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  1. Licensees and businesses
  2. AML
  3. Notices
  4. Scheduled LCCP update: new PML requirements in force 29 November 2024
Changes to LCCP

Scheduled LCCP update: new PML requirements in force 29 November 2024

29 November 2024

On the 24 May 2024, the Gambling Commission (the Commission) published an AML notice to inform licensees of changes to the requirements to hold a personal management licence (PML) coming into force on the 29 November 2024. These requirements have now come into effect.

The changes were part of the Commission’s Summer 2023 consultations (opens in new tab), and we proposed changes to Licence Condition 1.2.1 of the Licence Conditions and Codes of Practice (LCCP) to clarify and increase personal management licence (PML) coverage.

We:

  • reiterated the requirement for the person with responsibility for the overall management and direction of the licensee’s business or affairs to hold a PML by adding wording to state that this is likely to be a CEO, Managing Director or equivalent
  • proposed that, for organisations with a Board, the person responsible for chairing the Board holds a PML (where the licensee has such a body)
  • proposed that the person responsible for the licensee’s anti-money laundering and counter-terrorist financing function as head of that function holds a PML
  • proposed that the person responsible for the submission of reports of known or suspected money laundering or terrorist financing activity under the Proceeds of Crime Act 2002 and Terrorism Act 2000 holds a PML.

From 29 November 2024, these persons will be required to hold a PML (except for small scale operators).

Specifically, in relation to anti-money laundering (AML) and counter-terrorist financing (CTF) roles, with effect from 29 November 2024, individuals holding the following management office positions within gambling businesses (except small scale operators) will be required to hold a PML.

For holders of casino licences:

  • the person responsible for compliance with the relevant Regulations (and appointed in accordance with those regulations). Where appropriate, with regard to the size and nature of the business, this individual is a member of the casino’s board of directors (or equivalent management body if there is no board) or of its senior management as the officer responsible for the operator's compliance with the Regulations
  • the person responsible for submission of reports of known or suspected money laundering or terrorist financing activity under the relevant legislation (and appointed in accordance with the relevant Regulations). This is the casino's nominated officer.

For holders of licences other than casino licences, where an individual has been appointed to submit reports of known or suspected money laundering or terrorist financing activity under the relevant legislation, that individual.

‘The relevant Regulations’ in these requirements refers to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on Payer) Regulations 2017 (‘the Regulations’) (opens new tab) or any UK Statutory Instrument by which those Regulations are amended or superseded.

‘The relevant legislation’ refers to the Proceeds of Crime Act 2002 and the Terrorism Act 2000.

The following publications will be updated in due course to reflect the changes to the AML and CTF roles:

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