GC reveals Playtech brand’s failings after customer suicide

Playtech’s PT Entertainment Services (PTES) arm surrendered its GB B2C licence, after a customer's suicide led to the Gambling Commission uncovering serious failings within the business such as a lack of problem gambling safeguards for new customers and VIPs.

The death of the PTES customer who had lost more than £100,000 in the days leading up to his death in April 2017 prompted the Commission's investigation into PTES, which operates the Winner and Titanbet brands, and held a remote bingo, casino and betting licence at the time. It is understood that the operator opted to give up its licence in 2019 with Winner announcing in May that year that it was to close its doors.

“This is a tragic case which came to light after I was contacted by the family of the young man who very sadly took his own life,” Gambling Commission chief executive Neil McArthur said. “I want to thank them for their bravery in bringing his case to our attention and we are grateful for the way they have worked with us in such terrible circumstances so that we could understand what happened.”

The Commission's investigation found “systemic failures” in PTES's player protection and social responsibility safeguards. These social responsibility failings were highlighted through PTES’s interactions with the deceased customer, who opened a Winner account on 26 December, 2016, and a Titanbet account that same month. Despite two attempted deposits using a debit card being declined by the individual's bank, they suceeded in depositing £18,700 on 26 and 27 December, far higher than the average deposit for the business.

On 28 December, after a £4,000 deposit was declined by their bank, PTES provided a free gift of an Apple Watch that day and offered the player membership to its VIP programme. The player told the operator that they were grateful, as no other sites had offered similar rewards despite their wagering “much more” with these unnamed sites.

On 29 December, an internal email flagging the customer's net loss of £22,000, that they were 25 years old, and that PTES was unaware of their occupation was circulated. However, the Commission said, PTES gave no consideration to social responsibility or problem gambling checks, despite the player having had debit card payments declined, the operator being unaware of the individual's occupation or financial state, and the fact that they had claimed to be gambling even more on other sites.

Instead, it emailed the customer inviting them to take part in its Jackpot Giant promotion, offering a chance to win a £3.5m prize. 

“This amounted to an inducement to encourage more and higher levels of play when PTES had not assured itself that such play was affordable,” the Commission said.

While the individual won a substantial amount of money via their Winner account, and passed a source of funds check to withdraw the funds. Between 26 December 2016 and April 2017, the customer wagered £4.46m, winning £4.47m, on roulette and blackjack games. During that time, PTES failed to carry out any responsible gambling interactions. Between 1 to 5 April 2017 alone, the individual deposited and lost £119,395, without any checks to ascertain they could afford that level of play.

Besides specific interactions with this customer, the Commission found that the operator’s responsible gambling triggers only applied if customers were active for between two and six months, and so customers who gambled a very large amount of money in a short space of time after signing up – as the customer did – were missed.

The Commission found that of PTES’s top 20 customers in terms of money lost, only two had received problem gambling interactions, while in its top 20 for winnings, only one had received such a check. Of those combined 40 customers, however, 39 had been accepted into VIP programmes.

Out of PTES’s 240,126 customers, 633 received responsible gambling emails – or 0.26% of all players – a figure the Commission noted was “exceptionally low”.

The regulator said that while PTES did conduct assessments related to money laundering and terrorist financing, these were not sufficient as they did not identify levels at which a risk of money laundering may be greater. In addition, PTES did not review and revise these controls regularly, which is also required in the licence conditions and codes of practice (LCCP), and failed to monitor ongoing relationships with customers. These failings amounted to a breach of LCCP 12.1.1 and 12.1.2, it said.

Social Responsibility Code 3.4.1 requires licensees to put into effect policies and procedures for customer interaction where they had concerns that a customer’s behaviour may indicate problem gambling, the Commission continued. Specific provisions were to be made for VIP customers, it added. In addition, PTES had no specific responsible gambling checks for VIP customers and the Commission said there was a “clear lack of policy and training given to staff on how to manage so-called VIP relationships and minimise harm”.

As a result of PTES surrendering its operating licence before the investgation concluded, the regulator said it was unable to issue a financial penalty for the failings. Prior to this, PTES attempted to make a financial settlement on multiple occasions, but the Commission regarded its offers as “seriously deficient”.

It noted that PTES donated £619,395 towards the National Strategy to Reduce Gambling Harms as part of a settlement. Its parent company, Playtech, has pledged to donate £5m to mental health and gambling-related harm charities over the next five years. 

The Commission said it would have imposed a £3.5m fine had PTES retained its British licence. Titanbet's dot.com and dot.es sites are still active.

The regulator explained that it had published its findings in the public interest, so that other operators may learn from the issues identified in the case.

“Although PTES has ceased trading we decided to complete our investigation and publish our findings, as the lessons from this tragic case must be learned by all operators,” McArthur said.

The Commission said it is continuing to “investigate the role played by key individuals at PTES who still hold personal licences” and that it may take further action against these individuals if necessary.

The regular also asked numerous questions of other operators to ensure they did not commit the same failings as PTES. It ordered operators to implement an “effective VIP framework that ensures the bonuses and incentives are offered in a manner which is consistent with the licensing objectives” and to ensure “policies and procedures for identifying high risk customers for AML and social responsibility are being implemented effectively to safeguard customers”.

In addition, it asked operators to ensure they give “equal consideration” to AML and social responsibility breaches, and to conduct problem gambling interactions regardless of whether a customer is winning.

Commission chief executive McArthur said the regulator will soon open a consultation to introduce new safeguards around high-value customers.

“This case – like so many others we have seen – illustrates why the management of so-called ‘high value customers’ has to change,” McArthur said. “Operators must do everything in their power to interact with customers responsibly. We will shortly be opening a consultation to make permanent changes to the way operators recruit and incentivise high value customers.”

In April, the Commission announced that gamblers aged 25 and under will be banned from joining operators' VIP schemes as part of a series of voluntary reforms intended to reduce gambling-related harm. All customers eligble to join VIP schemes will also be required to pass a series of checks relating to spend, safer gambling and enhanced due diligence, before they can take advantage of incentives.

Playtech, PTES' parent company, is leading a working group on responsible game design with Scientific Games. In April, when the new VIP controls were announced, the Commission demanded more of this group, arguing that it had to do more to ensure player protection controls were integrated into real-money content.

“The Gambling Commission’s view is that while some progress has been made, this work must now go further and faster, in particular around using demographics and behaviours to indicate risk,” it said. “The Gambling Commission will now consult on the priority areas for immediate action as soon as possible.”