The Gambling Commission in Great Britain has levied a settlement action against Greentube Alderney for money laundering-related violations and social responsibility shortcomings. The NOVOMATIC company holds five license types in the UK and operates Admiralcasino and Bell Fruit Casino there.

The Commission began a regulatory review of the operator in December 2020 and found that between December 2019 and November 2020 the company failed to perform in accord with its license requirements in four separate and distinct fashions.

A regulatory settlement of £685,000 was imposed for the following breaches of responsibility:

• Failure to conduct proper assessments of money laundering risks
• Failure to prevent money laundering
• Failure to report key events
• Failure to interact with customers in a way that minimizes the risk of customers experiencing harm

The Commission noted that Greentube had taken remedial action.

Greentube Answers to the Failures

However, While Greentube accepted the Risk Assessment provided by the UK Commission it did not explicitly acknowledge that it would keep written records of steps that it had already taken to “identify and assess the risks of money laundering to which its business is subject as required”. Greentube also neglected to state explicitly that appropriate measures would be taken to assess and mitigate new risks that may occur when new technologies, business practices, or new products are adopted, nor that, “consideration had been given to the low-risk factors outlined in the Commission’s guidance.”

Greentube did acknowledge that out-of-hours operations monitoring of money laundering risks had not been addressed with adequate policies. It also acknowledged that the company’s processes during the period unduly relied on an assessment that slot games were a lower risk product and that the internal processes allowed some players to deposit and lose “significant sums” prior to Source of Funds requests were triggered.

Record keeping during the review period was also found to be wanting by Greetube’s admission and it was not always able to clarify audit trails to back up decision making.

Further findings and admissions include the failure of employees to interrogate customers on their source of funds, that unacceptable delays in documenting ownership of payment methods occurred.

Reported Transactions to Police

In the matter of key event reporting, although Greentube submitted six suspicious activity reports to the National Crime Agency, they failed to also inform the Commission within five days of filing those reports.

Regarding social responsibility breaches, Greentube acknowledged that they sometimes depended on monthly loss limit triggers rather than customer interactions to determine if harmful gambling might be happening at its properties. Other indicators such as length, frequency, and time of day of gambling were not always used to inform its decision-making.

In addition to the payment in lieu of financial penalty, Greentube agreed to publish a statement of fact about the case, allow third-party audits to ensure compliance, reimburse the Commission £8,789.86 toward covering costs related to investigating the case.

Helen Vann, Executive Director stated: “Compliance with Commission rules aimed at keeping people safe and gambling crime-free is not optional.

“We will always take firm action against those operators who fail to meet the high standards we expect for consumers in Britain.”