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Mr Green Limited Regulatory Settlement

This regulatory settlement consists of:

  • a total payment of £3,750,000 in lieu of a financial penalty, which will be directed towards socially responsible purposes, which includes a divestment of £218,310.20
  • agreement to the publication of a statement of facts in relation to this case
  • agreement by the Licensee to vary its operating licence to add conditions to its operating licence, namely:
    • to appoint a Board-level sponsor, either reporting directly to the Chair or the Executive Chair, to assume responsibility for compiling and progressing a 12-month action plan to deal with post case activity, and
    • undertake a follow-up independent audit of relevant policies and procedures by 13 February 2024 to ensure whether it is effectively implementing its AML and safer gambling policies, procedures and controls, and that any further recommendations made by the independent audit should be implemented thereafter
  • payment of the Commission’s costs of conducting the review.

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
  • there has been a repeated breach or failure by the operator or other group companies
  • 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 nature of the breaches may mean other customers were affected that the Commission has not reviewed
  • the Licensee’s senior management should have been aware of governance issues that lead to the breaches, given their significance.

Mitigating factors

  • the extent of steps taken to remedy the breach - the Licensee implemented an early action plan to remedy its failings
  • the Licensee procedurally met the Commission’s timetable in respect of providing material and, where such material could not be provided within the expected time period, sought an extension.

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 procedures, and are findings adequately recorded?
  • do you efficiently record all compliance 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 informed 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 the level of detail provided?
  • have your staff received sufficient AML and social responsibility training?

Notes

1 The Commission commenced its regulatory review on 30 September 2021

2 Mr Green Limited trade under: Mr Green

3 There are some variances of starting date for breach, but they all fall within this common period. Specific variations from this date, include breach of paragraph 1 of Licence condition 12.1.1 which occurred between 20 September 2020 and 22 October 2021; Failing to comply with paragraphs 1 and 2 of SRCP 3.4.1 between 4 December 2020 and 18 October 2021; Paragraphs 1 and 2 of SRCP 3.9.1 between 4 December 2020 and 18 October 2021.

4 The AML Guidance and the Commission’s ML/TF risk assessment sets out a number of factors licensees must and should consider when undertaking their own ML/TF risk assessments. In addition, the Licensee is required, by virtue of Regulation 18(2)(a) of the Regulations, to take these documents into account when carrying out its own ML/TF risk assessment.

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Mr Green Limited Findings

Last updated: 28 March 2023

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