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What you need to send us with your application

Make sure you read the guidance notes for the information you must send in with the application. If any information is missing, it will delay the application.

Source of funds evidence

Source of funds evidence is usually required for the funds used to acquire the controlling interest and any intended ongoing investment in the Licensee. This is a general overview of when and what source of funds evidence is required but we assess each application on a case-by-case basis according to risk so the type and level of evidence may differ between applications.

We consider there are three main categories of funding:

  • from unregulated entities or individuals
  • from regulated banks or investment companies
  • from regulated banks or investment companies acting as an intermediary for an investor or pool of investors.

Regulated means by the Financial Conduct Authority (FCA) in the United Kingdom (UK) and FCA equivalent in other jurisdictions, for example the United States equivalent would be the Securities and Exchange Commission (SEC). 

We would not normally require source of funds evidence in relation to the origin of monies when an operator takes out a loan from a UK regulated bank, but if an investor borrows from a UK regulated bank to invest in an operator, we will normally undertake source of funds checks on the period when the monies were in the investor’s control. If any bank is buying shares in the operator, we will undertake source of funds checks on the bank, as explained on this page.

Funding from unregulated individuals

These are typically private investors who are investing their own money. We require source of funds evidence if the individual has provided £50,000 (or equivalent in foreign currency) or more of the funding for the acquisition or ongoing investment. Evidence of the individual’s source of funds will depend on what the source of funds is but examples include bank statements, investment portfolio statements and P60s.

Funding from unregulated entities

These investors are typically entities using their own money to fund the investment. For these investors we need to know when they were created or incorporated, what jurisdiction they are registered in, and we require source of funds evidence if they have been:

  • created or incorporated for more than 12 months at the date of investment and invest £1,000,000 (or equivalent in foreign currency) or more
  • created or incorporated for less than 12 months at the date of investment and invested any amount.

Typically for established entities the latest set of filed financial statements can be sufficient evidence. For recently established entities, evidence of how the entity has been funded is required.

Funding from regulated banks or investment companies

These investors are regulated banks or entities investing their own money. When we consider what type of source of funds evidence is required, we group these investors into two categories – FCA regulated and overseas equivalent regulated.

For FCA regulated entities, we require its FCA reference number along with source of funds evidence if it is investing 10 percent or more of the total investment amount (that is, 10 percent of the total borrowed or 10 percent of the monies raised via the issue of new shares). Typically, these investors are established entities and the latest set of filed financial statements can be sufficient evidence.

For overseas equivalent regulated entities, we require its reference number with the regulator. If it is investing 5 percent or more of the total investment amount, we also require source of funds evidence. Typically, these investors are established entities and the latest set of filed financial statements can be sufficient evidence.

Funding from regulated banks or investment companies acting as an intermediary

These investors are regulated banks or entities acting as an intermediary for an investor or pool of investors (that is, the entity is not investing its own money). When we consider source of funds evidence, we group these investors into two categories – FCA regulated and overseas equivalent regulated.

For FCA regulated entities, we require its FCA reference number and, if it is investing 10 percent or more of the total investment amount, we require a schedule of the underlying investors.

For the underlying investors, we require source of funds evidence for:

  1. individual private investors investing £50,000 (or equivalent in foreign currency) or more
  2. non-regulated entities created or incorporated for more than 12 months at the date of investment and investing £1,000,000 (or equivalent in foreign currency) or more
  3. non-regulated entities created or incorporated for less than 12 months at the date of investment and investing any amount
  4. regulated entities investing 5 percent or more of the overall total investment amount.

For overseas equivalent regulated entities, we require its reference number with the regulator and, if it is investing 5 percent or more of the total investment amount, we require a schedule of the underlying investors.

For the underlying investors, we require source of funds evidence for:

  1. individual private investors investing £50,000 (or equivalent in foreign currency) or more
  2. non-regulated entities created or incorporated for more than 12 months at the date of investment and investing £1,000,000 (or equivalent in foreign currency) or more
  3. non-regulated entities created or incorporated for less than 12 months at the date of investment and investing any amount
  4. regulated entities investing 5 percent or more of the overall total investment amount.

Trusts

The Gambling Commission’s application disclosure requirements for Trusts are the same as those for other entity types and/or individuals that are part of a licensee’s ownership structure.

However, it is important to note that whilst the disclosure requirements set out below are general principles of the information required to support an application, the Commission retains the right to request further information or documents when this is required.

Where the Trust’s ownership equates to 3 percent or above interest in the licensee, in your application, you must include:

  1. a copy of the trust deed
  2. a copy of the letter of wishes
  3. a copy of the letter of consent from the trustees (for example, that they have consented to act as trustees)
    4. .

Trust beneficiaries

We require an Annex A from those beneficiaries whose interest in the Trust equates to a 10 percent or more controlling interest in the applicant and/or licensee or a parent undertaking of the licensee. The Annex A must be submitted online through our Apply for a personal licence service. If any beneficiary is under 18, then we do not require an Annex A from them.

If the beneficiary’s interest in the Trust equates to less than 10 percent but 3 percent or more, then we require the name, address, and date of birth of all beneficiaries which should be shown in the trust deed – if not, you must provide this information.

Trustees

We require an Annex A from all Trustees where the Trust’s interest in the applicant and/or licensee equates to a 10 percent or more controlling interest in the applicant and/or licensee (or a parent undertaking thereof). The Annex A must be submitted online through our Apply for a personal licence service.

In the case of the Trustee being a company, we require an Annex A from the person or people in that company who have lead responsibility for matters relating to the Trust.

If the Trust’s interest in the licensee equates to less than 10 percent but 3 percent or more, we require the name, address and date of birth of all Trustees which should be shown in the trust deed – if not, you must provide this information.

Settlor

We will not usually require an Annex A from the Settlor. We require the name, address and date of birth of the Settlor which should be shown in the trust deed – if not, you must provide this information.

Protector

We will not usually require an Annex A from the Protector. We require the name, address and date of birth of the Protector which should be shown in the trust deed – if not, you must provide this information.

Estates

If the license holder has passed away, please let us know. The death of someone is always a difficult time and we aim to make any changes to a licence as simple as possible, and a copy of the death certificate is not needed.

If the bereavement results in a change of corporate control, for example shares are redistributed within a family or with shareholders, or probate is involved and the estate is complex, please let us know as soon as possible so we can work with you to ensure any changes to the licence are dealt with as soon as we can.

Applications in advance

Section 103 of the Gambling Act 2005 (opens in a new tab) provides for this. An application can be made in respect of a person or entity who is expected to become a controller of a company.

Information needed

Ownership structure diagrams

This must show all individuals and companies that have an interest of over 3 percent in the Licensee.

If the Licensee has become part of a group because of the Change of Corporate Control a group structure will need to be provided showing all entities in the group and identifying all parent undertakings of the licensee.

Management structure diagram

If the management structure has changed because of the new controller.

Evidence to show the Licensee is controlled by the new controller

We require a copy of the share purchase agreement and documentation confirming the shares and/or voting power has transferred to the new controller, this may be in the form of share certificates or share register.

Limited companies

The following are needed for changing limited companies:

  1. articles of association for new controllers
  2. certificate of incorporation for all new controllers
  3. memorandum of association for new controllers.

Trust documents for new controllers

These are needed only where a trust is involved in the ownership of the Licensee as a result of the change of control and the trust has more than 3 percent interest in the Licensee.

We require a copy of the following:

  1. trust deed
  2. letter of wishes if applicable
  3. copy of letter of consent from trustees if applicable
    4. .

LCCP policies and procedures

This is needed if there are new or amended policies because of the change of corporate control.

Copies of gambling licences

This is needed if the new controller is licensed elsewhere.

Business plan

This is needed if changed because of the change of corporate control.

Source of funding evidence

This is needed alongside clear explanation. This can be in the form of but not limited to bank statements, audited accounts.

Purchase price evidence

Evidence from the buyer to the seller is required, alongside a clear explanation.

Profit and loss projections

This is needed if the ongoing funding of the business is changing we will need profit and loss projections for the next 12 months.

Online Personal Management Licence applications

If there is a change to the management structure because of the change of corporate control, Online Personal Management Licence applications and required supporting documents from each person responsible for a management office or Online Annex A Personal Declaration if the new controller is a Small-Scale Operator.

Online Annex A personal declarations

Online Annex A Personal Declarations from all new individuals who have more than 10 percent control of the Licensee because of the change of corporate control and if a Trust is involved in the new controller's ownership structure Online Annex A Personal Declarations from:

  1. all trustees
  2. all beneficiaries aged 18 years and over through their holding in a trust have more than 10 percent control of the Licensee.

    3. If the trustee is a company an Annex A Personal Declaration will be required from the person in the company who has lead responsibility for matter relating to the trust.

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    Last updated: 7 March 2024

    Show updates to this content

    Formatting changes, source of funds detail added

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