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Skill On Net Limited Regulatory Settlement

This regulatory settlement consists of:

  • £305,150 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 £9,079.00 towards the Commission’s costs of investigating the case
  • agreement to conduct an independent third-party audit as regards the effective implementation of the Licensee's AML and safer gambling policies, procedures and controls within 12 months of the conclusion of the Licence Review.

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

Aggravating factors:

  • the nature of the breaches may mean other customers were affected that the Commission has not reviewed
  • 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 Licensee was subjected to three compliance assessments which all identified failings resulting in a prolonged period of non-compliance
  • officials still identified failings following two periods of special measures.

Mitigating factors:

  • the Licensee has now taken steps to rectify the breaches highlighted
  • the Licensee has accepted the key failings
  • the Licensee has acted in a timely manner and been co-operative with the investigation.

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 lessons learned from public statements flow into your policy and processes?
  • does your ML and TF risk assessment meet all the requirements?
  • are your customer risk profiles formed by or linked to your ML and TF risk assessment?
  • do you have sufficient processes and systems in place to identify and interact with customers displaying markers of harm?

Notes

1 This varies for each licence condition and the dates for each one is detailed under the relevant sections

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Skill On Net Limited Findings

Last updated: 23 May 2023

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