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Public statement

Grosvenor Casinos Limited Public Statement

Published:

7 October 2026

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Our public statements make reference to breaches of the Licence Conditions and Codes of Practice (LCCP) requirements which were in effect at the time of the breach. In some cases, the requirements have since been updated.

Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.

Introduction

Licensed gambling operators have a legal duty to ensure their gambling facilities are provided in compliance with the Gambling Act 2005 (opens in new tab)(the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

• prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime
• ensure that gambling is conducted in a fair, safe and open way
• protect children and other vulnerable people from being harmed or exploited by gambling.

Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.

Grosvenor Casinos Limited Executive Summary

A licence review under Section 116 of the Act was commenced following information provided to the Gambling Commission (the Commission) and key event notices submitted by Grosvenor Casinos Limited (the Licensee). While this review was underway, further intelligence received by the Commission prompted a targeted compliance assessment of one of the Licensee’s venues, which was conducted on 13 June 2025.

The review found failings in the Licensee’s Anti-Money Laundering (AML) and Social Responsibility (SR) controls.

It was found that the Licensee had breached the following Licence Conditions (LC):

• LC 12.1.1 paragraph 2 - Prevention of money laundering and terrorist financing
• LC 12.1.1 paragraph 3 - Prevention of money laundering and terrorist financing.

It was also found that the Licensee had failed to comply with the following Social Responsibility Code Provisions (SRCP):

• SRCP 3.4.1 paragraphs (1) (b) and (c) - Premises-based customer interaction
• SRCP 3.4.1 paragraph 2 - Premises-based customer interaction.

Compliance with a SRCP is a condition of the licence by virtue of section 82(1) of the Act.

In line with our Statement of Principles for Licensing and regulation, the Licensee will make a payment in lieu of a financial penalty of £5,012,261. Details of this are set out under the heading Grosvenor Casinos Limited Regulatory Settlement.

The regulatory settlement was proposed to the Commission, and accepted, on behalf of the Licensee and the wider group¹ due to the group adopting the same policies, procedures and controls.

Grosvenor Casinos Limited Findings

It was found that the Licensee failed to comply with the following requirements relating to AML and SRCP controls:

LC 12.1.1 paragraph 2, which 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."

The review found that elements of the Licensee’s AML policies, procedures and controls did not adequately mitigate the risk posed by money laundering and terrorist financing.

Examples included:

• the Licensee’s AML policies, procedures and controls had not been updated appropriately
• for instance, changes to the Money Laundering regulations made in 2020 had not properly been accounted for, resulting in a customer not being rated as high risk when it would have been appropriate to do so
• the Licensee’s AML policies, procedures and controls allowed inconsistent decisions to be applied to customers with elevated Money Laundering (ML) risk
• for instance, the Licensee allows a level of autonomy in decision making to its venue management which, though not problematic in principle, resulted in instances where evidence of source of funds and/or source of wealth should have been obtained and submitted for close scrutiny but was not. In one case, this resulted in a customer losing significant funds that may or may not have been their own²
• a lack of clarity in parts of the Licensee’s AML policies, procedures and controls resulted in inappropriate risk levels being ascribed to high-risk customers, high risk sources of funds being used without appropriate scrutiny, and timescales for diligence checks on certain high-risk customers being inappropriately extended
• this lack of clarity applied to the processes operated by the Licensee when assessing the risk and legitimacy of cryptocurrency assets relied upon by customers as partial source of funds or source of wealth. The Licensee’s processes appeared to have required only that such assets be verified as having been converted into fiat currency³ via an appropriate bank account before being used to gamble.

LC 12.1.1 paragraph 3, which 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 review identified examples where it could be seen that the policies and procedures and controls published by the Licensee had not been implemented effectively and/or consistently, and that certain aspects of the published policies, procedures and controls could be seen to undermine controls.

Examples included:

• instances where enhanced due diligence checks were not carried out at appropriate points, as required by the Licensee’s policies, procedures and controls
• records were seen where the use of cryptocurrency assets by a customer as the source of their funds and a customer identified as a student from China failed to cause the risk level of either customer to be increased. The Licensee’s policies mandate that such individuals will not be ‘standard risk’ and that enhanced due diligence checks should be conducted as soon as possible
• instances where staff failed to request and/or to record sufficient evidence and rationale to support AML decisions that were made
• a customer record showed a customer returning to the Licensee’s venues after a significant break losing around £200,000 in two visits without adequate photographic identification on file or evidence of income being recorded⁴ in accordance with the Licensee’s policies and procedures
• instances where a ML risk level was applied to customers displaying characteristics that should have elevated the risk
• a record was seen of a customer exclusively playing with cash, recycling circa £85,000 through the venue over approximately 11 weeks. Despite this, the ML risk level of the customer was not raised and enhanced customer due diligence checks were not adequately conducted until losses reached approximately £13,000.

SRCP 3.4.1 paragraph (1) (b) and (c) which states:

"Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:

1. ...
2. interacting with customers who may be at risk of or experiencing harms associated with gambling.
3. understanding the impact of the interaction on the customer, and the effectiveness of the Licensee’s actions and approach."

SRCP 3.4.1 (1) (b):

The review found that the Licensee had failed to interact with customers at risk of experiencing harms associated with gambling appropriately due to improper application of the Licensee’s defined safer gambling policies and staff in venues making inappropriate decisions.

Examples included:

• instances where customers’ perceived wealth or winning position was used by staff as rationale for perfunctory safer gambling interactions
• for example, a well-known and long-standing customer won circa £260,000 in a short period and then lost circa £250,000 in 12 days without safer gambling interactions being recorded
• another example is of a long-standing and wealthy customer who had an extensive history with the Licensee losing circa £50,000 without safer gambling interactions taking place
• safer gambling interactions which failed to escalate when appropriate, despite the Licensee’s policies stating that they should do so
• for example, a customer playing with verified winnings from another operator was permitted to lose approximately £25,000 before safer gambling interactions took place. Several safer gambling interactions subsequently took place for reasons including frequency and length of visits, but the Licensee failed to escalate its approach – through either imposing limits on time or spend, reducing access to debit card facilities or any other appropriate measures - until the customer acknowledged that their winnings had been exhausted. Following this admission, over the next six weeks the customer was allowed to lose around £11,000 before a suspension was imposed
• customers displaying concerning history, behaviours or inappropriate spend were permitted to play for extended periods or lose significant amounts before play was suspended, contrary to the Licensee’s policies
• officials saw records of individuals returning from self-exclusion who were permitted to play with significant funds and lose heavily. This included the customer referred to in the previous example.

SRCP 3.4.1 (1) (c):

The review found that the Licensee had failed to adequately understand the impact of the interaction on individual customers, and the effectiveness of its actions and approach.

Examples included:

• customer records that showed repeated safer gambling interactions at the same level, such as reality checks and loss and play frequency alerts, which did not alter the customers’ behaviours. The Licensee failed to evaluate the impact of previous interactions and the effectiveness of its approach
• for example, as seen in example above, a customer record was seen where repeated, similar safer gambling interactions relating to losses and velocity of play failed to alter the customers behaviour and resulted in losses over £73,000
• officials did not see evidence of these, or similar, events being evaluated and informing decisions regarding either changes in policy and procedures or staff being reminded or retrained regarding existing policies and procedures.

SRCP 3.4.1 paragraph 2 which states:

"Licensees must take into account the Commission’s guidance on customer interaction."

From the failures identified, the review found that the Licensee had failed to adequately take into account the Commission’s guidance.

Grosvenor Casinos Limited Regulatory Settlement

This regulatory settlement consists of:

• a payment in lieu of a financial penalty of £5,012,261 on behalf of the Licensee and the wider group. The money will be directed to the Consolidated Fund
• agreement to the publication of a statement of facts in relation to this case
• payment towards the Commission’s costs of investigating the case
• a commitment to undertake a third-party external audit of the Licensee’s business within six months of the conclusion of the Commission’s licence review.

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

Aggravating factors

• the Licensee has previously been issued with formal advice regarding similar areas of concern
• the Commission has previously issued public statements regarding similar issues which it had observed in relation to other operators.

Mitigating factors

• the Licensee swiftly implemented changes designed to remedy the failings
• the Licensee fully co-operated 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 and take remedial action where required:

• would your AML policies, procedures and controls bear objective scrutiny and properly mitigate and control the risk of money laundering and terrorist financing?
• are your AML controls implemented effectively?
• are your safer gambling policies and procedures effective and have they been developed following consideration of the Commissions guidance?
• are your staff aware of and properly trained to deal with the range of indicators of harms associated with gambling, as set out in the Commission’s guidance?
• are your staff properly trained to ensure AML and safer gambling controls are effectively implemented?

Footnotes

¹ Grosvenor Casinos (GC) Limited and Gaming Group Limited

² In this particular case, evidence was obtained, but not submitted to central compliance teams for scrutiny

³ Such as Great British pounds or United States dollars

⁴ Older identification records were held, but only in form of reference numbers. Open-source internet searches conducted after the events described show the individual may have significant assets but no documentation was obtained from the customer, although the review of evidence of source of funds and source of wealth had been documented