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Triplebet's licence and the Money Laundering Regulations require operators to establish and maintain policies to manage effectively the risks of money laundering and terrorist financing. Other matters The Panel rejected a number of general arguments advanced by Triplebet, including the following: Triplebet argued that as the review had uncovered no evidence of money laundering, the Panel should conclude that its business model presented no substantial risk of money laundering. Monitoring of business relationships Triplebet's licence and the Money Laundering Regulations required ongoing monitoring of business relationships, including, where necessary, the customer's source of funds. The Panel found that in June Triplebet had adopted an effective responsible gambling policy. Share Tweet Browser does not support script. In any event, the Panel rejected the submission that professional gamblers are a known low risk category for money laundering, since money laundering includes the simple use of criminal funds to fund gambling as a leisure activity, and criminals may also be habitual gamblers. Although it claimed that it had relied on staff to ensure that its policies and procedures were being implemented effectively, it had failed to give its staff sufficient guidance on implementation or to monitor or manage them sufficiently. The Panel also rejected Triplebet's case that its general knowledge of its VIP customers sufficed, given Triplebet's failure in breach of the Money Laundering Regulations and licence conditions to maintain appropriate records of its alleged monitoring. Triplebet failed to update its anti-money laundering policy between November and October It also failed to ensure that its policies, procedures and controls were being implemented effectively. By the date of the hearing, Triplebet had suspended activity for all syndicates pending the carrying out of due diligence on their contributors in line with a policy which remained to be developed. Suspension The Panel decided to suspend Triplebet's licence with immediate effect. Following the intervention of the Gambling Commission, Triplebet ceased to permit account to account transactions for its UK customers in May It did not finally ban such transactions for non-UK customers until January One of Triplebet's main customers was a syndicate, whose lead contributor was a professional gambler, who also held a beneficial interest in Triplebet itself. In another, a customer deposited and shortly afterwards withdrew a large sum of money without any gambling activity, a risk factor for money laundering, yet Triplebet had carried out no checks on the customer other than to verify his identity and address one year earlier. AML Policies Triplebet's licence and the Money Laundering Regulations require operators to establish and maintain policies to manage effectively the risks of money laundering and terrorist financing. Triplebet's licence and the Money Laundering Regulations required ongoing monitoring of business relationships, including, where necessary, the customer's source of funds. Triplebet operated a betting exchange and a remote casino trading as Matchbook under an operating licence granted by the Gambling Commission. The Panel found that the consequence was that gamblers had been permitted to gamble very large sums without due diligence. The reasons for the Panel's decision were that Triplebet had: breached conditions of its licence relating to anti-money laundering measures; failed to comply with the Commission's social responsibility codes of practice, and operated in a manner inconsistent with the statutory licensing objectives to keep crime out of gambling and to protect children and other vulnerable people from harm. Posted on 08 April Show all parts of this guide Other news Latest gambling industry statistics published Gambling Commission investigation into failures in player protection at PT Entertainment Services PTES leads to company closure New data shows no uplift in complaints about illegal gambling. Read decision notice below. The Panel met on 17 February and decided to:. All operators need to learn the lessons from this case and our other enforcement cases. In March , Triplebet provided what purported to be its social responsibility policy effective from November However, this was a customer-facing document which did not comply with the Code. The Panel held that the requirements of the Money Laundering Regulations and licence conditions were focussed on taking steps properly to identify risks and then mitigate them. The Panel did not identify any mitigating factors. If you have a question about your gambling, or the gambling of someone close to you, our FAQs from gambling consumers during lockdown may provide valuable information. The financial penalty included a deterrence uplift, which the Panel considered to be justified on account of the following aggravating factors: the breaches spanned a period of three years they arose in circumstances similar to previous cases resulting in publication of lessons to be learned the breaches continued even during the review proceedings until Triplebet suspended syndicate betting on 9th August Triplebet's responsible gambling policy did not cover what is required by Social Responsibility Code 3. Due to the impact Covid is having on operations across the UK we have had to reduce our phoneline opening hours. New data shows no uplift in complaints about illegal gambling New data released today shows that there has been ….{/INSERTKEYS}{/PARAGRAPH} The Panel found that, prior to June , Triplebet's social responsibility policies generally failed to comply with this Code provision. Accordingly, the Panel directed that the suspension should not be lifted until the Commission confirmed to Triplebet that it had received a report from independent auditors, supported by a letter of assurance from Triplebet's directors and personal management holders, confirming that Triplebet had implemented the outstanding recommendations of the consultants. The Panel found that Triplebet's anti-money laundering policies were deficient as they failed:. The investigation found serious failings in Triplebet's approach to anti-money laundering, the monitoring of business relationships and due diligence checks into members of gambling syndicates. The Gambling Commission's Social Responsibility Code requires licensees to interact with customers in a way which minimises the risk of gambling-related harm. Latest gambling industry statistics published Gambling industry statistics are published twice a…. Triplebet could produce no record of requests to make account to account transfers being refused. Commission publishes the reasons for suspending Triplebet's licence. Triplebet stated that a further social responsibility policy did exist but was unable to locate it. These included:. {PARAGRAPH}{INSERTKEYS}The Commission has, today, published the reasons for suspending the licence of online gambling business Triplebet. The Panel found that Triplebet did not conduct appropriate ongoing monitoring of business relationships in several respects, including the following:. However, it was unable to adduce detailed documentary evidence to support its understanding of the customers in question as professional gamblers. You can call them free on , or visit gamcare. Further, Triplebet accepted that, whatever its policy said, both it and its predecessor policy failed to comply with the Social Responsibility Code provision then in force, by failing to refer to indicators such as time or money spent, and also by failing to contain specific provision in relation to "high value" or "VIP" customers. As stated above, the Panel rejected Triplebet's case that professional gamblers can always be regarded as low risk for money laundering. We will not hesitate to use our regulatory powers, including the suspension and revocation of licences, if we need to do that to protect consumers and the public from gambling related harm. The Panel determined that, in breach of the Code, Triplebet had failed to put into effect its policies and procedures for customer interaction in a number of cases. Triplebet had not always applied its own rule that those receiving transfers must roll them over in the Exchange before withdrawing them;. Triplebet also accepted that the structure of syndicates resulted in customers not being appropriately assessed from a social responsibility perspective and therefore did not facilitate compliance with licence requirements. Its operating licence was suspended, with immediate effect, on February 17 as part of a package of sanctions for social responsibility and money laundering failings. The Panel also rejected Triplebet's argument that the Commission ought to have provided a greater level of guidance as to the standards it required, including relating to syndicates, since the requirements of the Money Laundering Regulations are clear and in any event Triplebet had failed to seek appropriate professional advice as to its obligations prior to June Social responsibility failings The Gambling Commission's Social Responsibility Code requires licensees to interact with customers in a way which minimises the risk of gambling-related harm. These were required by the Commission's Licence Conditions and Codes of Practice from May but were not actually contained in Triplebet's responsible gambling policy until 1st June , three years later. Our what we do page also provides an overview of the types of queries we are able to help consumers with in the first instance. It is there to support those suffering from gambling problems or those concerned about the affect gambling is having on people close to them. Triplebet had provided a report from compliance consultants as to the steps which should be taken to bring Triplebet into compliance with the Commission's requirements, but had not implemented all of the steps. Triplebet submitted that some or all of the players were professional gamblers who are a known low risk category for money laundering. The reports must each be supported by an appropriate letter of representation or assurance from Triplebet's directors and personal management licence holders refrain from permitting or facilitating account to account transfers. Triplebet submitted that its actual customer was the lead contributor of the syndicate and that therefore there was no obligation upon it to ascertain the identities of the other contributors or consider their source of funds or source of wealth. The financial penalty included a deterrence uplift, which the Panel considered to be justified on account of the following aggravating factors:. Triplebet was unable to produce documentation demonstrating ongoing monitoring in a number of cases in which players were gambling large sums of money. Gambling Commission chief executive Neil McArthur said: "We have repeatedly made it clear that operators must put player protection at the forefront of their activities and ensure that they have effective anti-money laundering processes in place. The Panel found that Triplebet did not conduct appropriate ongoing monitoring of business relationships in several respects, including the following: monitoring did not place sufficient emphasis on addressing anti-money laundering risks there was insufficient recording of outcomes of monitoring monitoring did not always result in appropriate steps being taken in accordance with Triplebet's procedures, which resulted in too little emphasis on obtaining documentary evidence, including evidence relating to source of funds. The Panel found that such transactions are an obvious risk for money laundering. In the case of its top ten customers gambling on the betting exchange: checks were confined to basic checks of identity and address checks no risk profiles had been prepared the customers' source of funds had not been checked there was a general failure to record monitoring there was no record of meetings or interactions there were no records of conference minutes or records of any assessments as a result of meeting those customers. Syndicate One of Triplebet's main customers was a syndicate, whose lead contributor was a professional gambler, who also held a beneficial interest in Triplebet itself. In one case a player was able to gamble a large sum of money over the course of two days without any interaction whatsoever. It considered that before then, given the nature of the failings identified in relation to specific customers, that such failings were representative of Triplebet's approach across its customer base. In several cases, customers had been permitted to gamble very large sums without any checks of their source of funds or source of wealth. He then played for 10 hours a day on consecutive days and lost a large sum before self-excluding again, without any monitoring or interaction taking place. If you are a gambling operator please read our Frequently Asked Questions for gambling businesses. The contact us service is also available for answers to common questions and we will aim to respond to these enquiries as quickly as possible. This failure was a cause of Triplebet's failure to identify and sufficiently interact with a number of at-risk players and also syndicates. Additional licence conditions The Panel decided to impose additional conditions on Triplebet, requiring Triplebet to: implement the consultants' recommendations in full thereafter, continue to operate in accordance with the changes implemented to meet those recommendations instruct a firm of auditors to report to the Commission once those recommendations have been implemented in full, with the scope of the auditors' instructions to be approved in advance by the Commission provide auditors' reports every six months on the Licensee's provision of gambling facilities in reliance on the licence setting out whether and to what extent such provision has been undertaken in compliance with the consultants' recommendations and the conditions of the licence. Our phonelines are open on Monday, Wednesday and Friday between 10 am and 4 pm. Another player who registered, played and then self-excluded on the same day was subsequently able to reopen his account six months later.