The Gambling Commission has completed its investigation into a gambling business called International Multi-Media Entertainments Limited (IMME).

IMME had provided facilities for people to bet on the outcome of international lotteries under a real event betting licence, obtaining custom by calling consumers and hosting its website.  It also currently runs a lottery syndicate business which does not require a licence. This side to IMME’s business relies on staff telephoning consumers and using the 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, which revealed significant suitability, social responsibility and money laundering failures.

The suitability concerns included:

  • customers complaining of being called repeatedly by IMME sales agents.
  • 75% of its customers were over 60 years old and 20% were over 80 years old. This demographic seemed 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 rather than their real names.

The social responsibility failings included:

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

The 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 (which the Gambling Commission apparently assumed had limited means) 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.

IMME surrendered its operating licence before a regulatory panel hearing took place.  In any event, the Commission said that it would have revoked its operating licence under sections 117(1)(f) and 119(1) of the Gambling Act 2005.

Gambling operators should consider the following questions as a result of this investigation:

  • Do you have formal processes in place to measure the effectiveness of your anti-money laundering and safer gambling policies and are findings adequately recorded?
  • Do you efficiently record all compliance-related decisions and are you able to demonstrate to the Commission, on request, evidence of ongoing assessment, evaluation and improvement?
  • Do lessons learned from investigations such as these flow into your policy and processes?
  • Are your customer risk profiles formed by or linked to your money laundering and terrorist financing risk assessment?
  • Do you have a formalised process for analysing the effectiveness of customer interactions to ensure that reviews were adequately documented and consistent in their approach?
  • Do you log the types of behaviour which have triggered a customer interaction and keep sufficient records of interactions, along with decisions not to interact especially in terms of the level of detail provided?
  • Do you have out of hours arrangements in place?
  • Have your staff received sufficient training?