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Hi danhor - welcome back!

I have some immediate concerns about this complaint. In the first instance the UKGC does not stipulate what the AML policies at their licensees have to be, simply that they have to be appropriate to the prevention of fraud and money laundering. By centring your argument on the premise that you've used someone else's card and as such the operator has failed to engage appropriate security measures, this can only be demonstrated if you have indeed engaged in something inappropriate and the operator has failed to catch you. In other words, if you've used someone else's payment method without permission. If that is the case this has potential legal consequences for you alongside potential licensing consequences for the operator. Without having done anything wrong arguing that the operator's AML policies were insufficient is a subjective argument without demonstration of failure of their policies.

There may be more to look at in terms of Responsible Gambling in this instance but I'll have to speak to the operator before I can offer further comment on this.

Thanks,

ThePOGG

Hi danhor,

In order to review your case further AllBritish have requested that you provide direct permission to them for them to share information about your account to ensure they are compliant with the GDPR.

As such I've just emailed you a template permission letter. You need to complete the letter, print it, sign it, take a photo and email this to AllBritish support. When you do this you should CC in <a href="mailto:complaints@thepogg.com" rel="nofollow">complaints@thepogg.com</a> and I'll follow up with the operator once we've received this.

Thanks,

ThePOGG

Hi danhor,

I've now had the time to review your case in full. Unfortunately we cannot support your claim.

Firstly with regard to the AML concerns you raised there are two significant factors here:

i) You may or may not be the named on the card used, but it can be verified via the banking transactions that your name is associated with the account in question - i.e. you are named as approved to use that account.

ii) All transactions carried out on the account were 3D verified, which means that you have to confirm the security verification information for the card before the transactions will be processed. 


Moving on the the Responsible Gambling aspects of your complaint. For an operator to take action on a Responsible Gambling basis there would need to be significantly concerning activity on the account or a significant change in the pattern of activity on the account. 

The activity on your account is as follows:

- 31/7 - 40 deposits ranging from 20-40. Total amount deposited 1240
- 1/8 - 28 deposits ranging from 30-40. Total amount deposited 1190
- 3/8 - 32 deposits ranging from 20-40. Total amount deposited 910
- 4/8 - 2 deposits of 20
- 6/8 - 12 deposits ranging from 10-14. Total amount deposited 124
- 13/8 - 38 deposits ranging from 20-30. Total amount deposited 780

While there are frequent deposits on some of the days you do play these aren't in of themselves particularly concerning. Lots of players choose to make regular smaller deposits rather single larger deposit. The total amount deposited in any one session is not significantly concerning. The deposit amounts are a relatively consistent size. Over the duration of your activity with AllBritish there's no significant change in this pattern, with the activity immediately after your registration actually being markedly higher than your later activity.

Beyond the transaction volumes I also looked at your betting patterns over the duration of your activity. Your bet size remains relatively consistent throughout your sessions at around 4-5/spins. There's certainly no escalation in the amount being bet.

Finally, during your two weeks of activity you don't activate any of the in account Responsible Gambling tools offered in the AllBritish account, nor do you say anything that would indicate that you were experiencing any issues.

While I do understand this will not be the outcome that you wanted, having reviewed the case in detail there's simply not enough in your pattern of activity that we would have expected the operator to determine that you were experiencing issues controlling your gambling without a direct request from help from you.

Sorry we could not be of further help,

ThePOGG

Without directly informing the operator that they were experiencing issues controlling their gambling the activity patterns were not enough by themselves to demonstrate an issue.

The issue that I have experienced was: Over the past two weeks, I have deposited over £4,000.00 in 150+ separate transactions. I was asked to provide identification / KYC verification when I approached deposits of £2,000.00, in line with AML regulations, but my account was not put on hold whilst this was carried out and I was allowed to deposit, using the same payments methods, a further £2,000.00+ over the next 10 days without any documents submitted (http://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-compliance/AML/How-to-comply/Anti-money-laundering-compliance-advice.aspx). When I was originally asked to provide verification on the payment methods used, I responded stating that I was using a card in a different name and was given a document for the card holder to sign and authorise previous/future payments. I did not return this document (or any verification) yet I was able to make additional deposits with no cap. Clearly, I have an issue with my play which is evident in the fact that I self-excluded myself from further deposits on 13/08. I was contacted twice by yourselves to complete identification checks and in the second request from yourselves I was even asked if I would like to change my mind with regards to marketing preferences because I was missing out on VIP offers. Why was my account, or at least the deposit methods, not put on hold whilst verification was carried out? Out of desperation I even spoke with the Live Chat service and asked for free play after losing so much money, and I was not reminded about verification nor did they question my play/losses to ensure that I was not a problem player. I completely accept that I made the decision to make the transactions, however - if the casino acted in a socially responsible way that UK consumers and the UKGC would expect, this could and should have been averted.
 
 It occurred on: July-August 2018
 
 They should provide a refund of all deposits made after either:
 
 1. When I approached the AML regulations limit of £2,000.00.
 2. When the casino were advised that the payment method used was not in my name.

All British Casino - social responsibility, AML and use of 3rd party card issues

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