On the 21^st of October, the Gambling Commission released a new publication detailing a £900,000 fine issued to L&L Europe for failures including unnecessary delays in the processing of customer withdrawals.

The investigation was carried out by the commission following a compliance assessment and found that failures included:

• employing a term and condition which stated customers were only permitted to request one withdrawal at a time and could not request a further withdrawal until the original one l had been authorised – this is unfair within the meaning of the Consumer Rights Act 2015
• manually reviewing every fifth or tenth withdrawal for some customers led to customers being required to provide additional information prior to withdrawals being processed – Commission requirements state that a request by a customer to withdraw funds from their account must not result in a requirement for additional information to be supplied as a condition of withdrawal if the licensee could have reasonably requested that information earlier.

Further failings were revealed relating to the operator’s anti-money laundering and social responsibility processes, including:

• controls in place to identify risks associated with money laundering and terrorist financing were not appropriate as they were largely based on financial thresholds and sampling at set thresholds, rather than based on risk factors and customer risk profiles
• not following its own customer due diligence procedures including not considering the risks posed by newly-opened bank accounts or money in bank accounts not being evidenced as coming from employment, a business income or savings.
• safer gambling alerts flagging potential gambling harm such as time spent gambling or failed deposits were activated in respect of some websites but not across the Licensee’s entire suite of websites
• not having a process in place to evaluate the effectiveness of its overall approach to customer interaction.

The above failures show that the operator failed to comply with the following requirements of the Licence Conditions and Codes of Practice (LCCP) between October 2024 and October 2025:

• breach of Paragraph 1 of Licence Condition 7.1.1
• breach of Paragraph 2 of Licence Condition 17.1.1
• breach of Paragraphs 1, 2 and 3 of Licence Condition 12.1.1
• Paragraphs 5 (b, d & g), 11, 12 and 13 of Social Responsibility Code Provision (SRCP) 3.4.3
• breach of Licence Condition 2.3.1

As a result of these breaches L&L Europe are set to make a payment of £900,00 in lieu of a financial penalty

Aggravating factors

• the failings were serious and potentially impacted on the licensing objectives
• the breach arose in circumstances that were similar to previous cases the Commission has dealt with which resulted in the publication of lessons learned for the industry.

Mitigating factors

• the Licensee promptly put in place an action plan designed to remedy the failings and provided updates
• fully co-operated with the investigation and provided information by agreed deadlines
• accepted the failings at an appropriately early stage in the investigation.

On this case, Sue Young, Executive Director of Operations, said: “A basic expectation is that when you have winnings you can withdraw those swiftly without hinderance from unfair terms and conditions or the operator failing to carry out checks at an earlier stage”…“There may be occasions where a gambling business can ask consumers for information at withdrawal to fulfil legal obligations, but this was not the case here”.

OUR RECOMMENDATIONS

• Read and review the full statement released
• Ensure customer withdrawals are not delayed without reason
• Review policies and procedures to ensure checks on customers are carried out at an appropriate time

If you have any questions on these failings, please do not hesitate to Contact Us

LINKS TO FULL DETAILS
See the Commissions release HERE
View the Licensees public statement HERE