate action to mitigate any potential risks and the key persons provided the Commission with a high level of confidence that improvements would be made.

As a result of engagement between the Commission and the licensee, the following safeguards were immediately implemented due to the specific circumstances of the failings:

  • operator must secure Know Your Customer (KYC) documentation and a source of wealth questionnaire at £250 in lifetime deposits and cannot accept deposits further until this is completed
  • deposit flags lowered to £250 deposited in 24 hours

The licensee provided weekly updates to show progress against their action plan and a follow up compliance assessment was completed three months later to satisfy the Commission the licensee was now suitably compliant, and the following further safeguards had been effectively implemented:

  • the maximum deposit that can be accepted in one transaction is £100
  • deposits are disabled when a customer hits £250 in deposits and they must provide their salary and occupation before being allowed to gamble further
  • a net loss limit is calculated based on salary information provided by the customer and this limit cannot exceed £400 a month
  • once satisfactory source of funds information is provided, a monthly net loss limit at a maximum of 15% of the customer’s net salary is set
  • safer gambling interactions are automatically triggered by several factors which are identified through algorithmic software
  • where a safer gambling interaction is triggered, deposits are disabled until this is completed.

The licensee worked at pace to resolve significant failings to ensure adequate safer gambling controls and AML procedures were implemented, positioning customer wellbeing at the heart of the business, rather than a sole focus on commercial gain. The safeguards implemented reflected the customer and business risk the licensee had identified and felt appropriate for its specific customer base. The licensee engaged positively with the Commission to raise its standards and demonstrated meaningful co-operation to protect the Licensing Objectives based on the specific risk profile of its customer base.

In a further example of special measures success another operator:

  • introduced a three-stage process to identify the risk of unaffordable gambling, commencing from point of registration
  • implemented deposit blocks based on customer risk and loss levels (both time based and lifetime)
  • added additional Know Your Customer (KYC) checks throughout the customer journey
  • reviewed its customer risk markers for both AML and safer gambling indicators
  • improved the quality of customer review through consideration of transactional history and risk indicators
  • introduced live customer monitoring and expanded staff resource in this area
  • implemented hard stops for highest risk accounts
  • invested in additional specialist staff training
  • improved record keeping relating to customer and business decisions.
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