Social responsibility failures included:

• having insufficient controls in place to protect new customers, and to monitor high velocity spend and duration of play exposing the customer to the risk of substantial losses without safer gambling interaction
• making assumptions that customers were not at risk of harm because they were winning customers – it failed to carry out any safer gambling interactions on one customer who staked £517,499 over a two-month period
• a lack of evidence of evaluation of the effectiveness of individual customer interactions and a lack of record keeping which limited the effectiveness of future interactions.