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Good practice

We consider this case provides valuable learning for operators. They should consider the following questions:

  • Do you have policies and procedures in place to identify customers who may be experiencing or at risk of developing problems with their gambling?
  • Do you have systems in place to identify potential problem gamblers?
  • Do these include appropriate trigger points for when the usual pattern of gambling becomes unusual (these should not be just financial)? How do you protect new customers (where a pattern of play cannot yet be established)?
  • Are your staff sufficiently trained to spot problem gamblers and know how to report concerns? Are there clear procedures once a concern has been raised?
  • Do you know your customer (KYC)? Are you gaining a holistic picture of the customer’s source of funds, particularly in relation to VIP customers?
  • Are you critically assessing assurances you receive as to source of funds?
  • Have you ensured you have clear, up-to-date, and fit for purpose Responsible Gambling Policy which takes into account the Commission’s guidance and includes a customer’s affordability?
  • Have you ensured you have clear, up-to-date, and fit for purpose AML policies and procedures available to all who require guidance?
  • Have you ensured your policies and procedures have been informed by our guidance on AML?
  • Have you taken into account the Commission’s Money Laundering and terrorist financing risk assessment?

For further guidance on good practice read our Enforcement report (opens in new tab)

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BGO Entertainment Limited Regulatory Settlement

Last updated: 3 March 2021

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