Announcing the ruling today (9 January), the Commission said the payment will be made in lieu of a financial penalty in a settlement agreement it made with the operator. Greentube accepted the failings at an early stage and complied with the investigation throughout. All issues flagged related to activity on Greentube-operated gaming site AdmiralCasino.co.uk.

The regulator said Greentube breached two Licence Conditions and Codes of Practice (LCCP) between September 2022 and June 2023. These include Paragraph 3 of Licence Condition (LC) 12.1.1, which covers AML controls, and paragraphs 1 and 8 of Social Responsibility Code Provision (SRCP) 3.4.3, which refers to remote customer interaction.

AML failures placed Greentube customers at risk

Detailing the AML failures, the Commission said Greentube did not always scrutinise information to identify possible money laundering or terrorist financing risks.

In one case, a player provided a bank statement as proof of address. This showed several unusual transactions, including over £100,000 being transferred in and out. However, the statement was only scrutinised when the player’s spend reached a designated threshold four months later.

Meanwhile, the Commission said Greentube did not adhere to its ‘recycled winnings’ policy, which monitors winnings that are withdrawn and redeposited to ensure players are not spending beyond their means.

After a large win and withdrawal, one user was allowed to continue depositing funds via different payment methods after a specified recycled winnings period without Greentube requesting source of funds information. In total, over £70,000 was deposited.

Greentube was also reprimanded for not following its policy on ‘risky occupations’, where a player’s job may mean increased risk. One player worked as a finance manager but this was not recognised and no steps were taken to mitigate possible increased risks.

Also in relation to AML, Greentube was ruled to not always investigate users linked to other accounts. In one example, a player who had the same address and surname as another user was not flagged. The other account was held by a blocked customer with police convictions for the supply of class A drugs.

Greentube failed to follow social responsibility policies

The Commission also said Greentube did not implement its social responsibility policies. As such, this left players at increased risk of harm when gambling on AdmiralCasino.co.uk.

According to the regulator, Greentube did not follow a policy aimed at ensuring user limits are based on regular, sustainable income. This led to one user, after a large win, depositing significant sums greatly in excess of Greentube policy.

Greentube also failed to fully implement processes for ensuring KYC documents were genuine. Despite agents receiving training, the Commission found staff did not always apply this training.

On top of this, the Commission said Greentube did not properly use its controls to identify indicators of vulnerability among some players. Here, for proof address, one player had supplied a bank statement that showed negative funds in their account and included transactions to another operator. This was not reviewed or escalated until the customer deposited £4,000 over four months.

Repeat offence after 2021 ruling

The Commission ordered the payment in lieu of a financial penalty, which will be used to fund socially responsible causes. Greentube will also cover the costs of the case.

In its evaluation, the regulator said the failings were “serious”. It noted this is not the first time Greentube has fallen foul of licence requirements, with the operator paying out £685,000 for similar breaches in 2021.

However, the Commission also acknowledged the steps taken by Greentube in response to the latest case. In addition to accepting the failings, the operator put in place an action plan designed to remedy the failings.

Commission director of enforcement John Pierce said the regulator will continue to monitor Greentube to ensure it upholds standards going forward.

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

“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 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 AML standards is unacceptable, and today’s action reflects the gravity of the breaches identified.”