Football Pools Pays £375k for AML & SR Breaches

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The UK Gambling Commission (UKGC) has announced that Football Pools Limited will pay a £375,000 regulatory settlement following an investigation that uncovered significant failings in its anti-money laundering (AML) and social responsibility controls.

The public statement, published on 27 March 2025, details breaches that occurred between September 2022 and August 2023. The investigation focused on the operator's online betting services, not its traditional non-remote pool betting products.

Anti-Money Laundering Failures

The Commission found that Football Pools Limited breached Licence Condition 12.1.1, which requires operators to have appropriate policies and controls to prevent money laundering and terrorist financing.

Key failings identified by the regulator include:

• Over-reliance on financial triggers: The operator's AML policies were too dependent on specific financial thresholds to identify high-risk customers, rather than considering a broader range of risk factors.
• Lack of automatic blocks: The systems in place did not automatically apply hard stops on accounts when AML thresholds were met. Instead, they relied on manual reviews, which were often delayed.
• Delayed risk assessments: The investigation found significant delays in creating customer risk profiles, with an average delay of 25 days after a financial trigger was hit. In some cases, profiles were not created at all, preventing timely risk mitigation.

Social Responsibility Breaches

The operator also failed to comply with multiple paragraphs of Social Responsibility Code Provision (SRCP) 3.4.3, which governs customer interaction.

The UKGC highlighted several areas where protections for vulnerable customers were inadequate:

• Ineffective monitoring: The systems for identifying customers at risk of gambling harm were found to be ineffective. They overly focused on financial triggers, which were set too high, and failed to identify non-financial markers of harm such as long gambling sessions or high-velocity betting.
• Delayed interactions: Due to low staffing levels and system flaws, there was a large backlog of safer gambling risk profiles. This meant customers exhibiting signs of harm were not interacted with in a timely manner. In one example cited, a customer deposited approximately £4,100 within two weeks of opening an account but did not receive a safer gambling interaction.
• Communication gaps: The operator's systems were unable to deliver safer gambling messages to customers who had opted out of marketing communications, creating a significant gap in its ability to protect potentially vulnerable players.

Regulatory Settlement and Implications

In lieu of a formal financial penalty, Football Pools Limited will make a payment of £375,000, which will be directed to socially responsible causes. The operator will also cover the Commission's costs for the investigation.

The UKGC noted that while the failings were serious, Football Pools Limited cooperated fully with the investigation and swiftly implemented an action plan to remedy the issues.

This case serves as a reminder to all licensed operators of the importance of having robust, proactive, and effective systems for both anti-money laundering and social responsibility. The Commission expects operators to use a range of indicators to identify risk, act swiftly when harm is identified, and continuously evaluate the effectiveness of their policies and procedures.