The UK Gambling Commission has released its findings on gambling business International Multimedia Entertainment Limited.
IMME has provided a facility for betting on the outcome of the international lottery under a real-world event betting license, calling consumers and hosting its website, lotteries.com .
IMME also currently operates a license-free lottery syndicate business. IMME's business relies on employees calling consumers and using the thelotterycentre.com website for digital marketing.
As concerns were raised about the way the business was conducted, the Commission suspended IMME's operating license and launched an investigation.
This revealed significant suitability, social responsibility and money laundering failures.
Conformity concerns include: Customers complaining about being repeatedly called by IMME sales agents, including one customer in his 90s who was called multiple times a week. Another complainant said Lotteries.com customers answered the phone five or six times, every 30-40 minutes until they answered the phone 75% of customers are over 60 and 20% are over 80. This demographic appears to be disproportionately focused on the elderly and IMME has not taken into account potential vulnerabilities in its customer base Multiple complaints about consumers' police and action scams on IMME products Calling call center employees who use pseudonyms raises questions about why employees can be instructed or chosen to be dishonest about their real names. Failure of social responsibility: IMME has not been able to fully demonstrate to the Commission its safe gambling interactions with customers There was no record of interaction with a customer (aged 78) who spent £63,951 in just three months One customer, 74, was able to deposit £9,379 over eight days without proper responsible gambling interactions. Money Laundering Failures: One customer, who was 100 at the start of the committee's review, had bet £23,839 in just months. His deposits more than doubled from £2,992 in September 2018 to £6,090 in October 2018 and continued to increase, but IMME failed to obtain evidence of funding sources IMME was aware that two of its top depositors were retired postmen, but it did not get any further information to support that level of spending, allowing one to bet £20,345 in five months and the other to bet £16,207 in six months.