Done Bros (Cash Betting) Ltd ordered to pay £3.5m fine for failures

Done Bros (Cash Betting) Limited, who operate over 1,700 betting shops in the UK under the trading name Betfred, will pay £3.25 million after a Gambling Commission investigation found failures in social responsibility and anti-money laundering.

Social responsibility failures included:

  • having insufficient controls in place to protect new customers, and to monitor high velocity spend and duration of play exposing the customer to the risk of substantial losses without safer gambling interaction
  • making assumptions that customers were not at risk of harm because they were winning customers – it failed to carry out any safer gambling interactions on one customer who staked £517,499 over a two-month period
  • a lack of evidence of evaluation of the effectiveness of individual customer interactions and a lack of record keeping which limited the effectiveness of future interactions.

Anti-money laundering failures included:

  • poor record keeping and its financial alerts (thresholds) were set too high
  • failing to consistently obtain appropriate ‘know your customer’ identification and Source of Funds (SoF) documentation from its customers when its thresholds were met
  • placing an undue reliance on open-source information and should have taken further steps to corroborate customers’ SoF information.

These failing occurred over a period between January 2021 and December 2022.

The public statement contains more information.

All of the £3.25m settlement will be paid to socially responsible causes.


Findings of the review

Findings of the review included:

  1. Failures in Anti-Money Laundering (AML) Measures: Done Bros did not adequately implement AML policies, procedures, and controls. They did not sufficiently assess the risks of their business being used for money laundering and terrorist financing. The risk assessment was not up to the Commission’s expectations, failed to consider all relevant risks, and did not detail countermeasures effectively.
  2. Weaknesses in Safer Gambling (SG) Measures: The company’s SG policies, procedures, controls, and practices were found to be deficient. There was insufficient protection for new customers and inadequate monitoring of high spending, exposing customers to the risk of substantial losses without SG interaction. The interactions with customers at risk were not timely or effective, and there was a lack of evidence regarding the evaluation of the effectiveness of these interactions.
  3. Compliance Breaches: Done Bros breached several license conditions and codes of practice related to AML and SG. They failed to conduct proper risk assessments, implement appropriate policies, and maintain effective controls. They also did not consistently conduct Know Your Customer (KYC) checks and relied on open-source information inadequately.

As a result of these findings, Done Bros agreed to a regulatory settlement, which includes:

  • A payment of £3,250,000 in lieu of a financial penalty, directed towards socially responsible purposes.
  • Divestment of £1,052,717.
  • Publication of a statement of facts related to the case.
  • Payment of the Commission’s costs for conducting the review.

The UK Gambling Commission considered the seriousness of the breaches and their impact on licensing objectives. They also noted mitigating factors, such as the steps taken by Done Bros to address the issues and their early acceptance of the Commission’s findings.

The regulatory settlement serves as a reminder for gambling operators to:

  • Review their ML/TF risk assessment at least annually.
  • Measure the effectiveness of their AML and SG policies and procedures and keep records.
  • Incorporate lessons learned from public statements and regulatory decisions.
  • Review customer risk profiles in light of new information.
  • Ensure formalized processes for analyzing the effectiveness of customer interactions.
  • Maintain comprehensive records of interactions and decisions not to interact.
  • Provide sufficient AML and social responsibility training to staff.