Mr Green Limited Public statement
- Social Responsibility Code Provision 4.1
- Ordinary Code Provision 4.2.
27 February 2020
Operators are expected to consider the issues here and review their own practices to identify and implement improvements in respect of the management of customers.
Licensed gambling operators have a legal duty to ensure that their gambling facilities are being 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, namely 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 and open way
- protect children and other vulnerable people from being harmed or exploited by gambling.
Mr Green Limited Executive summary
Mr Green Limited Findings
Mr Green Limited Actions taken by Mr Green Limited
Mr Green acknowledges the policies relating to AML and customer interaction in force at the relevant time were ineffective. It has now improved those policies and that process remains ongoing.
Mr Green carried out a review its top 120 customers, applying improved AML processes to its existing customer base. This led to 113 of those customer accounts being closed due to those accounts being unable to satisfy the improved AML requirements.
The Licensee has agreed to complete a compliance assessment of the next 130 top customers. Once this is complete it will have assessed all of its top 250 customers (measured by lifetime Gross Gambling Yield).
Mr Green recognises there have been considerable learnings from these cases and has invested in improving its AML and responsible gambling processes. Mr Green states it is also committed to working with the industry to raise standards, particularly in relation to safer gambling.
Mr Green Limited Regulatory settlement
In line with our Statement of principles for licensing and regulation, Mr Green has concluded a regulatory settlement. The settlement agreement consists of:
- £3,000,000 payment in lieu of a financial penalty, which will be directed towards delivering the National Strategy to Reduce Gambling Harms
- Agreement to conduct a review of an additional 130 customers in the same manner as previously undertaken to follow on from the initial 120 customers who were initially reviewed.
- Agreement to the publication of a statement of facts in relation to this case
- Payment of £10,349.77 towards our investigative costs.
In considering an appropriate resolution to this investigation, the Commission has had regard to the following aggravating and mitigating factors:
- Mr Green accepted that these breaches were not isolated and occurred over four years.
- The systemic nature of the breaches means customers not known to the Commission were likely affected.
- The breaches arose in circumstances similar to previous cases which have resulted in the publication of lessons to be learned for the wider industry.
- The need to encourage compliance amongst other operators.
- Following its acquisition by William Hill, Mr Green has put in place renewed policies and procedures which it says will prevent similar failings recurring.
- Mr Green accepted responsibility for the failings at an early stage and has been co- operative during the review process.
Mr Green Limited Good practice
We consider this case provides valuable learning for operators. They should consider the following questions:
- Do you have policies and procedures in place to identify customers who may be experiencing or at risk of developing problems with their gambling?
- Do you have systems in place to identify potential problem gamblers?
- Do these include appropriate trigger points for when the usual pattern of gambling becomes unusual (these should not be just financial)? How do you protect new customers (where a pattern of play cannot yet be established)?
- Are your staff sufficiently trained to spot problem gamblers and know how to report concerns? Are there clear procedures once a concern has been raised?
- Do you know your customer (KYC)? Are you gaining a holistic picture of the customer’s source of funds, particularly in relation to VIP customers?
- Are you critically assessing assurances you receive as to source of funds?
- Have you ensured you have clear, up-to-date, and fit for purpose AML policies and procedures available to all who require guidance?
- Have you ensured your policies and procedures have been informed by our guidance on AML?
- Have you taken into account the Commission’s Money Laundering and terrorist financing risk assessment?
For further guidance on good practice read our Enforcement report (opens in new tab)