Spreadex fined again for AML failings

Hi ,

Last week the Gambling Commission announced the second fine in three years for Spreadex - the Sports & Financial Trading UK spread-betting company founded in 1998 (revenue of £103.3m to 31 May 2024).

This time the Gambling Commission fined Spreadex £2,022,000 for broadly similar AML & social responsibility failings to the 2022 fine of £1,360,000.

The £ fine amounts seem similar but the tone from the Gambling Commission has changed.

The 2022 fine was accompanied with a note of co-operation and “swift and robust action the Licensee took” (see below).

Last week’s fine was announced with a far stricter tone - “Its failure to uphold anti-money laundering standards, delays in necessary interventions… …were unacceptable”

Below, I highlight what stayed the same, what worsened, and one key takeaway for you.

What Stayed the Same

Both 2022 and 2025 enforcement actions featured:

• Weak Source of Funds checks - High-value deposits were allowed without verifiable documentation

• Inadequate escalation processes - Risk was not reassessed or scrutiny increased as gambling behaviour intensified

• Poor record-keeping and evaluation - Interactions were logged, but not meaningfully assessed or actioned

What Got Worse

The Gambling Commission specifically highlighted in the 2025 fine that the Spreadex risk assessment framework didn’t meet the Gambling Commission expectations - it didn’t consider “key customer, product, geographic and payment risks”

One key takeaway for you as AML Leaders

Don’t over-rely on customer self-reporting
The Gambling Commission made a big deal out of this in the enforcement action and it’s a good prompt to review your approach no matter what regulator you deal with:

I’m currently working on enforcement actions across OFSI, FCA, FinCEN and OFAC and hope to publish another few this week - I’ll give you some tasters throughout the week.

Cheers

Paul