William Hill Organization Limited Findings
The investigation found:
- failings in the Licensee’s implementation of Anti-Money Laundering (AML) policies, procedures and controls
- deficiencies in its responsible gambling policies, procedures, controls and practices, including weaknesses in implementation
- weaknesses in its reporting arrangements.
We found that, between January 2020 and 18 October 2021, the Licensee had been in:
Breach of paragraph 1 of licence condition 12.1.1
Breach of paragraph 1 of licence condition 12.1.1, which states: “Licensees must conduct an assessment of the risks of their business being used for money laundering and terrorist financing. Such risk assessment must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic or any other material changes, and in any event reviewed at least annually.”
The Licensee accepted it breached this licence condition as its ML/TF risk assessment did not sufficiently reflect the Commission’s expectations or fully take into account the Commission’s ML/TF risk assessment of the British gambling industry.
The failings were that the Licensee’s risk assessment did not:
- make explicit reference to specific risks in relation to TF.
- make specific reference to risks associated with customer bank account changes, risks of fraudulent or dyed notes or business risks in the geographical risk section3
- mention how the Licensee monitors customers who place bets in multiple betting offices, how this was reviewed and the mitigations in place.
Breach of paragraphs 2 and 3 of licence condition 12.1.1
Licence condition 12.1.1 (2) states: “Following completion of and having regard to the risk assessment, and any review of the assessment, licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing.”
Licence condition 12.1.1(3) states “Licensees must ensure that such policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time.”
The Licensee accepted:
- weaknesses and shortcomings in relation to the adequacy and maintenance of its policies and procedures, and their implementation
- certain customers identified by the Commission were able to stake large amounts of money without being monitored or scrutinised to the standard expected by the Commission:
- a customer profile was compiled for Customer A after the customer had gambled £34,000 and lost £16,000 between 20 May and 1 June, 2021. Despite staking a £19,000 in a single bet no Source of Funds (SoF) evidence was requested
- customer B staked £39,324 and lost £20,360.67 between 16 and 28 October 2020. No documentation was obtained by the Licensee which would support levels of gambling spend to mitigate the ML risk of high spend taking place over a short period of time
- customer C staked a total of £276,942 with a total loss of £24,395 between 17 August and 16 October 2020. SoF evidence was requested on 12 October 2020, however, to date no evidence has been seen by the Licensee
- the Licensee acknowledged that AML thresholds have since been revised and has confirmed that it has since amended its bet acceptance process
- in relation to certain customers identified by the Commission, it placed over-reliance on recycled winnings
- in particular cases, the Licensee failed to appropriately track customers across multiple Licensed Betting Offices (LBOs). The Commission found instances where the Licensee could have more effectively tracked customers across its LBO estate using information available to it. The Commission recognises the challenges of tracking customers using multiple premises in the non-remote Licensed betting offices.
The Commission’s review of the specific customers identified during the compliance assessment found no evidence of criminal spend with the Licensee.
Failure to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)
Compliance with a SRCP is a condition of the licence by virtue of section 82(1) of the Act. SRCP 3.4.1 (amended from 31 October 2019) states:
“1 Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:
- a. identifying customers who may be at risk of or experiencing harms associated with gambling
- b. interacting with customers who may be at risk of or experiencing harms associated with gambling
- c. understanding the impact of the interaction on the customer, and the effectiveness of the Licensee’s actions and approach.
2 Licensees must take into account the Commission’s guidance on customer interaction.”
The Licensee accepted it was not fully in compliance with SRCP 3.4.1 as:
- with certain customers, the Licensee did not identify changes in the customer behaviour which should have provoked consideration of whether the customer was experiencing harm:
- a safer gambling interaction was conducted with Customer D only after he had placed and had accepted an £18,000 bet - no interaction took place when accepting his bet as the Commission would have expected
- Customer A usually places small stakes but then placed a £19,000 bet. Although a safer gambling interaction was conducted during which he stated he was ‘fine with his spend’, the Licensee failed to proactively further consider him from a responsible gambling prospective
- it had insufficient controls in place to protect new customers, and to effectively consider high velocity spend and duration of play until the customer may have been exposed to the risk of substantial losses in a short period of time:
- after its retail premise had been re-opened following the Covid pandemic lockdown, the Licensee allowed Customer F to lose £10,600 in two days without a safer gambling interaction.
- despite being unknown and staking £42,253 in 130 bets over a three-day period, staff did not identify Customer G as being at risk of experiencing harms associated with gambling or undertake any customer interactions
- in particular cases, the Licensee did not conduct interactions with customers who may be at risk of experiencing harm early enough in the customer journey
- there was a lack of evidence of evaluation of the effectiveness of individual customer interactions and a lack of record keeping limited staff in properly tailoring their interactions with historic interactions in mind.
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William Hill Organization Regulatory Settlement
Last updated: 28 March 2023
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