L & L Europe to pay £900,000 to Gambling Commission over AML and other failings
The Gambling Commission found failings in the operator's anti-money laundering and social responsibility controls between October 2024 and October 2025, and agreed a £900,000 regulatory settlement.
The Gambling Commission's public register shows a regulatory settlement with L & L Europe Limited, with a decision date of 21 October 2026. The licensee will make a payment in lieu of a financial penalty of £900,000. The listed outcomes also include Commission costs and a public statement. The register gives the operator's head office as Mosta, Malta.
According to the register, the Commission started a regulatory review under section 116 of the Act after a compliance assessment of the operator's remote operating licence. The review found failings in the licensee's anti-money laundering and counter terrorist financing (AML/CTF) controls and its social responsibility controls between October 2024 and October 2025.
On AML, the register cites paragraphs 1, 2 and 3 of licence condition 12.1.1. This condition requires licensees to conduct an assessment of the risks of their business being used for money laundering and terrorist financing.
The register also cites paragraph 1 of licence condition 7.1.1 on fair and transparent terms, paragraph 2 of licence condition 17.1.1 on customer identity, social responsibility code provision 3.4.3 on remote customers (paragraphs 5(b), 5(d), 5(g), 11, 12 and 13), and licence condition 2.3.1 on technical standards.
Why it matters to AML professionals
Gambling operators carry AML duties, and the Gambling Commission continues to settle cases where risk assessment and controls fall short. AML professionals in gambling should be able to show that their written risk assessment shapes the checks applied to real customers.
Red flags in this case
- Deposits that do not fit the customer's stated income, occupation or past play
- Money arriving from newly opened bank accounts or several payment methods in a short period
- Large deposits followed by withdrawal requests with little gambling activity
- A customer who avoids or delays giving source of funds information when asked
If this landed in your queue
- Compare the customer's deposit history with their risk profile and any source of funds evidence on file
- Check whether the risk triggers in your policy fired and whether the required checks were done on time
- Ask for proportionate source of funds evidence early in the relationship rather than only at withdrawal
- Escalate to the money laundering reporting officer (MLRO) and consider a suspicious activity report if the funds stay unexplained
What control failed
Risk assessment. The Gambling Commission cited licence condition 12.1.1, which requires licensees to assess the risks of their business being used for money laundering and terrorist financing, among failings in the operator's AML/CTF controls.
Key terms
- Regulatory settlement
- An agreed outcome between a regulator and a licensee that resolves a case without a contested penalty decision.
- Payment in lieu of a financial penalty
- Money the licensee agrees to pay instead of the regulator imposing a formal fine.
- Business risk assessment
- A firm's written review of how its products, customers and channels could be used for money laundering or terrorist financing.
Interview angle
Why do regulators focus on the business-wide risk assessment in gambling cases?
Say that the risk assessment is the basis for every other control: thresholds, due diligence triggers and monitoring should follow from it. Give an example of how a gap in the assessment can lead to weak checks on high-risk customers.
Sources
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