Casimba - failed to follow UKGC AML/KYC regulations, resulting in £40,000 of deposits in one session
In October 2018, at the height of my issues with problem gambling, I opened a Casimba account and deposited £40,000 in the space of a few hours, across multiple cards and resulting in multiple transaction failures.
After working on my issue over the past year and a half, this night has always haunted me - so much so that I took some time to look further into it, as it didn’t seem right. After some investigation, I became aware that Casimba failed to carry out adequate AML and KYC checks on me and my deposits, once I passed the €2000 threshold.
I got in touch with Casimba on 2 March 2020 and then again on 10 March, when I received a reply telling me that their complaints department would need “a few working days” to get back to me. I followed up again on 24 March with no reply and I am yet to receive a response, over 2 months later. I contacted their live chat earlier today and was told the same thing as before: “the relevant department is looking into it. Keep an eye on your emails.”
Looking at their terms and conditions, they mention 28 days as a target, but some cases may be up to 8 weeks. Given that we are now over 8 weeks, I am hopeful that ThePOGG may be more likely to get a response than me.
I have included the original email that I sent to Casimba below.
Over the past number of years, I have suffered from problem gambling. This resulted in me registering with GamStop on the day that this took place in 2018.
Having done some further research into the circumstances around this email, I am confident that you failed to fulfil your UKGC requirements as a gambling operator, for both Responsible Gambling and Anti-Money Laundering. Therefore, I request that you provide a full refund of £40,000.
I have reviewed the documentation set out by the UKGC, here: https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-compliance/AML/How-to-comply/Anti-money-laundering-compliance-advice.aspx.
From the documentation above from UKGC:
For casino operators, a key requirement of the Money Laundering Regulations is to make checks on customers. Two approaches can be adopted by casino operators:
• identifying and verifying the identity of all customers on entry to the premises
• undertaking identification and verification when a customer approaches a deposit, spend or win of €2000.
For online operators, this means that you must undertake identification and verification when a customer approaches a deposit, spend or win or €2000. You failed to do this, as highlighted by this email, where you only requested this information the morning afterwards, after £40,000 had been deposited and lost.
Furthermore, the documentation states:
Casino operators should also apply enhanced due diligence measures where:
• the customer is a politically exposed person (PEP)
• the customer comes from a high risk jurisdiction
• there is any other situation which can present a higher risk of money laundering such as an increase in frequency or spend by a customer, or their inclusion on a sanctions list.
I opened this account and immediately began depositing, across 3 cards (moving on to the next one as the other failed due to lack of funds), to a total of £40,000. All of the aforementioned actions should raise suspicion of high risk transactions.
Had you followed the regulations set out by UKGC, my account should have been blocked from making further deposits and I should have received this email once the €2000 threshold had been crossed. This would have prevented me from depositing further funds into your website until you had verified the source of funds, meaning that I would have been able to cool off and would not have continued to deposit and lose money in this short space of time. In fact, you even reference the UK Gambling Commission website in your email.
To summarise:
• I made multiple deposits, totalling £40,000, from 3 credit and debit cards, with payments failing on multiple occasions, due to lack of funds, before moving on to the next card
• Casimba failed to initiate KYC/AML checks after €2000 of transactions, resulting in me being able to deposit and lose much more money, beyond my means
• Casimba failed to recognise the high frequency of deposits and spending on a newly opened account as being a high risk of money laundering and continued to accept deposits
• Casimba failed to recognise the multiple card payment failures as being a high risk of money laundering and continued to accept deposits
I request that you make refund of these £40,000 worth of payments to your company. If you are unable to resolve this matter, I will be left with no other choice than to make a formal complaint to the UK Gambling Commission and, if necessary, seek legal advice to proceed further.
