GC reveals Matchbook's AML, social responsibility failings

8 April 2020

The British Gambling Commission has revealed the details of Matchbook operator Triplebet’s licence suspension, in which it reports serious failings in the areas of anti-money laundering (AML), social responsibility and due diligence checks into syndicates.

The Commission suspended Triplebet's licence on 18 February following a two-year review of the business.

The regulator highlighted examples of players who did not receive sufficient anti-money laundering interaction from the operator. In one case, a player staked over £2m in a single day without facing any source of funds or source of wealth checks. Another player deposited and withdrew a large sum of money on the same day without gambling, with no AML checks carried out.

Matchbook did not monitor or interact with this player.

A different player lost $714,000 in a year before the Gambling Commission raised concerns that the funds may be linked to a family member who had been convicted of gambling-related offences.

Triplebet said many of these players were professional gamblers and therefore at low risk of money laundering, but could not produce evidence to back this up.

For the ten players who gambled the most on Matchbook’s sports betting exchange, the Commission said only basic identity and address checks were carried out, with risk profiles and source of funds checks not undertaken. There was no record of interactions with these players.

The regulator added that Triplebet failed to set out objective criteria for reclassifying a player’s money-laundering risk level or to specific enhanced due diligence AML measures for high-risk customers.

In addition, the Commission said the operator did not provide guidelines for when source of funds investigations should be undertaken and said its recording process was not adequate.

Triplebet also allowed account-to-account money transfers, which the regulator said was “ an obvious risk for money laundering". Between November 2014 and May 2018, approximately £3.2 million and $2.4 million was transferred from British customers to customers elsewhere, with £1.1 million and $1.8 million moving the other way.

Triplebet could not produce any record of an account-to-account transfer being refused.

While Triplebet pointed out that no evidence of actual money-laundering was found, the Commission said this does not mean it did not violate the Licence Conditions and Codes of Practice (LCCP) in this area.

In terms of social responsibility, the Commission highlighted the example of a player who gambled a “large sum” for several hours a day and late at night on consecutive days and faced no interaction.

A further example was of a player who self-excluded and was then able to reopen his account six months later, after which he played for 10 hours a day on consecutive days and lost significant amounts before self-excluding again.

The Commission also pointed out that one of Triplebet’s largest customers was a syndicate, whose main contributor held a “beneficial interest” in the business. This syndicate staked more than $55 million on Matchbook’s exchange without any documented risk assessment.

Another player lost $714,000 in a year, without any evidence of due diligence being carried out by Triplebet.

When asked to produce its social responsibility policy, Triplebet could only produce a customer-facing document, as opposed to the internal document required in the LCCP.

These failings prompted the Commission's regulatory panel to commence a review of its practices. iGB understands that, after the Gambling Commission began its review of its practices, Triplebet engaged the services of performance improvement consultancy Alvarez and Marsal.

The Commission did acknowledge that by June 2018, Triplebet had adopted an “effective” responsible gambling policy. However, Triplebet had not adopted all recommendations by the time of the licence hearing in late January, after deciding to implement them in phases. As a result, the licence was suspended.

"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,” Gambling Commission chief executive Neil McArthur (pictured) said.

“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.

“Any operator that doubted that we were ready and willing to use the full range of our regulatory powers should think again. All operators need to learn the lessons from this case and our other enforcement cases.’’

Triplebet did not disclose which recommendations put forward by the consultancy that were yet to be adopted, however.

The Commission also issued a £739,099 fine to Triplebet.

In addition, the Commission imposed further conditions on Triplebet’s licence, requiring it to implement the consultants' recommendations in full, provide auditors' reports every six months and ban account-to-account transfers. 

The recommendations that Alavarez and Marsal offered included new policies for the fair treatment of customers, the establishment of a compliance committee, the establishment of a new responsible gambling algorithm and progress towards Gamcare’s Safer Gambling Standard certification.

Also included in the recommendations were anti-money-laundering and problem gambling training by GamCare for 30 key members of staff and for daily screening to recognise players that may be those subject to international sanctions and politically exposed people (PEPs). 

A Triplebet spokesperson said the operator has now implmented all of Alavarez and Marsal's recommendations.

“Triplebet welcomes the conclusion of the UKGC’s two-year review," the spokesperson said. "Through working with the experienced compliance consultants we appointed in the middle of last year, and in spite of the impact of Covid-19 on our industry, we have already implemented all of their recommendations.

"We are committed to upholding every aspect of the UKGC regulations, and we are proud of all the hard work our teams have put in to get us to these final stages. We are excited about relaunching for our UK customers, who tell us they are looking forward to our return.”