Today, August 21st 2025, the Commission have released information on the regulatory settlement for ProgressPlay Limited.

This is the second regulatory settlement for ProgressPlay following a £175k settlement in 2022.

A Key takeaway from the settlement is;

‘Social responsibility failures included;

• Employing a customer interactions policy which failed to adequately address the elements of identify, act and evaluate set out in the Remote Customer Interaction section of the Licence Conditions and Codes of Practice.’

Our Consultancy team see many instances where although operators have layered safer gambling controls, regulatory penalties result from operators not perfectly aligning to the Commission guidance as opposed to any profit via non-compliance. Often seeing cases where non-compliance is potentially less profitable due to very low financial thresholds replacing adequate behavioural monitoring.

Other failings listed by the Commission included (as per GC release);

• the Licensee did not conduct an appropriate Money Laundering and Terrorist Financing (MLTF) risk assessment and did not implement appropriate controls to minimise the risk of MLTF
• not considering all risks associated with its business and therefore failed to take a sufficiently risk-based approach to AML
• failing to sufficiently scrutinise transactions carried out during the course of customer relationships—including, where necessary, verifying the Source of Funds (SoF)—to ensure those transactions were consistent with the casino’s understanding of the customer, their business activities, and their risk profile.
• not having in place adequate systems and processes to effectively monitor customer activity at the point of account opening – this meant that early identification of any potential gambling related harm or the implementation of appropriate interventions was put at risk
• failure to implement adequate processes to understand the impact of individual interactions and actions on a customer’s behaviour, the continued risk of potential harm and therefore whether and, if so, what further action was needed.

John Pierce, Commission Head of Enforcement, stated:

“Gambling businesses must have robust policies and procedures in place to protect consumers and ensure appropriate anti-money laundering controls are maintained. These measures must be actively implemented and regularly tested to confirm their effectiveness.

This case marks the second time ProgressPlay Limited has been subject to enforcement action by the Gambling Commission. Its failure to meet AML obligations, along with the gaps identified in its social responsibility processes, are unacceptable.

As part of the regulatory outcome, ProgressPlay is now required to undergo an independent third-party audit to assess the adequacy of its compliance arrangements across these areas.

Operators should be in no doubt: repeated regulatory breaches will result in increasingly severe enforcement action.

We urge all operators to examine the failings identified in this case and take proactive steps to strengthen their own systems and controls.”

The breaches noted in this case did not reflect any significant customer losses, highlighting the fact that failings are not as commonly associated with large customer losses as they were in previous years!

Luke ARC advice:

• The AML risk assessment must be strictly aligned to the UKGC guidance and take into account, not only the UKGC risks, but also adhere to their given descriptions.
• Make sure that safer gambling controls, including the alert types, actions and evaluation exactly as described in Commission guidance.
• Align all internal terminology to the UKGC regulations and guidance.

If you wish to discuss Gambling Commission Compliance and in particular white label related requirements, feel free to Contact Us for a free consultation.

All of these topics will be covered in the Luke ARC annual Compliance forum (see link) on October 8th 2025 in Central Birmingham. So email ClientCare@LukeARC.com to get your FREE space!