Date: 01 June 2020
To: UK Gambling Commission
cc’d: Head of Operations, Aspire Global.
I am requesting an update as to the progress of a case involving UKGC registered company, Aspire Global Communications. I submitted the initial case material to you over two years back now. The case involved the company sending me marketing communications after I had self excluded, following a spell of disordered gambling where clear harm markers I displayed were ignored by the company. The case also involved a lack of compliance with Money Laundering Regulations (MLR) as it is clear to see that there was not ongoing monitoring of my account once a business relationship was formed, as stipulated within MLR.
Last year I agreed to sign a ‘settlement agreement’ with the company (AKA a NDA). The following month, remarkably, the company sent me further marketing communications to try to entice to gamble again, despite informing them I was a disordered gambler and wished to self-exclude some years back now. At the time The Head of Operations at the company (cc’d I this email) informed me that ‘lessons had been learned’. I asked him whether he had reported the case to The Commission, as per the regulatory requirement. The Head of Operations informed me that he wasn’t sure of the rules on this and would have to refer the matter to the relevant department.
Then this year I have received yet further marketing communications from the company attempting to entice me to gamble again. The company have ignored me each time I have informed them of these further LCCP breaches. As you aware, whether these marketing communications were done so via an affiliate is an irrelevance as it is the licence holder that is wholly responsible for their affiliates’ activities.
Please therefore address the following;- what initial action did you take when I supplied you with clear evidence that this company had breached SR and marketing LCCPs?- Did the company report the case to you in 2018, when I made them aware of the breaches, as per their regulatory requirement? – Did the company make you aware of the existence of the subsequent NDA?- Did the company report the further breaches of SR/marketing codes when I made them aware, following signing the NDA?
I find it extremely concerning that you may have chosen to ignore my case material and equally concerning if it materialises that the company have not reported the breaches and the existence of the NDA to you. I find it concerning that since reporting the initial breaches to you, the company have committed further breaches towards me. What concerns me the most is that if you have ignored the material I have set you, how many other vulnerable people have been exploited by continual breaches from this company? How many disordered gamblers that have self-excluded have been sent marketing material from this company that may have triggered an extremely harmful event in their lives, either by opening another account with this company or opening an account with another licence holder?
Should you simply wish to pass me a generic response quoting policy without answering the points I have raised, I shall ensure this case is passed to the ‘right people’ that have an interest in the potential shortcomings and negligences.
For you information, this letter will be published on Gamvisory.com, under ‘publications’.
I look forward to a meaningful response from you in the very near future.