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Frank&Fred – Limit not working


Unresolved - There is some clear ambiguity in the definition of the word 'loss' in this instance, but given the regulator's historic position and our ADR role we do not feel we can provide a judgement on this matter.

Read our Frank&Fred Casino Review.

Player's Complaint

Hello Thepogg, I have set up a loss limit of € 1 a day for Frank and Fred to protect my outstanding payouts. Unfortunately, the loss limit didn't work and I was able to gamble away a € 2,000 withdrawal. The support wanted to explain the non-working limit with a net loss limit. However, I had deposited € 20 for the test where I was told in the chat that I could only gamble away € 1. This didn't work either and I was able to gamble away the € 20. My account was then blocked and the € 20 refunded to me. The casino refuses to refund the € 2,000. Evidence from chat and limit is available.

Read the casino review

2 Responses

Jan 03, 2021

Hi spacebear - welcome back!

I'll contact the operator and see what we can find out for you.



Feb 14, 2021

Hi spacebear,

I've discussed this issue with the operator. This is an ambiguous case.

Under MGA license requirements, licensees are not actually required to offer a loss limit at all. The guidance that the regulator has issued historically on this matter has directed that where operators do offer loss limits should be based on player deposits, disregarding winnings. The concept behind this is to protect players from experiencing financial losses, not to preseve wins. Under this interpretation, as your balance was made up of winnings rather than deposited funds, the loss limit would not have been triggered.

However, it does seem to me that the term 'loss' can be interpreted in multiple different ways, those being the reduction of balance from its present point or overall financial position and I do question whether the Frank&Fred system was clear enough in detailing how this system should function.

Given that the Loss Limit did function in the manner that the regulator has directed I don't feel that we - as an ADR serving on behalf of MGA licensees (albeit not Frank&Fred) - can rule against the operator. But given the ambiguety of the definition of 'loss' I don't feel we can fully support them either. As such this complaint will be ruled as 'Unresolved'.

Sorry we could not be of more help.


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spacebear consented for ThePOGG to act on their behalf and share the personal information that they provide to ThePOGG with the following agencies for the purposes of resolving their complaint:

  • Frank&Fred
  • Malta Gaming Authority
  • The Mill Adventure Ltd

January 3, 2021

The United Kingdom of Great Britain and Northern Ireland sits to the north-west of mainland Europe. The United Kingdom shares a border with The Republic of Ireland and has coasts on the Atlantic Ocean, Celtic Sea, North Sea, Irish Sea and English Channel. The population of the UK is approaching the 67.6 million mark leading to a fairly densely populated land mass. The gambling sector in the United Kingdom is entirely regulated and licensed by the UKGC – the United Kingdom Gambling Commission. Should players resident In the UK wish to gamble with foreign based operators there is no history of this being treated as a criminal offence, but high levels of protection exist for UK residents playing with UK licensed operators.


The above information is what we believe to be the the legal status of online gambling, however information on this topic is limited and hard to find. We accept no liability for any errors or ommissions. It is the reader’s responsibility to ensure that they know the legality of online gambling in their country before engaging with any online gambling service.