Greentube to Pay £1 Million for Repeat Failings

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The UK Gambling Commission (UKGC) has ordered Greentube Alderney Limited to pay a £1 million regulatory settlement following an investigation that uncovered significant and repeated failures in its anti-money laundering (AML) and social responsibility (SR) procedures.

The enforcement action, announced on 9 January 2025, marks the second time the operator has faced regulatory action for similar failings, following a settlement in 2021. The investigation found breaches occurred between September 2022 and June 2023.

Anti-Money Laundering Failures

A UKGC compliance assessment found that Greentube failed to effectively implement its own AML policies. The regulator highlighted several specific examples where the operator did not act on clear risk indicators in a timely manner:

• Delayed Scrutiny: A customer provided a bank statement showing over £100,000 in complex transactions and a negative balance. The operator failed to scrutinise this information for four months until the customer hit a spending threshold.
• Linked Accounts: The operator was slow to investigate and mitigate risks associated with accounts that appeared to be linked. In one case, a potential link to an individual with a previous conviction for supplying class A drugs was not escalated promptly.
• Recycled Winnings: Greentube did not follow its own policy on 'recycled winnings'. One customer who had a large win was allowed to deposit over £70,000 from different payment methods long after the specified time period for such activity, without any source of funds checks being conducted.
• Risky Occupations: The company failed to properly assess the increased risk posed by a customer employed as a 'finance manager', who had potential access to third-party funds.

The Commission's review noted that for the specific customers examined, it found no evidence of actual money laundering or criminal spend with the operator.

Social Responsibility Breaches

The investigation also revealed serious shortcomings in Greentube's commitment to player protection and customer interaction.

The operator failed to effectively implement its systems to identify and act on signs of gambling-related harm. Key failings included:

• Ignoring Vulnerability: Customer documents showing clear signs of financial vulnerability—such as negative bank balances, overdrafts, and payments to multiple other gambling operators—were not reviewed or acted upon until a financial trigger was hit. In one instance, a customer deposited over £4,000 over four months while the operator possessed a bank statement indicating financial distress.
• Delayed Action: When staff identified markers of harm that warranted a phone call, these interactions were often postponed while further monitoring took place, allowing customers to continue gambling and potentially incur further harm.
• Policy Failures: The operator did not adhere to its policy for managing high winners, permitting a customer to deposit significant sums after a large withdrawal without verifying the funds were from the original winnings.

Background and Implications

This is the second time Greentube Alderney Limited has been penalised by the UKGC for AML and SR failings, with a previous regulatory settlement accepted in 2021. The Commission listed this history as an aggravating factor in its decision, noting the breaches were serious and similar to previous cases where lessons should have been learned by the industry.

In mitigation, the UKGC acknowledged that Greentube cooperated fully with the investigation, accepted its failings at an early stage, and swiftly put an action plan in place to remedy the issues.

The £1 million payment is in lieu of a financial penalty and includes a divestment of £22,113. The funds will be directed towards socially responsible purposes. Greentube will also cover the Commission's investigation costs.

This case serves as a stark reminder to all licensed operators of their duty to effectively implement their own safety policies and to act swiftly on any information that indicates a customer may be at risk of harm or involved in illicit financial activity.