Should My Bank Have Done More?

[satchnz]

And to add to what @Jono777 said above, I feel this thread is sending a very wrong message to the community. If you have a gambling addiction, take steps to block yourself, but continue to deposit and gamble anyway, the banks will have your back by way of refunding your losses. I can only see that fuelling problem gamblers, nothing more.

 

[conker]

Too right, very harsh post @Jono777, I believe the OP asked for some help and advice, I didn't get the impression he was after some morality lessons from our educated community.

You're probably right, there is some responsibility for the gambler to take control of their situation and make sure they are not blowing their wages/savings on gambling.

However, I also believe there is a responsibility for banks and gambling websites to make sure that the person at the centre of this is making informed decisions. A call, an email, something to check in with the customer and make sure they are ok.

Do they really want to wire another xxxx amount of money to Belize, having done so hours earlier? It's not a lot to ask, as you can guarantee these payments would have been coming up in big flashing lights on their systems at Lloyds and Barclays.

 

[Educated_ant]

I don't think there will be anyone harsher than myself for the mess I've got myself into. But at the same time the "swagger level" that Playhub Casino promote where you have to keep depositing and wagering to withdraw the money you have deposited / won... just is impossible to deal with when you have a gambling problem. It makes one really bad impulsive day turn into days, weeks, months of temptation, stress, fear that you won't get the money.... making you gamble and gamble in order to hit a level so you can withdraw everything and get out of it. But with that kind of activity it only ends one way.

At the end of the day, this unregulated offshore gambler should not be accepting UK customers for this kind of reason. The same as drug addict's supplier if they break the law to fuel an addiction. Simply put, they should not be due this money. Whether I should be, I understand the argument. But that casino should not.

 

[L&L-Jan]

At the end of the day, this unregulated offshore gambler should not be accepting UK customers for this kind of reason.

but thats their sole goal? For your bank its often also not a gambling transaction but you purchased fashion or so, can be anything.

Going forward to the only solution: Did you download and install betblocker on ALL your devices?

 

[Educated_ant]

I've literally given control of all my finances to my wife so I've gone a step further than that!

 

[L&L-Jan]

Buy virtual cards shop is a possibility, also there is a moment where she relaxes because it goes better.

Trust me, the only solution for you at this moment:

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- or ask you wife to do it for you.

 

[Educated_ant]

ok thank you, I will do that

 

[jasonuk]

Firstly, I'm glad you are seeking help - gambling addiction is incredibly dangerous and people frequently underestimate how destructive it can be.

The banking rules have changed considerably in recent years - all of the additional technological steps (such as SMS/2FA) are designed to ensure that you are you, and only you are the one spending your money.

This does have the unfortunate side effect that banks can be more lax on checks - because the liability now rests with you, rather than the bank or the merchant.

So the questions I can see:

• Should Barclays have done more?
• Should Lloyds have done more?
• Is there any way to get the money back?

It sounds like Barclays have already settled your issue given they refunded £10k - but then closed your account as a high-risk (in a commercial sense, and an AML sense) customer. They have the right to do that, so I doubt you'd see much traction there.

The only question with them is whether they should have forwarded information on your gambling block - but as far as I can see the current account switch service focuses on balances and payment instructions (direct debit, standing orders), so I doubt this would be in scope and I expect that onus would have been on you.

Regarding Lloyds, I fear you are thinking of the old ways here - the point of the SMS/2FA is to catch cases of unauthorised fraud faster and reduce the number of manual interventions by their security department. Which in your case has the unfortunate side effect that it allows you to keep gambling large amounts of money.

--

However, you then mentioned something interesting - the Curacao-based casino correctly used MCC 7995 for the transaction. The frustrating part here is codes 7800, 7801 and 7802 exist for licensed transactions but are currently restricted to use by US merchants - which means for the rest of us everything appears to stack on 7995.

So taking each one in turn...

For PlayHub, they correctly coded the transaction - the bank were made aware it was a gambling transaction and allowed it through despite being forbidden. Additionally, the site has since transitioned to an interim GCB license (the key question is when, although older CM threads suggest they were on the nasty 1668/JAZ license - which was terminated on October 1st 2024) which means they cannot accept UK customers, which may add credibility to recent transactions.

For DonBet, there are multiple such domains (by different owners), the one I found (dot com) still claims to be 1668/JAZ licensed, even though that doesn't exist anymore. The "About Us" page helpfully says "text", so that's not much help either...

So we have...

• In the first instance, initiate a complaint with the bank:
  • for card payments that would be a chargeback (although your rights start to erode after 4-6 months) - you would be able to challenge both MCC 7995 (because not licensed) and non-MCC 7995 (because merchant code fraud) transactions.
  • for bank transfers, you are going to have a fight on your hands - it's not covered by MCC blocks (which is how they prevent gambling transactions), it's not protected by the
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    either because the recipient is outside the UK... and you will have approved the transaction which puts the onus on you.
    • Sadly that's the reason why these shithole casinos are pushing towards bank transfers - they know how few rights you have to complain...
• If that doesn't work, you can then complain to the Financial Ombudsman (FOS) - but as others have already pointed out even when the bank is at fault, the amount of compensation may not reflect the amount of money lost.
• You'll want Betblocker as others have already mentioned - although I expect that will also block sites like CM, so make sure you've taken a copy of these threads before you install as you may not have access afterwards.

I think you have more of a case with the MCC 7995 transactions because the bank could and should have flagged those - but beyond that I think you'll be going through the motions and have limited luck with the other scenarios. It's a significant amount of money to lose, and a very painful reminder of the dangers of the high seas.

Something very strange about all this.

Can someone please explain to me how debit card payments can be made to non UK licensed casinos operating out of Belize? I guess it's the whole buying rugs online trick, but it's actually payments for gambling.

In which case, this possibly turns into a case of fraud.

There are multiple sites of that name (as mentioned above, another still claims to be 1668/JAZ licensed even though those don't exist anymore).

The PlayHub one is particularly concerning because that was coded correctly and still went through - they typically fake the merchant code because they don't want the scrutiny of MCC 7995.

Because the rules have changed in recent years, the onus is often on the consumer or the bank rather than the merchant, so the bank do additional verification checks, and the customer says they really want to buy that vase of flowers from Cyprus, then in their eyes there's nothing more for them to do - until the customer cries foul because they've lost their deposit and/or got scammed.

 

[Educated_ant]

@jasonuk - thank you for the really detailed and considered reply. This was truly beyond the kind of response I ever expected to get.

With this kind of chargeback request, is it ultimately Visa who make the deciding call? The bank are putting the request through for me and are happy with the evidence I've shown them in regards to PlayHub being unlicensed/unregulated, the terms and conditions not mentioning a single jot about withdrawal limits, the clear bypass of naming the UK as a restricted place, the lack of any due diligence verifications on me, the encouragement of using VPN to gamble, the terrible reviews of this company, the fact they've lost court cases and have been called a scam company... they all seem happy with that.

But is it not on Visa ultimately who make the call? And if Visa dont suggest a refund they would be endorsing these payments effectively if they didn't do that and that's against the law?

 

[satchnz]

Too right, very harsh post @Jono777, I believe the OP asked for some help and advice, I didn't get the impression he was after some morality lessons from our educated community.

@Jono777 post is far from harsh. It’s reality. Why do we need others to validate every poor decision we make? Do you really want your bank to validate every single transaction you make?

You need to own your own mistakes. I feel you are in the minority here.

 

[jasonuk]

With this kind of chargeback request, is it ultimately Visa who make the deciding call? The bank are putting the request through for me and are happy with the evidence I've shown them in regards to PlayHub being unlicensed/unregulated, the terms and conditions not mentioning a single jot about withdrawal limits, the clear bypass of naming the UK as a restricted place, the lack of any due diligence verifications on me, the encouragement of using VPN to gamble, the terrible reviews of this company, the fact they've lost court cases and have been called a scam company... they all seem happy with that.

But is it not on Visa ultimately who make the call? And if Visa dont suggest a refund they would be endorsing these payments effectively if they didn't do that and that's against the law?

The payment provider sets the rules, and then it becomes a review between the two banks (with your bank having the final say).

More information from Mastercard

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(the VISA version at

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is less helpful, but will follow the same lines).

Be aware of the 120 day limitation, and also that if you get a provisional credit (your bank considers the complaint valid) that it can be clawed back later in the review process (the complaint is valid but is denied after review).

@Jono777 post is far from harsh. It’s reality. Why do we need others to validate every poor decision we make? Do you really want your bank to validate every single transaction you make?

You need to own your own mistakes. I feel you are in the minority here.

I don't think it was harsh either - particularly as we don't want to send the wrong message here and people see it as as "freeroll" for their own mistakes.

For cases where there is a clear failure by the bank (e.g. accepting MCC 7995 transactions from offshore casinos), then there might be a path to a refund - because the bank has done something wrong.

For everything else, with the shifting regulations in recent years (and the increase in gambling-related fraud), the banks are more alert to their liability and will fight back more. The whole purpose of 2FA is to ensure the customer is the one making the transaction - and if that is the case, then the customer takes more of the responsibility when something goes wrong because the transaction has been validated successfully.

 

[conker]

@Jono777 post is far from harsh. It’s reality. Why do we need others to validate every poor decision we make? Do you really want your bank to validate every single transaction you make?

You need to own your own mistakes. I feel you are in the minority here.

Been stewing on that one for a while have we @satchnz?

I guess we all have different ways of looking at things. If you would kindly like to explain the mistake and I have made and I will gladly own it.

 

[Webzcas]

You'll want Betblocker as others have already mentioned - although I expect that will also block sites like CM, so make sure you've taken a copy of these threads before you install as you may not have access afterwards.

Yes it will. I interviewed Duncan a few months back ( perform a google search for 'Betblocker Interview', first results returned ;-) ).

Betblocker doesn't just block operators, but a vast myriad of gambling sites, including the likes of Casinomeister.

 

[dunover]

Ultimately it will come down to whether the bank believes it's buyer's remorse, or they are satisfied you were encouraged or hoodwinked into paying what are essentially criminals. Could you have been reasonably expected to know this?

If they observe you spent money on legitimate sites in the UK and then later on did not, then they could argue you should have known the difference. If they identify the recipients of the money as suspect or spot a system designed to remove money and prevent chargebacks (in the case of cards) it could help, but in the case of IBAN transfers you are wholly at the discretion of the bank as UK banks will continually ask when setting up a new payee if you are sure, they will inform you if the recipient info tallies with their data etc. It's a convoluted process sometimes setting up a payment to someone I know in the UK let alone internationally.

My gut feeling, as much as I hope for a positive outcome for you, is that the hurdles you jumped to make those transfers will pretty much nullify any chance of a refund. Even the argument that the gambling was unlicensed historically hasn't made any difference in similar cases we've had before. Caveat emptor is usually their philosophy unless they can actually retrieve these monies, and I am pretty sure that would be impossible. Good luck with the process anyway.

 

[satchnz]

Been stewing on that one for a while have we @satchnz?

I guess we all have different ways of looking at things. If you would kindly like to explain the mistake and I have made and I will gladly own it.

I’m not stewing on anything. And I meant that people have to own their own mistakes, not specifically you.

It is a mistake though to give problem gamblers a false hope. The messaging here risks doing that.

 

[jasonuk]

My gut feeling, as much as I hope for a positive outcome for you, is that the hurdles you jumped to make those transfers will pretty much nullify any chance of a refund. Even the argument that the gambling was unlicensed historically hasn't made any difference in similar cases we've had before. Caveat emptor is usually their philosophy unless they can actually retrieve these monies, and I am pretty sure that would be impossible. Good luck with the process anyway.

That's the harsh reality - the checks and balances, warnings and hurdles are there for that exact reason.

While we are entering a slightly different era with the CGCB, I suspect it'll be mostly the same despite it now being black market (because they cannot accept UK players) rather than grey market. Players will still get scammed, banks will continue to refuse refunds because it's not their fault (and in most cases, that's true) and the fraudsters will keep running off with the loot.

Even in the scenario with the merchant codes and where the bank has potentially made an error, they could point to the other transactions as a way to diminish responsibility, quite literally "they would have lost it on another site anyway" - and a bank being 10% liable is considerably less expensive than a bank being 100% liable...

At the end of the day, this unregulated offshore gambler should not be accepting UK customers for this kind of reason. The same as drug addict's supplier if they break the law to fuel an addiction. Simply put, they should not be due this money. Whether I should be, I understand the argument. But that casino should not.

And that is the scary reason why they do operate - if they can hook a whale they can make a fortune "legally", with limited amounts of comeback (and the longer they can stall the player, the more rights are eroded).

We've heard plenty of stories over the years of players, like yourself, that have lost eye-watering amounts of money and the short, sobering, answer to "what are my rights?" would be "what rights?". Your bank tends to be the primary port of call because all other options quickly lead to dead ends or risk making a bad problem much worse (e.g. expensive legal action with no guarantee of success).

I hope there's a positive outcome, but you will have to be realistic that most, if not all, of that money is gone... even if the bank and/or FOS find in your favour, the amount awarded may be a token gesture.

 

[snorky510238]

First time post. During Covid when stuck at home I became inflicted with a horrible gambling addiction for sports betting and particularly online casinos, regularly losing £10-20k in a month.

This went on for years but as 2024 started my wife helped me realise that this simply had to stop and I registered with gamstop. I told Barclays to block gambling on my account. Unfortunately, they still allowed me to continue betting. I complained and they refunded me my £10k losses that were accrued from the moment I asked them to stop me.

However, Barclays closed my account just days after this and told me to use a switch service to another bank as they no longer wanted me as a customer. I had been a customer of that bank since 1997 when my mum opened it for me aged 11... the only current account I had ever had and it caused me quite the upheaval.

I used the switch service to Lloyds bank. Before too long, this nasty addiction hit me again and I was soon gambling. In September I hit the lowest point of it. I lost my job of twenty years and panicked and made 27 deposits x £3k in 3 days... most of these in 5-6 chunks within minutes. I lost £80k+.

I then put a gambling block on my Lloyds account. I have since complained that these debit card payments should have been flagged earlier given the high volume and high amount of them and the fact they were to a dodgy looking overseas vendor. Indeed, on one day Lloyds actually stopped me from depositing any more as I hit a daily card limit, only for this to then reset the next day. Nothing to do with gambling just an auto block for the high volume of payments.

I never got a phone call from Lloyds or any "are you sure" messages on my app during or after. My wife helped me put a gambling block on my mobile app... but it sadly didn't stop me from doing bank transfers to gambling sites a few weeks later and I lost another £20k in October.

Considering Lloyds never flagged these high volume of debit card payments as a problem, despite hitting their daily limit and allowing me to continue when it reset the next day

Considering Lloyds never called or asked about my wellbeing after I put the stop on my app

Considering they then never flagged 4 dodgy £5k payments, done within minutes, to an overseas gambling merchant...

do I have any grounds to complain about how I have been let down as a customer?

Furthermore, do I have any kind of case to complain against Barclays for ditching me as a customer when I was clearly vulnerable with my addiction. Should Barclays have done more to tell Lloyds I was with gamstop / I had a gambling block on my account? Would Lloyds have been granted access to that information? Or is that onus completely on me.

I've been on and off reading this thread and I'm not being naive about my gambling problem. I am seeking therapy, my wife now has control of all my finances and I'm learning to cope with the new reality that I'm never getting any of my losses back.

However, it is still gnawing away at me that perhaps both Barclays and Lloyds have let me down here?

Any advice would be much welcome.

It’s none of my business but I am always intrigued by people who lose this kind of money. One question keeps going through my mind, over and over.

What the hell do you do for a living?

 

[Educated_ant]

I keep reading in various places about GDPR requests. Is that the same as an SAR request?

And what consequences / who do you even report to if unregulated, offshore operators ignore those requests?

 

[Webzcas]

GDPR only covers the EU and the UK FYI -

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Offshore operations outside the remits of the EU and UK would likely not comply with it.

GDPR (General Data Protection Regulation) and SAR (Subject Access Request) are related but different concepts in data protection law.

In simple terms, GDPR is the overall law, while a SAR is a specific mechanism within GDPR that allows individuals to request access to their personal data that an organisation holds about them.

 

[conker]

The biggest problem you have with going after offshore operators is that authorities in Europe have no straightforward ways of getting to them. The UKGC has struggled for as long as I can remember in bringing both offshore operators or the jurisdictions they license themselves in, to heel. They tend to stick their head in the sand and pretend they don't exist. The UK now has a very clear and obvious black market, created in part by regulation, KYC verification, Source of Wealth checks, and self-exclusion schemes.

It took the UKGC 2 years to send Google a takedown request for websites advertising 'casinos not on gamstop'. That means thousands and thousands of very vulnerable players were going to these sites before the UKGC finally got their act together. It's still going on by the way.

Other licensing authorities like those in The Netherlands and Australia have created blocked lists, meaning ISP's are forced to block offshore operators from the citizens of their respective countries. This can be very effective, but doesnt stop people jumping on VPN's. It effectively becomes a game of whack-a-mole.

IMHO you will not get very far going after these casinos, no matter how angry you feel. Lawyering up will also be a costly and potentially fruitless effort.

I am not going to make anymore suggestions on what you should do, as I have already been told that I am giving you false hope. However, I can tell you that going after these casinos is a dead end.

 

[justdoit]

Compulsive spending >> when a person feels an uncontrollable

 

[Educated_ant]

I realise it's a long shot but I'm trying to do all the research I can, if nothing else to make sure I've exhausted everything that's available to me.

So it turns out Donbet.com use a UK based bank account with Clearbank. I'm very surprised they would do such a thing given the unregulated nature of what they do. The payments go through as Falcora Finance.

 

[Guntis]

EducatedAnt, i wouldn't hope to get anything back, but you can try sending a formal complaint to Lloyds and if that doesn't work, then after 8 weeks, take it to the Financial Ombudsman Service. I think the complaint should be based on Lloyds' 'improper customer account protection.'

Just send something like the following to see how it goes. But before sending anything, check the bank's terms and fine-tune your message using precise and impactful language. Make sure there is no BS.

Example Letter:

I am writing to raise a formal complaint regarding Lloyds Bank's failure to implement adequate safeguards during a period of extreme high-risk transaction activity from my account.

My complaint focuses on three specific and serious failures by Lloyds Bank:

1. In September 2023, I made 27 debit card payments of £3,000 each to gambling merchants over just three days, totaling £81,000. While these transactions triggered Lloyds' daily limit, the bank simply reset this limit the following day without any investigation or customer contact, effectively enabling continued harmful behavior.
2. When I actively sought protection by implementing a gambling block on my app - explicitly signaling my vulnerability to gambling harm - Lloyds failed to:
   
   • Make any welfare contact
   • Implement additional transaction monitoring
   • Review the recent pattern of high-risk transactions
3. Most concerningly, after these clear warning signs, I was still able to make four rapid £5,000 transfers to an overseas gambling merchant within minutes. These obvious red-flag transactions proceeded without any security checks or intervention from Lloyds.

These failures demonstrate a fundamental breach in Lloyds' duty of care to protect vulnerable customers from financial harm. I request a full investigation into why your customer protection protocols failed at each of these critical points.

I expect your response within the mandated 8-week timeframe. If your response is unsatisfactory, I will consider escalating this complaint to the Financial Ombudsman Service.

---

Regarding UKGC, casino licensing, and legalities - i don't think they matter when it comes to actual payments. Here is an example of what Mastercard says:

Source:

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[dunover]

EducatedAnt, it wouldn't hope to get anything back, but you can try sending a formal complaint to Lloyds and if that doesn't work, then after 8 weeks, take it to the Financial Ombudsman Service. I think the complaint should be based on Lloyds' 'improper customer account protection.'

Just send something like the following to see how it goes. But before sending anything, check the bank's terms and fine-tune your message using precise and impactful language. Make sure there is no BS.

Example Letter:

I am writing to raise a formal complaint regarding Lloyds Bank's failure to implement adequate safeguards during a period of extreme high-risk transaction activity from my account.

My complaint focuses on three specific and serious failures by Lloyds Bank:

1. In September 2023, I made 27 debit card payments of £3,000 each to gambling merchants over just three days, totaling £81,000. While these transactions triggered Lloyds' daily limit, the bank simply reset this limit the following day without any investigation or customer contact, effectively enabling continued harmful behavior.
2. When I actively sought protection by implementing a gambling block on my app - explicitly signaling my vulnerability to gambling harm - Lloyds failed to:
   
   • Make any welfare contact
   • Implement additional transaction monitoring
   • Review the recent pattern of high-risk transactions
3. Most concerningly, after these clear warning signs, I was still able to make four rapid £5,000 transfers to an overseas gambling merchant within minutes. These obvious red-flag transactions proceeded without any security checks or intervention from Lloyds.

These failures demonstrate a fundamental breach in Lloyds' duty of care to protect vulnerable customers from financial harm. I request a full investigation into why your customer protection protocols failed at each of these critical points.

I expect your response within the mandated 8-week timeframe. If your response is unsatisfactory, I will consider escalating this complaint to the Financial Ombudsman Service.

---

Regarding UKGC, casino licensing, and legalities - i don't think they matter when it comes to actual payments. Here is an example of what Mastercard says:

View attachment 203116

Source:

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Good stuff.

I will say that the final bold paragraph regarding Mastercard is contestable. Legally. As it fails to acknowledge failures in the conduct of the supplier and the reasonable buyer expectation of their obligation to fulfil the complete process when it comes to gambling, which naturally includes regulatory edicts and paying winning accounts.

 

[Guntis]

Good stuff.

I will say that the final bold paragraph regarding Mastercard is contestable. Legally. As it fails to acknowledge failures in the conduct of the supplier and the reasonable buyer expectation of their obligation to fulfil the complete process when it comes to gambling, which naturally includes regulatory edicts and paying winning accounts.

Yeah, it should be very case and specifics-based. But from what I've seen in official PDFs like this - they typically refuse chargebacks. It's like Oh..we've got gambling chargeback again? Fak that...lol