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UK: Gambling Commission fines ProgressPlay £175,718 for social responsibility and anti-money laundering failures

The Gambling Commission ('the Commission') published, on 17 May 2022, its decision, as issued on the same date, in which it imposed a fine of £175,718 on ProgressPlay Limited, for violations of Paragraphs 2 and 3 of Licence Condition ('LC') 12.1.1, Paragraph 1 of LC 12.1.2, and Paragraphs 1 and 2 of the Social Responsibility Code Provision ('SRCP') 3.4.1, following an investigation.

Background to the decision

In particular, highlighting that licensed gambling operators have a legal duty to ensure their gambling facilities are provided in compliance with the Gambling Act 2005 ('the Act'), the conditions of their licence, and in accordance with the licensing objectives, the Commission noted that its investigation resulted in the commencement of a regulatory review under Section 116 of the Act on 14 August 2020.

Findings of the Commission

In this regard, the Commission found that ProgressPlay failed to comply with the following:

  • Paragraphs 2 and 3 of LC 12.1.1, requiring compliance with the prevention of money laundering and terrorist financing;
  • LC 12.1.2, requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017; and
  • Paragraphs 1(a), (b), and (c) and 2 of SRCP 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission's guidance on customer interaction.

Additionally, the Commission found that ProgressPlay failed to consider Ordinary Code Provision 3.4.2 which sets out good practices and which states, among other things, that operators should keep a record of customer interactions and, where an interaction has been ruled out, the reasons for this.

In reaching this decision, the Commission considered aggravating factors, including the fact that there were repeated breaches of licence conditions as a result of the absence of internal controls and procedures, as well as mitigating factors, including ProgressPlay's open cooperation with the investigation undertaken by the Commission and no attempt to conceal the extent of the breaches.


As a result, the Commission proceeded to a regulatory settlement consisting of:

  • £175,718 payment in lieu of a financial penalty and divestment, which will be directed towards delivering the National Strategy to Reduce Gambling Harms;
  • agreement to the publication of a statement of the facts in relation to this case; and
  • payment of £12,466.35 towards the Commission's costs of investigating the case.

You can read the press release here and the decision here.