Greentube Alderney Limited fined £1m for regulatory failures

On January 9th 2025 the Commission released a statement regarding the regulatory action on Greentube Alderney.

A few things highlighted within the Commissions public statement regarding the 1 million fine for Greentube Alderney Limited which Operators should be aware of.

One overarching point is that Operators must follow their own policies and procedures stringently. Another point which catches many Operators unaware is that where bank statements have been obtained, even when it was sent for the purpose of identity or address verification, the statement must be fully reviewed for risks and indicators of harm! The Customer Interaction Guidance clearly states that Operators should draw on all available sources of data!

This is not new and B2C gambling operators should ensure that staff in receipt of verification documents are trained on what to look out for to avoid failures.

John Pierce, Commission Director of Enforcement, stated:

“This case arose from a follow-up compliance assessment designed to ensure the operator had continued to apply lessons learned from previous regulatory action.

While we noted that the business had made significant general improvements, further regulatory breaches were still identified. The operator was subsequently required to swiftly put in place an effective action plan designed to remedy all of the identified failings.

We want to remind all operators that any business found to breach rules designed to keep gambling safe and free from crime for a second time should expect increasingly stringent enforcement action. Any failure to uphold anti-money laundering standards is unacceptable, and today’s action reflects the gravity of the breaches identified.”

Gambling operators should take account of the failings identified to ensure industry learning. Operators should consider the following questions and take remedial action where required:

do you have effective processes in place to test and assess whether your policies, procedures and controls are being effectively implemented by staff? Is this recorded and demonstrable?
do you have set turnaround times for manual reviews, actions, processes, etc? Are these routinely met?
have staff received adequate initial and refresher training? Is this recorded and demonstrable?
do you have an effective method to disseminate feedback, good practice and lessons learned to your staff?
do you fully consider the risks associated with customers who may have access to third-party funds which could be misappropriated?
do you fully investigate accounts and mitigate risks when links are identified?
are you fully scrutinising all customer information available to you in a timely manner, properly assessing and taking steps to mitigating potential ML/TF and SR risks?
do you have a good system for cross-departmental sharing of information and concerns? For example, would your Fraud/AML agents alert your social responsibility agents if a bank statement showing financial vulnerability was received?
do you act quickly enough when customers display potential markers of harm? Do your procedures specify appropriate timescales for actions and interactions?
if you deviate from your policies and procedures, are you able to justify this and do you fully document those decisions and the rationale?

This is the second time Greentube has faced regulatory action. In 2021 the operator paid out £685,000 after a Commission investigation revealed social responsibility and money laundering failures.