QuinnBet Limited are set to pay a £609,104 fine following an investigation carried out by the Gambling Commission which revealed AML and Safer Gambling failures.
AML Failures noted by the Commission include:
• employing insufficient controls to act in a timely manner to identify and mitigate the risk posed by customers who were displaying disproportionate spend – in one example a customer provided payslips that showed monthly earnings of circa £2,000 yet was able to deposit and lose £9,000 in four days
• allowing some customers to deposit significant funds without Source of Funds (SoF) being established to evidence that the monies were from a legitimate source. One customer was seen depositing £120,000 and withdrawing £111,000. Despite SoF documents being obtained, the operator assumed the customer was recycling funds without any further evidence being sought.
• having insufficient controls to ensure that Suspicious Activity Reports were submitted as soon as practicable after the threshold for suspicion had been met.
Safer Gambling Failures include:
• deploying a manual process which allowed those aged between 18 to 24 to spend over deposit limits the operator had set for this potentially vulnerable group
• ineffective controls meant signs of potential gambling harm such as high deposits, short high velocity sessions, increasing stakes, number of bets and high turnover were not captured and flagged for manual review – in one example one customer was able to place approximately 4,800 bets in one day, and 7,000 the following day without this being identified and flagged
• ineffective controls did not always flag indicators of risk of harm in a timely manner for manual intervention or automated processes – following a large win, one customer’s stakes escalated to the point where over £215,000 was staked in a day with multiple wagers over £5,000 but this was not identified until a report was produced the following day
• not effectively ensuring all customers who met the relevant threshold underwent a light touch financial vulnerability check.
The commission also expressed that while account reviews were taking place, they were “not always sufficiently detailed and did not consider all of the information available” and reviewing agents appeared to not take previous reviews conducted into consideration or assess whether previous interactions had been impactful.
As such, Quinnbet are set to make a payment in lieu of a financial penalty of £609,104 (including a disgorgement of £193,118).
Aggravating factors include:
• the Commission previously issued public statements regarding similar issues which it has observed in relation to other operators.
Mitigating factors include:
• QuinnBet has not previously been subject to regulatory enforcement action
• swiftly devised and put in place an appropriate action plan designed to remedy the failings, provided frequent updates
• fully co-operated with the investigation and provided information by agreed deadlines
• made early and voluntary reports of some of the failings to the Commission
• voluntarily and proactively divested itself of funds had been accrued as a result of some of the failings
• accepted the failings at an appropriately early stage in the investigation.
On this the commissions director of enforcement, John Pierce said: “This case highlights the serious consequences of relying on systems and controls that are unable to identify and respond to indicators of harm and financial crime quickly enough. We expect operators to ensure their safeguards are effective in practice to protect consumers and keep crime out of gambling”
OUR RECOMMENDATIONS
Review failings listed against your own internal processes
Ensure financial AML triggers include proportionate, deposit based triggers.
Have automated controls in place to control disproportionate and high spending Customers.
If you have any questions regarding any of the issues identified, please do not hesitate to Contact Us
LINKS TO FULL DETAILS
See the commissions release HERE
View the full public statement HERE
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