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Hillside (UK Gaming) ENC Regulatory Settlement

This regulatory settlement consists of:

  • a payment of £343,035 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 £15,684.50 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

  • there has been a repeated breach or failure by the operator
  • 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 breach continued after the licensee became aware of it
  • the scale of the breach of a licence condition across the licensed entity
  • the impact on customers and the public
  • the absence of internal controls or procedures intended to prevent the breach.
  • the duration of the breach.

Mitigating factors

  • the extent of steps taken to remedy the breach
  • timely co-operation with any investigation undertaken by 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 anti-money laundering 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 policies and procedures?
  • do you undertake financial sanctions checks on new customers prior to their first deposits?
  • are your customer risk profiles informed by or linked to your ML and TF 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?
  • have your staff received sufficient anti-money laundering and social responsibility training?
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Hillside (UK Gaming) ENC Findings

Last updated: 4 April 2024

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