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Blue Star Planet Limited Regulatory Settlement

This regulatory settlement consists of:

  • £620,000 payment in lieu of a financial penalty, which will be directed towards socially responsible causes.
  • agreement to the publication of a statement of facts in relation to this case.
  • payment of £3,571.25 towards the Commission’s costs of investigating the case.

In considering an appropriate resolution to this investigation, the Commission has had regard to the following aggravating and mitigating factors:

Aggravating factors

  • the serious nature of the breaches identified
  • the impact on the licensing objectives
  • the breach arose in circumstances that were similar to previous cases the Commission has dealt with which resulted in the publication of lessons to be learned for the wider industry
  • the need to encourage compliance among other operators
  • the nature of the breaches may mean other customers were affected that the Commission has not reviewed
  • Blue Star Planet Limited’s senior management should have been aware of governance issues that lead to the breaches.

Mitigating factors

  • the extent of steps taken to remedy the breach
  • Blue Star Planet Limited’s early recognition of its failings
  • the Licensee has been co-operative throughout its dealings with the Commission.

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

  • do you have formal processes in place to measure the effectiveness of your AML and safer gambling policies and are findings adequately recorded?
  • do you efficiently record all compliance-related decisions and are you able to demonstrate to the Commission, on request, evidence of ongoing assessment, evaluation and improvement?
  • do lessons learned from public statements flow into your policy and processes?
  • are your customer risk profiles formed by or linked to your money laundering and terrorist financing risk assessment?
  • do you have a formalised process for analysing the effectiveness of customer interactions to ensure that reviews were adequately documented and consistent in their approach?
  • do you log the types of behaviour which have triggered a customer interaction and keep sufficient records of interactions, along with decisions not to interact especially in terms of the level of detail provided?
  • do you have out of hours arrangements in place?
  • have your staff received sufficient AML and SR training?

Notes

1 The Commission commenced its section 116 review on 7 September 2021.

2 Although the Licensee accepts the breach, it remains of the view that an isolated incident of a single broken website link should not warrant a finding that it breached licence condition 8.1.1.

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Blue Star Planet Limited Findings

Last updated: 16 February 2023

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