On May 15^th 2025 the Gambling Commission published their latest regulatory action taken against Spreadex Limited (Spreadex.com) due to Anti-Money Laundering and Social Responsibility failings. For this the business will pay a £2,022,000 penalty.

This is the second occasion Spreadex has faced enforcement action – in 2022 the operator paid a £1.36 million regulatory settlement for social responsibility and anti-money laundering failures.

Following a compliance assessment conducted in July 2023 the Commission revealed failures in the following areas:

Anti-Money Laundering

• the Licensee’s Money Laundering and Terrorist Financing (ML/TF) risk assessment failed to consider key customer, product, geographic and payment risks as detailed in the Commission’s guidance and therefore failed to take a sufficiently risk-based approach to Anti-Money Laundering (AML).
• the AML policies, procedures and controls were not appropriate to prevent ML/TF. The Licensee was overly reliant on customers’ self-reported financial position and customers were able to continue depositing substantial amounts of money without providing Source Of Funds (SOF) information in line with the risks present. For example, a customer opened an account and deposited circa £64,000 into the business within a short period of time but the Licensee did not request SOF information in line with the risks present and the customer went on to lose £50,000 within one month.
• the Licensee repeated the same checks on customers without increasing the levels of scrutiny when a customer’s risk increased due to significantly larger deposits or gambling activity.

These failings show breaches of “paragraphs 1, 2 and 3 of Licence condition 12.1.1: Anti-money laundering – Prevention of money laundering and terrorist financing”.

Social Responsibility

• not conducting a stronger form of customer interaction to ensure that a customer who hit a daily deposit limit of £3,340 12 times in 14 days was not potentially suffering gambling related harm. Despite the high spend in a short period, the operator restricted its social responsibility interactions to four pop-up messages and did not carry out human interactions.

These failings show failure to “comply with paragraph 9c of Social Responsibility Code Provision (“SRCP”) 3.4.3: Customer Interaction”.

Key takeaways from this regulatory action:

• Relying solely on self-reported income is not sufficient, Source of Funds (SOF) should always be verified when deposits or losses are substantial.
• Ongoing monitoring should include increased scrutiny where activity has increased.
• Automated pop-ups are not a replacement of meaningful customer interactions, especially where signs of harm are present.

On this case Commission Head of Enforcement, John Pierce said: “The conclusion of this case marks the second time Spreadex Limited has been subject to enforcement action. Its failure to uphold anti-money laundering standards, delays in necessary interventions, and weaknesses in social responsibility measures were unacceptable”.

Don’t forget that Luke – Audit, Risk and Compliance are the leading experts in remote gambling compliance, enforcement action and conducting independent audits which give an up to date reflection of the Commissions compliance assessments!

If you wish to discuss Gambling Commission Compliance assessments and the related requirements, feel free to Contact Us for a free consultation.