
UKGC Review Exposes Gaps in Risk Management
The regulatory review under section 116 of the Gambling Act 2005 followed a compliance assessment of NetBet’s remote operating licence (number 039170-R-319343-028). Investigators found that between November 2023 and July 2024, the operator failed to maintain adequate AML and Counter Terrorism Financing (CTF) systems, and its processes for safeguarding vulnerable players were insufficient.
The UKGC noted that NetBet’s money laundering and terrorist financing risk assessment failed to consider significant risks such as managing third-party business relationships, handling high-stakes gambling, and monitoring customers from third countries living in the UK. The operator was also deemed overly reliant on financial triggers, allowing some customers to spend well beyond their means.
In one example, a customer deposited nearly £2,000 over four days via Apple Pay, worked in a high-risk occupation, and later provided a payslip showing a net monthly income of around £2,800. Despite the clear mismatch between income and gambling spend, the player was not escalated to the Money Laundering Reporting Officer and remained classified as low risk.
Failures in Player Protection and Data Accuracy
The Commission further found that NetBet had not properly implemented customer interaction systems to prevent gambling-related harm. During various periods between September 2022 and July 2024, the operator missed clear indicators such as overnight play, rapid deposit cycles, and escalating gambling patterns. In several cases, problematic behaviour was only flagged after manual account reviews, meaning that interventions were delayed.
Other breaches included the submission of inaccurate information in the operator’s regulatory returns, which are used by the Commission to determine fee categories, compile industry data, and oversee market compliance. Officials also noted a failure to include mandatory underage gambling warnings on the company’s website, though this was immediately corrected when pointed out in April 2024.
Additionally, the £1 million jackpot promotion on the NetBet website failed to display significant terms and conditions despite not being subject to space restrictions, breaching Social Responsibility Code Provision (SRCP) 5.1.9 on transparent marketing.
Settlement Terms and Required Audit
The Gambling Commission accepted a regulatory settlement consisting of a £650,000 payment in lieu of a financial penalty, an agreement to publish the statement of facts, and an undertaking to commission an independent audit. The audit will assess the effectiveness of NetBet’s updated governance, compliance, and risk management arrangements.
The Commission considered prior public statements on similar issues as aggravating factors. However, it acknowledged NetBet’s prompt cooperation and willingness to rectify shortcomings, including developing an internal action plan and providing timely updates throughout the review.
UKGC Director of Enforcement John Pierce stated:
“This case highlights the serious consequences of failing to meet anti-money laundering and social responsibility obligations. We expect all operators to take note and ensure their systems are not only well-designed but are working effectively to protect consumers and to keep crime out of gambling.”
He added that the operator had been ordered to make significant system improvements, including stronger risk assessments, better detection of harm indicators, and accurate reporting procedures.
The Commission reminded all licensees to assess their AML thresholds, verify that their safer gambling controls effectively identify all indicators of harm, and ensure promotional materials comply fully with the Licence Conditions and Codes of Practice.
Source:
NetBet Enterprises Limited to pay £650,000 for regulatory failures, gamblingcommission.gov.uk, November 5, 2025.

