Executive summary
This case concerns BGO Entertainment Limited (BGO) which holds a combined operating licence authorising it to operate as a remote operator and includes casino.
The Commission conducted a compliance assessment in September 2018, in which a number of customer accounts were examined. Failures were identified concerning the manner that BGO interacted with the customers from a social responsibility (SR) and anti-money laundering (AML) perspective.
Our investigation subsequently uncovered systemic failings in respect of both BGO’s SR and AML controls which affected a significant number of customers across its online casinos. These failings stemmed from inadequate Risk Assessments relating to AML together with inadequate AML and SR policies and controls.
On 4 September 2019 the Gambling Commission gave BGO notice that we were commencing a review of its operating licence.
BGO cooperated with the Commission throughout the compliance assessment and the subsequent investigation and acknowledged that between 25 September 2018
and 21 July 2020 it did not have effective and adequately resourced AML controls in place to consistently address risks presented by higher risk customers.
The settlement agreement consists of additional licence conditions which have been imposed and agreed by the Licensee to protect consumers they consist of:
(i) Licensee shall apply enhanced due diligence measures (EDD) to the top 250 customers within its customer profiling system where it is required to do so in accordance with both the Money Laundering Regulations 2017 and the Gambling Commission’s published guidance concerning AML. This will consist of the top 125 customers by drop (deposits) and the top 125 customers by loss, in each case based on customers who have placed a bet in the previous 12 months, irrespective of whether such customer’s account is, at the relevant time, active, frozen / closed or self-excluded. The top customers shall be determined by their drop (deposit) and loss in the previous 12-month period. This EDD is to be conducted within three months of the publication of the public statement and conducted thereafter every 12 months as required. The findings of each review should be presented to the Board of Licensee and acted upon. Records are to be maintained and presented to the Gambling Commission when required.
(ii) Licensee shall maintain a record of the effectiveness of the Responsible Gambling checks that it undertakes on the top 250 customers within its customer profiling system. This will consist of the top 125 customers by drop (deposits) and the top 125 customers by loss, in each case based on customers who have placed a bet in the previous 12 months, irrespective of whether such customer’s account is, at the relevant time, active, frozen / closed or self-excluded. The top customers shall be determined by their drop (deposit) and loss in the previous 12-month period. The Responsible Gambling checks should be conducted in line with the Gambling Commission’s published guidance. This review is to be conducted within three months of the publication of the public statement and conducted thereafter every 12 months as required. The findings of each review should be presented to the Board of Licensee and acted upon. Records are to be maintained and presented to the Gambling Commission when required.
In addition, the Licensee will make a payment of £2,000,000 in lieu of a financial penalty to address failings identified by the Commission. The Licensee will also pay Commission costs of £31,023.87p
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BGO Entertainment Limited Findings
Last updated: 2 March 2021
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