The Gambling Commission has recently found that two gambling businesses were guilty of social responsibility and anti-money laundering failures and is requiring them to pay nearly £700,000 between them.

The investigations involved Progress Play and Jumpman. Each operator failed to comply with:

  • rules on prevention of money laundering and terrorist financing; and
  • requirements for operators to minimise the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

The Commission acknowledged that Progress Play fully cooperated throughout the course of the investigation and had accepted that its policies and procedures regarding anti-money laundering and safer gambling were neither appropriate nor implemented effectively. It has also accepted that it failed to act in accordance with conditions of its operating licence. It also provided an action plan during the investigation and took action to expand and improve its compliance capacity.

Taking into account remedial action taken and in line with the Commission’s Statement of principles for licensing and regulation, Progress Play will make a payment in lieu of a financial penalty and divestment of £175,718.00. It will also pay the Commission’s costs of £12,466.35. Jumpman Gaming will pay a total of £500,000 in lieu of a financial penalty.

The Commission has warned about these issues before and reiterates that gambling operators should take account of the failings identified and consider the following:

  • 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 lessons learned from public statements flow into your policy and processes?
  • does your money laundering and terrorist financing risk assessment meet all the requirements?
  • 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 the types of interaction are effective?
  • 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 robust measures to identify separate accounts which are held by the same individual. and which enable you to relate each of a customer’s such accounts to each of the others?