A gambling business must pay a £780,000 fine after a Commission investigation revealed social responsibility and money laundering failures.

Buzz Group Ltd – which operates buzzbingo.com – has also received a formal warning for the failures which occurred between October 2019 and December 2020.

Social responsibility failures included:

• financial triggers not sufficiently identifying at-risk players as they were set too high. One customer was able to deposit £22,400 in five days without the operator conducting a meaningful interaction within that period
• systems not sufficiently identifying at-risk players. Two customers won large amounts of money gambling, yet the operator failed to consider the increased risk of gambling harm to those customers despite the customers displaying high levels of spend
• not carrying out effective customer interactions with customers who gambled aggressively over short periods of time. One customer deposited and lost £12,400 during a six-day period but the operator’s only record of a customer interaction simply stated customer was ‘coping well in COVID-19’
• once a decision to interact with a customer had been made staff did not always sufficiently follow the requirement of the operator’s own customer interaction procedure to check the customer was comfortable with their gambling levels, if they felt in control, and then discuss responsible gambling tools and support resources.

Anti-money laundering failures included:

• triggers prompting source of funds (SOF) checks being over reliant on open source or anecdotal information such as staff relying heavily on assurances provided verbally by customers during interactions
• in one instance the operator placed reliance on a large customer win as the SOF for the customer’s future gambling spend without considering that it might not be recycled winnings and that it may be the proceeds of crime
• multiple alerts needed to be activated before a customer AML interaction took place. One customer was able to hit nine financial alerts before their account was suspended pending an AML interaction
• the operator keeping insufficient records of AML interactions with customers and it was often not clear what had been discussed during those interactions.

The case against Buzz Group Ltd, like other recent enforcement action, was the result of planned compliance activity.

Helen Venn, Commission Executive Director, said: “As a regulator we expect all operators to effectively implement policies and procedures which make gambling safe and crime-free. Every single gambling business should be aware that we do check that these are in place and are being adhered to. If they are not, we will take action.”

The Commission has published the conclusion of an investigation into gambling business International Multi-Media Entertainments Limited (IMME).

IMME had provided facilities for the betting on the outcome of international lotteries under a real event betting licence, obtaining custom by calling consumers and hosting its website lotteries.com.

IMME also currently run a lottery syndicate business which does not require a licence. This side to IMME’s business is reliant on staff calling consumers and using the thelotterycentre.com 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.

This revealed significant suitability, social responsibility and money laundering failures.

Suitability concerns included:

• customers complaining of being called repeatedly by IMME sales agents, including one customer in her 90s who was called several times a week. Another complainant stated that a Lotteries.com customer was called every 30-40 minutes, five or six times until the phone was answered
• 75% of its customers were over 60 years old and 20% were over 80 years old. This demographic seems 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 which raises the question as to why a staff member might be told to or choose to be dishonest about their real name.

Social Responsibility failings included:

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

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 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.

Helen Venn, Commission Executive Director, said:

“We will not tolerate gambling businesses behaving in the way IMME did.

An interesting read, assuming most will now use this incident as a platform to build off and create more safety tools for players