UK regulated books are a joke. The regulators side with the books always, no matter how wrong they are.
It is not the case that all books wait until wd are requested in order to some some know your customer procedures. BetFair, SBO, Bet365, SIA, all will ask for documents or require a verified deposit method some time before wd have been requested.
Heritage's business model has always been to only take bets from selected customers (losers). They want to know exactly who is playing there. They do not want open enrollment to the whole world so people (say me) can find some off lines at 3am, open a new account, deposit 20k via neteller and go to work. They carefully select their players from the usa only. Limited deposit methods allow them to see the money coming in.
When you take 53 western union deposits from the same person playing an abnormal number of hands per day of job someone should notice long before 53, especially if you are not planning on paying the winnings.
Using the shitty UK books as a comparison sucks as they operate in a different environment. They should be compared to other US facing (illegally operating) books. Pinny, greek, cris would all pay in this case.