UK-licensed lottery operator escapes sanctions after license surrender

IMME Ltd, aka International Multi-Media Entertainments Limited, has been found by the Gambling Commission in the United Kingdom to have breached the terms of its license in multiple ways and the Isle of Man firm’s ability to conduct games of chance in Great Britain has been revoked.

Canadian citizen Gloria Jean Evans registered with the Isle of Man government in September 2020 as the company’s director using a Douglas IoM address. According to separate reports, Evans served previously as CEO of Vancouver-based lottery reseller CW Agencies. An Irish national based in Hertfordshire, England was listed as the finance director – Paul Michael Whelan

Both of them surrendered personal gambling business licenses to the Gambling Commission.

According to a 2016 article in the Vancouver Sun about a lottery reseller closing up shop and laying off 200 Canadians just before Christmas, there may be a history in the industry of targeting the elderly.

The Dec 23, 2016 article stated: “Telco is connected to CW Agencies, one of the only resellers of European, Australian and Atlantic Canada lottery tickets to have escaped significant penalties from U.S. investigators, who in the 1990s were battling an entrenched illegal lottery ticket industry in B.C. that targeted elderly Americans.”

At Least One Target was 100 Years Old

Trading under the names The Lottery Centre and, the company was found to be targeting seniors and pensioners with phone solicitations. The UKGC’s report states that 75% of the victims were aged 60 to 79 and 20% of them were 80 years old or elder. Sales agents, who used made-up names, would contact the victims in an effort to persuade them to play lotteries online.

It wasn’t made clear to them that the company was only accepting bets on lottery outcomes and not actually providing a messenger service or direct lottery ticket sales. The websites are no longer available to web users in the UK, but we were able to find archived versions of the sites and the actual process of betting is only explained in an obscure FAQ. A 2016 press release announcing one of the companies explicitly stated that they were “lottery-ticket agents”.

Pensioners Encouraged to Bet on Lottery Outcomes

We don’t find any accusations of outright theft from players. The sales associates did target older citizens by an overwhelming majority according to the report.

Over the course of five months, one customer, a centenarian, bet £23,839 without the company ever inquiring about the customer’s source of funds. Two of the company’s top depositors were retired postal workers. The company knew that and still accepted bets from one of £20,345 over five months and a total of £16,207 from the other over the course of only half a year.

Records keeping violations were high on the grievance list from Commissioners with staff members having no access to records of their customers so they had no way to process checks on responsible gambling. There were reportedly no records kept at all on a 78-year-old customer who deposited £63,951 in less than four months.

Marketing practices were also found to be most egregious with a harassing level of attempted contacts on the telephone. One potential customer was called every 30-40 minutes until she would answer her phone and another, in her 90s, was called several times each week.

In order to encourage deposits, the company’s literature intimated that players would be contributing to good causes while betting on the lotteries, but there were no such charities.

Escaped Responsibility with License Surrender

According to The Guardian, IMME’s license was suspended in March 2020 and would have been revoked had the operators not surrendered. With the licenses surrendered, the Commission is not legally allowed to levy sanctions, fines, penalties, or offer payments in lieu of penalties as IMME no longer falls under the agency’s purview.

The company did not cooperate with the investigation, according to the Commission.

The company said that it is attempting to return all deposited funds to players and stated: “IMME ensures that every player is telephoned as soon as they spend £160 and every player is assigned a customer care agent who monitored their play. Additionally, all players over 70 years of age received a social interaction call after every sale regardless of size.”

The Gambling Commission said the IMME continues to run lottery ticket syndicates but current law doesn’t require a license for that type of business.

Executive director of the Gambling Commission, Helen Venn, said: “There is no room in Britain’s gambling industry for operators who fail in the way IMME have.

Source: Gambling firm that coaxed older people to bet thousands will escape sanctions, The Guardian, December 22, 202

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