L&L Europe's £900,000 Settlement Reveals Failures in Casino Compliance Checks

An online casino operator that delayed customer withdrawals through additional checks was also failing to follow its own anti-money-laundering procedures, a Gambling Commission investigation has found. 1

L&L Europe Limited has agreed to pay £900,000 following regulatory breaches between October 2024 and October 2025. The company operates seven gambling websites, including All British Casino, Casino Casino and Hyper Casino. 2

The findings covered unfair withdrawal restrictions, shortcomings in customer due diligence and failures to identify signs of potentially harmful gambling. 1

Withdrawal checks imposed unnecessary delays

L&L Europe's terms prevented customers from requesting another withdrawal until an existing request had been authorised.

The Commission found the restriction unfair under the Consumer Rights Act 2015. It also identified withdrawals being withheld for reasons unrelated to legal or regulatory obligations.

Under the company's fraud and collusion procedures, every fifth or tenth withdrawal was manually reviewed for certain customers. Some reviews resulted in additional documentation requests before payments were released.

L&L Europe acknowledged that these checks had delayed withdrawals and that some of the information could reasonably have been requested earlier. Gambling Commission rules prohibit making a withdrawal conditional on information an operator could reasonably have obtained before the customer requested payment. Further checks remain permissible where another legal obligation requires them.

The company has amended its procedures. According to the Commission, withdrawals are no longer withheld unless there is a legal or regulatory requirement. 1

£4,400 deposited, £50 withdrawn

The investigation also found shortcomings in how L&L Europe assessed the source of customer funds.

In one case, a customer deposited £4,400 within eight hours of opening an account and made a £50 withdrawal. The operator accepted the source of funds as a gambling account without adequately considering the underlying source. The bank account involved had been opened just two weeks before the customer registered.

When the customer contacted L&L Europe about a withheld withdrawal, further documentation was requested. The customer twice supplied an incorrect address, but the discrepancies did not prompt suspicion from the operator.

L&L Europe's own due diligence procedures recognised that knowing the account from which money was transferred was not necessarily sufficient to establish a legitimate source of funds. The Commission found that the operator was not always following those procedures. 1

The regulator also criticised controls that relied heavily on financial thresholds and sampling rather than individual risk factors and customer profiles. GamRight explains the distinction between routine verification and enhanced due diligence separately.

Monitoring missed warning signs

The Commission identified separate weaknesses in systems intended to detect potentially harmful gambling.

One customer attempted to deposit money 84 times over seven days. The transactions failed because of insufficient funds, but the system did not identify the potential for harm.

Although the operator had alerts covering failed deposits, time spent gambling and deposit frequency, they were not active across all its websites. Alerts were also generated only when two indicators were present on the same day.

The investigation identified further cases involving younger customers. An 18-year-old lost £4,000 in eight minutes without the relevant indicators being identified. A 21-year-old lost £6,500 within three days of registering, with the customer's age not adequately considered.

In another case, a customer reached a financial threshold on their first day but did not receive a required telephone interaction until two weeks later, despite reaching the threshold repeatedly in the meantime.

The Commission found that L&L Europe could not demonstrate an effective process for evaluating its overall approach to customer interactions. 1

Procedures that did not work in practice

The findings covered failures in both the design and implementation of the operator's controls.

Withdrawal reviews delayed payments through checks that could have been completed earlier. Anti-money-laundering controls relied too heavily on thresholds and sampling, while existing due diligence procedures were not consistently followed. Customer-monitoring alerts were either inadequately configured or absent from parts of the company's website portfolio.

The settlement also covered breaches of technical standards concerning financial limits. In one case, a customer returning from self-exclusion deposited £2,898 and withdrew £1,800 over nine days, exceeding an agreed £1,000 monthly net deposit limit by £98. 1

The £900,000 payment is in lieu of a financial penalty and covers the wider regulatory findings, not withdrawal delays alone. The settlement also provides for publication of the findings and a contribution towards investigation costs. 3

L&L Europe accepted its failings at an early stage, cooperated with the investigation and introduced an improvement plan. The Commission took those actions into account when agreeing the settlement. 1