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  3. Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

Consultation response

Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.

Published
1 May 2024

Last updated
13 June 2024 - Changes

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Contents

Application handling

For Managing Directors, CEOs or the equivalent

The Personal Management Licence (PML) provision consulted on is an existing requirement and the Gambling Commission is clarifying what roles the condition captures. For example, we consider that a licensee’s Managing Director, CEO or equivalent is already captured and required to hold a PML due to the ‘specified management offices’ in Licence Condition 1.2.1 (2)(a). Following consultation, we have made this requirement more explicit. As such, the Commission will be accepting PML applications for these roles with immediate effect.

Individuals responsible for anti-money laundering and counter terrorist financing roles

This may include a member of the board of directors (or if there is no board, its equivalent management body) or to a senior manager undertaking this position. We consider these should already be captured under the definition of ‘management office’, because the person is taking or sharing responsibility for ‘facilitating or ensuring compliance with terms or conditions of the operating licence’ under section 80(5) of the Gambling Act 2005.

In consulting on this proposal, we also made it clear that the requirements will include money laundering reporting officers (MLRO) and nominated officers (NO) as ones where the individual must hold a PML.

In recognising that we are enhancing the requirements for MLROs, and NOs as detailed in ‘The prevention of money laundering and combating the financing of terrorism for remote and non-remote casinos: Fifth edition (Revision 3)’ and extending to all other relevant sectors, we will commence accepting applications for these roles from 1 June 2024 onwards. This will allow for upgrades to the Commission’s systems for the processing of these applications and allow licensees sufficient time to identify the appropriate individuals who must apply for a licence.

The person with responsibility for chairing the Board of an organisation (where the licensee has such a body) and the person is appointed for a fixed term of office or indeterminate term of office

We consider this role should already be captured under the definition of ‘management office’. Nonetheless, we have consulted to make it clear that a person responsible for chairing the Board of an organisation (where the licensee has such a body) who has been appointed for a fixed or indeterminate term of office (not on a transient and/or short-term basis for individual meetings), will be required to hold a PML.

In implementing this specific requirement, we are allowing a longer period for operators to identify these relevant individuals and will therefore be accepting applications from 1 August 2024.

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