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Guidance

LCCP Information requirements

Guidance for licence holders on the information requirements in the LCCP

Published
30 October 2020

Last updated
15 April 2024 - Changes

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  1. Contents
  2. 7 - Key events (legal or regulatory proceedings or reports)

7 - Key events (legal or regulatory proceedings or reports)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to legal or regulatory proceedings or reports.

It includes how to tell us:

  • if any application your company has made for a licence or other permission, to a gambling regulator in another jurisdiction, is granted, withdrawn or refused
  • if a professional, statutory, regulatory or government body (in any jurisdiction) is investigating your company’s activities, or the activities of a person in a key position, and the investigation could result in a sanction or penalty which could be expected to raise doubts about your company’s suitability to hold a licence from us
  • if your company, or any person in a key position in the company, is the subject of any criminal investigation by a law-enforcement agency in any jurisdiction, and this could give us cause to question if your measures to keep crime out of gambling have failed
  • if a third party (such as an auditor, a professional, statutory or other regulatory or government body, in any jurisdiction) refers any concerns they have about your company’s gambling facilities to your board or any person performing the role of an audit or risk committee
  • if your company starts disciplinary proceedings for gross misconduct against the holder of a personal licence, or a person in a qualifying position (even if that person resigns before any action is taken against them)
  • if any legal action or court proceedings are started against your company, or a company in your group, in any jurisdiction
  • if your company makes a suspicious activity report under section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 (opens in a new tab) or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (opens in a new tab), or one is made about its activities.

Key Event 9: Grants, withdrawals or refusals of licence applications to other gambling regulators

Licence condition 15.2.1 (9)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The grant, withdrawal or refusal of any application for a licence or other permission made by the licensee, or in the case of a licensee which is a body corporate, any group company of theirs, to a gambling regulator in another jurisdiction. In the case of a withdrawal or refusal of the application, the licensee must also notify the reasons for such withdrawal or refusal.

Your company must submit a key event report to us if any application it has made for a licence or other permission, to a gambling regulator in another jurisdiction, is granted, withdrawn or refused.

You must do this within five working days of you finding out about the event.

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. This requirement includes companies which are incorporated outside of the United Kingdom.

For a detailed explanation of the meaning of ‘subsidiary’ refer to the Companies Act 2006 (Section 1159) (opens in a new tab). For ‘body corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab).

You do not need to tell us about this event if it relates to applications for licences or other permissions to carry out activities which would fall outside the scope of a Gambling Commission operating licence if carried out in Great Britain, or with customers in Great Britain.

When reporting this key event, you should include the following information:

  • the name of the gambling regulator and the jurisdiction
  • if the licence or permission application was granted, tell us if this means your company will make changes to its Gambling Commission licence (for example, do you intend to surrender your licence with us)
  • if the licence or permission application was withdrawn, tell us the reasons for the withdrawal. You must include if the regulator had indicated to your company that it might refuse the application and the reasons for this
  • if the licence or permission application was refused, tell us the reasons for the refusal.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

  • Key Event: Licence/permission applications

This reporting requirement applies to holders of all operating licences.

Key Event 10: Investigations by professional, statutory, regulatory or government bodies

Licence condition 15.2.1 (10)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

Any investigation by a professional, statutory, regulatory or government body (in whatever jurisdiction) into the licensee’s activities, or the activities of a person in a ‘key position’, where such an investigation could result in the imposition of a sanction or penalty which could reasonably be expected to raise doubts about the licensee’s continued suitability to hold a Gambling Commission licence.

Your company must submit a key event report to us if a professional, statutory, regulatory or government body (in any jurisdiction) is investigating its activities, or the activities of a person in a key position, and the investigation could result in a sanction or penalty which could be expected to raise doubts about your company’s suitability to hold a licence from us.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

  • the name, address, and website of the investigating body
  • if known, provide the name, email address and phone number of the person carrying out the investigation
  • when the investigation started
  • the reasons for the investigation
  • when you expect the investigation to be completed
  • in the case of a person in a key position, the name, address and date of birth of the person and their role in your company.

A ‘key position’ is defined in LCCP Licence condition 15.2.1 (4) (Reporting key events - Relevant persons and positions).

You do not need to report to us investigations that are being conducted by us.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

  • Key Event: Investigation - suitability

This reporting requirement applies to holders of all operating licences.

Key Event 11: Criminal investigations by a law enforcement agency

Licence condition 15.2.1 (11)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

Any criminal investigation by a law enforcement agency in any jurisdiction in which the licensee, or a person in a ‘key position’ related to the licensee, is involved and where the Commission might have cause to question whether the licensee's measures to keep crime out of gambling had failed.

Your company must submit a key event report to us if it, or any person in a key position in the company, is the subject of any criminal investigation by a law-enforcement agency in any jurisdiction, and this could give us cause to question if your measures to keep crime out of gambling have failed.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

  • the name, address, and website of the investigating body
  • if known, provide the name, email address and phone number of the person carrying out the criminal investigation
  • when the criminal investigation started
  • the reasons for the criminal investigation
  • when you expect the criminal investigation to be completed
  • in the case of a person in a key position, the name, address and date of birth of the person and their role in your company.

A ‘key position’ is defined in LCCP Licence condition 15.2.1 (4) (Reporting key events - Relevant persons and positions.

You only need to report criminal investigations that could give us cause to question if your measures to keep crime out of gambling have failed.

If the criminal investigation is abroad (or in another jurisdiction within the United Kingdom), you must still report it to us if your business provides gambling facilities there.

You do not need to report to us criminal investigations that are being conducted by us.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Criminal investigations

This reporting requirement applies to holders of all operating licences.

Key Event 12: Referral to Boards (or audit and risk committees) of material concerns raised by a third party

Licence condition 15.2.1 (12)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The referral to the licensee’s Board, or persons performing the function of an audit or risk committee, of material concerns raised by a third party (such as an auditor, a professional, statutory or other regulatory or government body, in whatever jurisdiction) about the provision of facilities for gambling: a summary of the nature of the concerns must be provided.

You must submit a key event report to us if a third party (such as an auditor, a professional, statutory or other regulatory or government body, in any jurisdiction) refers any concerns they have about your company’s gambling facilities to your board or any person performing the role of an audit or risk committee.

You must do this within five working days of you finding out about the event.

Material concerns include those which relate to your company’s ability to comply with the Gambling Act 2005 (opens in a new tab) or the LCCP. They also include more general concerns relating to the provision of facilities for gambling (such as suitability to hold a licence, consistency of actions relative with the licensing objectives, and risk about products, facilities, or operating environments for gambling) in any jurisdiction.

If you are unsure if a report identifies a matter of material concern, contact us to discuss the matter.

When reporting this key event, you should include the following information:

  • the name of the auditor, a professional, statutory or other regulatory or government body
  • the date of the completion of the audit and or reporting of findings
  • a summary of the relevant findings
  • the date when these were reported to your board, or audit and risk committee
  • any actions taken by your company in response to the report.

It is often useful if you upload a copy of the relevant report, or a summary of the report’s findings.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

  • Key Event: Referral to Board/audit/risk

This reporting requirement applies to holders of all operating licences.

Key Event 13: Disciplinary sanctions against personal licence or qualifying position holders for gross misconduct

Licence condition 15.2.1 (13)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The imposition by the licensee of a disciplinary sanction, including dismissal, against the holder of a personal licence or a person occupying a qualifying position for gross misconduct; or the resignation of a personal licence holder or person occupying a qualifying position following commencement of disciplinary proceedings in respect of gross misconduct against that person.

Your company must submit a key event report to us if it starts disciplinary proceedings for gross misconduct against the holder of a personal licence, or a person in a qualifying position, even if that person resigns before any action is taken against them.

You must do this within five working days of you finding out about the event.

There are two types of personal licence holders. These are a personal management licence and a personal functional licence (for people involved in gaming or handling money in a casino).

A ‘qualifying position’ is defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 (opens in a new tab) and applies to small-scale operators.

Gross misconduct can results from actions such as theft, physical violence, gross negligence, or serious insubordination.

When reporting this key event, you should include the following information:

  • the name, address and date of birth of the person and their role in your company
  • the disciplinary sanction awarded
  • a summary of the reasons for the gross misconduct
  • in the case of people who resign after the start of a disciplinary proceedings for gross misconduct, the date of their resignation
  • any actions taken by your company in response to the gross misconduct (including the removal, dismissal or disqualification of the person from a key position).

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

  • Key Event: Disciplinary gross misconduct

This reporting requirement applies to holders of all operating licences.

Note, if any person leaves key position, or leaves a key position to take up another, or you must submit another key event telling us about this change. Refer to the guidance notes for LCCP Licence condition 15.2.1 (4) for further information.

If a personal licence holder receives a disciplinary sanction for gross misconduct, they must also tell us this themselves, by submitting a personal licence event report.

Key Event 14: Legal action or court proceedings

Licence condition 15.2.1 (14)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The commencement (in whatever jurisdiction) of any material litigation against the licensee or, where the licensee is a body corporate, a group company: the licensee must also notify the outcome of such litigation.

Your company must submit a key event report to us if any legal action or court proceedings are started against it, or a company in your group, in any jurisdiction.

You must do this within five working days of you finding out about the event.

‘Material’ litigation is any significant litigation and any litigation which:

  • might bring into question your company’s suitability to hold a licence with us
  • might have a detrimental impact on your customers or the operation of your business
  • might affect your company’s ability to carry out its activities.

For a detailed explanation of ‘body corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab). A group company includes any subsidiary or holding company and any subsidiary of such holding company. This requirement includes companies which are incorporated outside of the United Kingdom.

When reporting this key event, you should include the following information:

  • the name, address and country of the party taking legal action
  • the date legal action started
  • the reasons for the legal action
  • when you expect the legal action to be settled.

When the legal action is settled, you must also tell us the outcome of the proceedings. This means that you will submit two key events, one at the start of the legal proceedings and one at the end, when the outcome is known.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

  • Key Event: Material litigation

This reporting requirement applies to holders of all operating licences.

Key Event 15: Suspicious activity reports

Licence condition 15.2.1 (15)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The making of a disclosure pursuant to section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (a suspicious activity report): the licensee should inform the Commission of the unique reference number issued by the United Kingdom Financial Intelligence Unit of the National Crime Agency in respect of each disclosure and for the purposes of this key event the five working day period referred to above runs from the licensee’s receipt of the unique reference number. The licensee should also indicate whether the customer relationship has been discontinued at the time of the submission.

Your company must submit a key event report to us if it makes a suspicious activity report under section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 (opens in a new tab) or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (opens in a new tab), or one is made about its activities.

Suspicious activity reports (SARs) alert law enforcement to potential instances of money laundering or terrorist financing. SARs are a vital source of intelligence not only on economic crime but on a wide range of criminal activity. They provide information and intelligence from the private sector that would otherwise not be visible to law enforcement.

SARs are submitted to the United Kingdom Financial Intelligence Unit (UKFIU) (opens in a new tab) which is part of the National Crime Agency. The easiest way to submit a SAR is with the secure SAR Online system (opens in a new tab). Separate guidance on SARs (opens in a new tab) is available on the UKFIU website.

After submitting a SAR, the UKFIU will send you a unique reference number (URN) for the disclosure you have reported. You must submit this key event to us within five working days of you receiving the URN for the disclosure.

When reporting this key event, you should only provide the following information:

  • the URN for the disclosure
  • in some circumstances, your company will be required to end the relationship with a customer that is the subject of the disclosure or will decide to end the relationship even if not required to do so. In those cases, you should advise us if the customer relationship has been discontinued when submitting this key event.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

  • Key Event: Suspicious activity report SAR

This reporting requirement applies to holders of all operating licences.

SARs and key events are not crime or fraud reports. If you need to report a crime or a fraud you should contact either your local police service on 101 or Action Fraud (opens in a new tab) on 0300 123 2040.

Known or suspected offences relating to gambling must also be reported to us. Refer to guidance for LCCP Licence condition 15.1 (reporting suspicion of offences) for further information.

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