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Public Statements

Public statements can be viewed on our website at gamblingcommission.gov.uk/public-register

Generated: 25 June 2024

Hillside (UK Gaming) ENC Public Statement

Published: 4 April 2024

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:

The Gambling Commission commenced a section 116 regulatory review of Hillside (UK Gaming) ENC (the Licensee) - Remote Bingo and Casino Operating Licence Number 055149- R-331499-002 - following a compliance assessment conducted in March 2022.

The regulatory review found failings in the Licensee’s processes aimed at preventing Money Laundering (ML) and protecting individuals from being harmed or exploited by gambling.

The Licensee failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will pay a total of £343,035 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found the Licensee had:

Breached paragraph 2 of licence condition 12.1.1 (Prevention of money laundering and terrorist financing) between May 2021 and July 2022

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.”

The Licensee accepted that, at the time of the assessment:

The Commission’s review of the specific customers identified during the compliance assessment found no evidence of criminal spend with the Licensee or the acceptance of funds from persons subject to financial sanctions.

Breached licence condition 12.1.2 (Anti-Money Laundering - Measures for operators based in foreign jurisdictions) between May 2021 and July 2022

Licence condition 12.1.2 has been in place since October 2016 and requires that: “Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business”.

Hillside (UK Gaming) ENC accepted it breached this licence condition as the AML failings, set out above, constitute a breach of the 2017 Regulations, namely:

Failed to comply with paragraphs 1b and 1c of SRCP 3.4.1 (Customer Interaction) between October 2021 to September 2022

Compliance with a SRCP is a condition of the licence by virtue of section 82(1) of the Act. SRCP 3.4.1 (in force from 31 October 2019 until 11 September 2022) states:

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

The Licensee accepted that at the time of the assessment:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:


Hillside (UK Sports) ENC Public Statement

Published: 4 April 2024

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:

The Gambling Commission commenced a section 116 regulatory review of Hillside (UK Sports) ENC (the Licensee) - General Betting Standard - Real Event, General Betting Standard - Virtual Event, and Pool Betting – Remote, Licence Number 055148-R-331498-001 - following a compliance assessment conducted in March 2022.

The regulatory review found failings in the Licensee’s processes aimed at preventing Money Laundering (ML) and protecting individuals from being harmed or exploited by gambling.

The Licensee failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will pay a total of £239,085 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found the Licensee had:

Breached paragraph 2 of licence condition 12.1.1 between May 2021 and July 2022

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.”

The Licensee accepted that, at the time of the assessment:

The Commission’s review of the specific customers identified during the compliance assessment found no evidence of criminal spend with the Licensee or the acceptance of funds from persons subject to financial sanctions.

Failed to comply with paragraphs 1b and 1c of Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction) between October 2021 to September 2022

Compliance with a SRCP is a condition of the licence by virtue of section 82(1) of the Act. SRCP 3.4.1 (in force from 31 October 2019 until 11 September 2022) states:

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

The Licensee accepted that at the time of the Assessment:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:


Lindar Media Limited Public Statement

Published: 20 September 2023

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:

The Gambling Commission commenced a section 116 regulatory review of Lindar Media Limited (the Licensee), Combined Remote Operating Licence Number 051250-R-328289-006, following a compliance assessment conducted in September 2022.

The regulatory review found failings in Lindar Media Limited’s processes aimed at preventing Money Laundering (ML) and protecting individuals from being harmed or exploited by gambling.

Officials found that, between July 2021 and September 2022, Lindar Media Limited failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

Taking into account the remedial action taken by Lindar Media Limited prior to and immediately following the compliance assessment, and in line with our Statement of principles for licensing and regulation, Lindar Media Limited will pay a total of £690,947.

A Commission compliance assessment and subsequent regulatory review found:

The investigation and our subsequent regulatory review found Lindar Media Limited had been in breach of the following:

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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 failed to have an appropriate ML and TF risk assessment, as it did not to reference that it had adequately assessed risk relating to:

In addition, the ML and TF risk assessment did not specifically address certain key risk factors as set out in the Money Laundering Regulations 2017 (the Regulations) and the Commission’s Prevention of money laundering and combating the financing of terrorism (PDF) (opens in a new tab) (February 2021) (the AML Guidance) including:

Breach of paragraph 2 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.”

The following procedures and controls were not appropriate:

Breach of paragraph 3 of licence condition 12.1.1

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 policies and procedures had been reviewed, but not in a timely manner or as frequently as necessary to take into account the Guidelines published by the Commission. They had not been signed off by the Money Laundering Reporting Officer (MLRO). Officials acknowledge the Licensee has taken steps to address this.

Failure to take into account Ordinary Code Provision 2.1.1

Paragraph 1 of Ordinary Code Provision (OCP) 2.1.1 states: "In order to help prevent activities related to money laundering and terrorist financing, licensees should act in accordance with the Commission guidance on anti-money laundering. The Prevention Money Laundering and Combating the Financing of Terrorism Guidance for remote and non- remote casinos".

The Licensee failed to take into account OCP 2.1.1 in that, contrary to the AML Guidance, the Licensee:

Breach of licence condition 15.2.1 (4) - Reporting key events

Licensees must notify the Commission, in such form or manner as the Commission may from time to time specify, of the occurrence of a key event, as soon as reasonably practicable and in any event within five working days of the Licensee becoming aware of the events occurrence.

The Licensee failed to notify the Commission when the Head of Regulatory Compliance (who held the post from 1 August 2019 to 14 June 2022) ceased to hold this position.

The Commission found the Licensee was in breach of licence condition 15.2.1 between 20 June 2022 and September 2022.

Breach of licence condition 1.2.1(3) - Specified management offices – personal management licences

"The person responsible for the licensee’s gambling regulatory compliance function as head of that function shall not, except with the Commission’s express approval, occupy any other specified management office."

At the time of the Assessment the person holding the position of Head of Regulatory Compliance also held a number of other specified management posts without the Commission’s express approval.

The Commission found the Licensee was in breach of licence condition 1.2.1(3) between 20 June 2022 and 3 October 2022.

Failure to comply with paragraph 1b, 1c 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 (in force from 31 October 2019 until 11 September 2022) states:

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

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

Failings were identified in respect of the customer interaction processes, relating to identifying customers who may be at risk of or experiencing harms associated with gambling in that:

Officials did not see evidence as to how the Licensee had fully taken account of the Commission’s formal customer interaction guidance, Customer interaction - Formal Guidance for remote gambling operators (PDF) (opens in a new tab) (July 2019)1 (CI Guidance) in the following areas:

Identify

Interact

Failure to comply with SRCP 5.1.6 - the advertising codes

On 29 June 2022 an advertisement posted on behalf of the Licensee by one of its agents relating to its MrQ website appeared on Reddit. This advertisement featured an image showing three carton Spiderman figures.

Further, a review of MrQ.com on 3 August 2022 identified cartoon imagery, not in a restricted gateway. The imagery related to King Kong cash pots, Piggy Bank Bills and The Doghouse Megaways.

On both occasions the images shown were likely to be of particular appeal to children. The Commission acknowledges that, once it became aware of the adverts, the Licensee took immediate action to remove them.

The Commission found the Licensee had failed to comply with SRCP 5.1.6 on 29 June 2022 and 3 September 2022.

Failure to comply with SRCP 3.1.1(2) – Combating problem gambling

Licensees are required to make an annual financial contribution to an organisation, approved by the Commission to support research, prevention and treatment for those harmed by gambling. The Licensee had failed to make such a payment for the year ending December 2021.

The Commission found the Licensee had failed to comply with SRCP 3.1.1(2) for the year ending December 2021.

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

The Licensee has:

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1This guidance is no longer in force, as of 11 September 2022.


Done Bros (Cash Betting) Limited Public Statement

Published: 18 July 2023

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 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:

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of Done Bros (Cash Betting) Limited’s (the Licensee/Done Bros) Non-Remote General Betting Standard, Pool Betting and Ancillary Remote Licence number: 001058-N-102469-014. The regulatory review found failings in the Licensee’s processes which were aimed at Safer Gambling (SG) and preventing Money Laundering (ML).

Between January 2021 and December 20221, Done Bros failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £3,250,000, which includes a divestment of £1,052,717.

The investigation and our subsequent regulatory review found:

We found that the Licensee had:

Breached licence condition 12.1 Prevention of money laundering and terrorist financing

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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 ML/TF risk assessment did not:

Breach of paragraph 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.”

Although an analysis of the specific customer records identified during the regulatory review found no evidence of criminal spend with the Licensee, the Licensee nevertheless accepted that it had breached this licence condition, as:

Failed 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:

  1. 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:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1 This date represents the total period of non-compliance, there are some variations in the individual breach period for each condition.


Videoslots Limited Public Statement

Published: 15 June 2023

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 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:

This investigation followed two compliance assessments which resulted in the commencement of a section 116 regulatory review1 of Videoslots’ Limited, Combined Remote Operating Licence number: 039380-R-319311-032.

The regulatory review found failings in the implementation of Videoslots’ processes which were aimed at preventing Money Laundering (ML) and ensuring safer gambling.

Between October 2019 and February 20222, Videoslots failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

In line with our Statement of principles for licensing and regulation, Videoslots will make payments in lieu of a financial penalty of £2,000,000. A breakdown of the regulatory settlement is set out in the following pages.

The investigation, and our subsequent regulatory review, found:

We found that Videoslots had been in:

Breach of licence condition 12.1.1(3)

Licence condition 12.1.1(3) states that “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.”

Videoslots accepted it breached this licence condition between March 2021 and April 2022 for the following reasons:

Failure to comply with 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.

During the period covered by the compliance assessments SRCP 3.4.1 (ceased in September 2022) states:

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

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

Videoslots accepted it was not fully in compliance with SRCP 3.4.1 during the following periods:

Videoslots accepted it breached this SRCP for the following reasons:

A regulatory settlement penalty package of £2,000,000 has been agreed, which consists of the following elements:

Conclusion

Our investigation found, and Videoslots accepts, that there were significant weaknesses in its ability to implement its policies and procedures for AML and safer gambling purposes.

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

Aggravating factors:

Mitigating factors:

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should also consider the following questions:

Notes

1 The Commission commenced its regulatory review on 9 February 2022

2 This demonstrates the overall breach period. The period the Licensee was in breach for each condition varies and has been detailed further under the relevant sections below.


Skill On Net Limited Public Statement

Published: 23 May 2023

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 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:

This investigation followed the commencement of a section 116 regulatory review of Skill on Net Limited (the Licensee), Combined Remote Operating Licence number: 039326-R-319358-050. The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling and preventing Money Laundering (ML).

Between the period of January 2021 and December 20221, the Licensee failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £305,150, which includes a £105,650 divestment, and 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.

The investigation and our subsequent regulatory review found:

We found that, between the period of January 2021 and December 2022, Skill on Net had been in:

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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 between May 2021 until December 2022, 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 Commission found the relevant risk assessment failed to:

Breach of paragraph 2 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.”.

The Licensee accepted that issues identified by the Commission indicated deficiencies in their policies and procedures and accepted they were in breach of licence condition 12.1.1(2) between May 2021 and March 2022.

The Commission’s concerns included:

Breach of paragraph 3 of licence condition 12.1.1

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 acknowledged their policies and procedures were not fully compliant with licence condition 12.1.1(3) between May 2021 and December 2022.

The Commission’s concerns included:

Breach of paragraph 1 of licence condition 12.1.2 (Anti-money laundering - measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires the Licensee comply with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the 2017 Regulations).

The Licensee accepted its policies and processes were not fully compliant and that there was a breach of licence condition 12.1.2 between May 2021 and December 2022.

Commission officials consider the Licensee failed to adequately implement the measures described in the relevant regulations laid out in the 2017 Regulations for reasons including:

Failure to comply with SRCP 3.4.1 paragraphs 1 and 2

SRCP (1) and (2) states:

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

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

The Licensee accepted they were not in full compliance with SRCP 3.4.1 as follows:

The Commission was concerned in particular with the following customer interaction failings regarding SRCP 3.4.1(1):

The Commission was also concerned the Licensee failed to take into account the Commission’s guidance on customer interaction, in accordance with SRCP 3.4.1(2) as:

This regulatory settlement consists of:

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

Aggravating factors:

Mitigating factors:

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

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


William Hill Organization Limited Public Statement

Published: 28 March 2023

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 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:

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review1 of William Hill Organization Limited (WH Retail / the Licensee), Combined Non-Remote Operating Licence number: 000-002752-N-102413-014.

The regulatory review found failings in the Licensee’s processes which were aimed at preventing Money Laundering (ML), and safer gambling.

Between 1 January 2020 and 18 October 20212, the Licensee failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £2,999,850 which includes a divestment of £244,026.95, and will vary its licence to add additional licence conditions.

The investigation found:

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:

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:

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:

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:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good Practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1 The Commission commenced its regulatory review on 30 September 2021.

2 There is one variance from the breach date listed - Paragraph 1 of licence condition 12.1.1 was breached between 1 January 2020 and 2 May 2022.

3 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.


WHG (International) Limited Public Statement

Published: 28 March 2023

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 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:

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review1 of WHG (International) Limited (the Licensee/WHG), Combined Remote Operating Licence number: 000-039225-R-319373-0112.

The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling and preventing Money Laundering (ML).

Between May 20203 and 18 October 2021, WHG (International) Limited failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £12,500,000, which includes a divestment of £284,361.57, and will vary its licence to add additional licence conditions.

The investigation and our subsequent regulatory review found:

We found that between May 20204 and 18 October 2021 the Licensee had been in:

Breach of paragraph 1 of licence condition 2.3.1

Licence condition 2.3.1, paragraph 1 states: “Licensees must comply with the Commission’s technical standards and with requirements set by the Commission relating to the timing and procedures for testing”

The Licensee accepted it was not fully in compliance with 2.3.1 as:

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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:

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 it breached this licence condition as:

Breach of paragraph 1 of licence condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires that:

“Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business”.

The Licensee accepts it breached this licence condition as the AML failings, set out above, constitute a breach of the 2017 Money Laundering Regulations, namely:

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:

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:

Failure to comply with paragraphs 1a, 1c and 1d of SRCP 3.7.1 (Provision of Credit)

Paragraph 1a of SRCP states:

“Licensees who choose to offer credit to members of the public who are not themselves gambling operators must also:

Paragraph 1c of SRCP 3.7.1 states:

Paragraph 1d of SRCP 3.7.1 states licensees must:

The Licensee accepted it was not fully in compliance with SRCP 3.7.1 as:

Failure to comply with paragraph 2a of SRCP 3.9.1 (Identification of individual customers)

Paragraphs 2a of SRCP 3.9.1 state:

“2. Where licensees allow customers to hold more than one account with them, the licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each of the others and ensure that:

The licensee accepted it was not fully in compliance with SRCP 3.9.1 as:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1 The Commission commenced its regulatory review on 30 September 2021

2 WHG (International) Limited trade under: William Hill Online

3 There are some variances of starting date for breach, but they all fall mainly within this common period. Specific variations from this date, include breach of licence condition 2.3.1 occurred during an unknown time period between December 2020 and February 2021; breach of paragraph 1 of licence condition 12.1.1 which occurred between 20 September 2020 and 22 October 2021. The Licensee also failed to comply with SRCP 3.4.1 between 4 December 2020 and 18 October 2021; SRCP 3.7.1 between 7 February 2021 and 12 February 2021; SRCP 3.9.1 between June 2021 to October 2021

4 Subject of variations detailed at footnote 3

5 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.

6 The Licensee reported early and voluntary breaches to the Commission which related to matters detailed in Finding 1 (Remote technical standard requirements under A.7.2.2); Finding 6 (SRCP 3.7.1); and Finding 7 (SRCP 3.7.1).


Mr Green Limited Public Statement

Published: 28 March 2023

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 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:

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review1 of Mr Green Limited (the Licensee/MRG), Combined Remote Operating Licence number: 000-039264-R-319432-0192. The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling and preventing Money Laundering (ML).

Between May 20203 and 18 October 2021, MRG failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £3,750,000, which includes a £218,310.20 divestment, and will vary its licence to add additional licence conditions.

The investigation and our subsequent regulatory review found:

We found that between 20 September 2020 and 22 October 2021 MRG had been in:

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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:

We found that between May 2020 and 18 October 2021 MRG had been in:

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.”

MRG accepted it breached this licence condition as:

Breach of Paragraph 1 of licence condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires that:

“Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business”.

The Licensee accepts it breached this licence condition as the AML failings, set out above, constitute a breach of the 2017 Money Laundering Regulations, namely:

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:

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

MRG accepted it was not fully in compliance with SRCP 3.4.1 as:

Failure to comply with paragraph 1 and 2b of SRCP 3.9.1 (Identification of individual customers)

Paragraph 1 of SRCP 3.9.1 states:

“Licensees must have and put into effect policies and procedures designed to identify separate accounts which are held by the same individual”.

Paragraph 2b states:

“Where licensees allow customers to hold more than one account with them, the licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each of the others and ensure that: all of a customer’s accounts are monitored and decisions that trigger customer interaction are based on the observed behaviour and transactions across all the accounts”.

MRG accepted it was not fully in compliance with SRCP 3.9.1 as:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

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.


Blue Star Planet Limited Public Statement

Published: 16 February 2023

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 above 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:

This investigation resulted in the commencement of a section 116 regulatory review1 of Blue Star Planet Limited, Combined Remote Operating Licence Number: 000-043173-R-322899-020.

The regulatory review found failings in Blue Star Planet Limited’s processes which were aimed at preventing Money Laundering (ML) and protecting vulnerable people. These failings were identified following a compliance assessment that was conducted by Commission Officials on 22, 23, 24 and 25 June 2021.

Between November 2019 and June 2021, Blue Star Planet Limited failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

Considering remedial action taken by Blue Star Planet Limited and in line with our Statement of principles for licensing and regulation, Blue Star Planet Limited will pay a total of £620,000 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found:

We found that between November 2019 and June 2021, Blue Star Planet Limited had been in:

Breach of paragraph 1 of license condition 12.1.1

Licence condition 12.1.1(1) 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.”

Blue Star Planet Limited accepted its AML Risk Assessment (the Risk Assessment) was inadequate in certain areas and did not explicitly acknowledge:

Breach of paragraph 2 of license 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.”

Blue Star Planet Limited accepted that at the time of the Assessment:

Breach of paragraph 3 of licence condition 12.1.1

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.”

Blue Star Planet Limited accepted that, at the time of the Assessment:

Breach of paragraph 1 of licence condition 12.1.2 (Anti-Money Laundering Measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires that: “Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business”.

Blue Star Planet Limited accepted:

Breach of licence condition 8.1.1 (Display of Licensed Status)2

Licence condition 8.1.1 states:

“1 Licensees providing facilities for remote gambling must display on every screen from which customers are able to access gambling facilities provided in reliance on this licence:

2 Such statement, account number and link must be in the format, provided by the means, and contain the information from time to time specified by the Commission in its technical standards applicable to the kind of facilities for gambling provided in accordance with this licence or otherwise notified to licensees for the purposes of this condition.

3 Licensees may also display on screens accessible from Great Britain information about licences or other permissions they hold from regulators in, or by virtue of the laws of, jurisdictions outside Great Britain provided it is made plain on those screens that the licensee provides facilities for gambling to persons in Great Britain in reliance on their Gambling Commission licence(s).”

Blue Star Planet Limited accepted that, at the time of the Assessment:

Failure to comply with paragraph 1b, 1c and 2 of Social Responsibility Code Provision (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:

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

Blue Star Planet Limited accepted, at the time of the Assessment:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1 The Commission commenced its section 116 review on 7 September 2021.

2 Although the Licensee accepts the breach, it remains of the view that an isolated incident of a single broken website link should not warrant a finding that it breached licence condition 8.1.1.


Vivaro Limited Public Statement

Published: 17 January 2023

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 as follows 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 gambling facilities are provided in compliance with the Gambling Act 2005 (the Act), the conditions of their licence, and in accordance with the licensing objectives, which are to:

This investigation followed a compliance assessment carried out in April 2021 and resulted in the commencement of a section 116 regulatory review1 of Vivaro Limited (Vivaro), Combined Remote Operating Licence number: 000-044662-R-324273-017.

The regulatory review found failings in Vivaro’s processes which were aimed at preventing Money Laundering (ML) and safer gambling.

Between October 2020 and June 2021 Vivaro failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

In line with our Statement of principles for licensing and regulation, Vivaro will make payments in lieu of a penalty package of £337,631. A breakdown of the regulatory settlement is set out in the following sections.

The investigation, and our subsequent regulatory review, found:

We found that between October 2020 and June 2021, Vivaro had been in breach of the following licence conditions and Social Responsibility Code Provisions:

Breach of licence condition 12.1.1.2 and 12.1.1.3

Licence condition 12.1.1 (2) states that “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 that “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.”

Vivaro accepted it breached these licence conditions for the following reasons:

The Commission’s review of the specific customers identified during the Compliance assessment found no evidence of criminal spend with the Licensee.

Breach of licence condition 12.1.2.1

Paragraph 1 of this condition has been in place since October 2016 and requires that:

“Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business”.

The Licensee accepts it breached this licence condition as the AML failings, set out above, constitute a breach of the 2017 Money Laundering Regulations, namely:

Failure to comply with Social Responsibility Code Provision (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:

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

Vivaro accepted it was not fully in compliance with SRCP 3.4.1 as:

A regulatory settlement package of £337,631 has been agreed, which consists of the following elements:

Conclusion

Our investigation found, and Vivaro accepts, that there were significant weaknesses in its systems relating to how it managed its customers for AML and social responsibility purposes.

In determining the appropriate outcome, we took the following factors into account:

Good Practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should also consider the following questions:


Spreadex Limited Public Statement

Published: 25 August 2022

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.

Key failings:

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) and the conditions of their licence, and in accordance with the licensing objectives, which are to:

This investigation resulted in the commencement of a section 116 regulatory review of Spreadex Limited (Spreadex), Combined Remote Operating Licence number: 000-008835-R-104580-017. The Commission commenced its regulatory review on 2 June 2021, following concerns identified in a compliance assessment conducted in May 2021.

The regulatory review found failings in Spreadex’s procedures which were aimed at preventing Money Laundering (ML) and protecting vulnerable people.

Between January 2020 and May 2021 Spreadex breached its Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by Spreadex and in line with our Statement of Principles for licensing and regulation, Spreadex will pay a total of £1,363,786 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found:

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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 Commission found, and Spreadex acknowledged, that its Money Laundering and Terrorist Financing Risk Assessment (ML and TF RA) was not fully compliant with licence condition 12.1.1 (1). In particular:

Breach of paragraph 2 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.”.

The Commission found, and Spreadex acknowledged, that it was not fully compliant with licence condition 12.1.1(2). In particular:

As examples, the Commission’s concerns included:

Breach of paragraph 3 of licence condition 12.1.1

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 Commission found, and Spreadex acknowledged, that its policies, procedures and controls were not fully compliant with licence condition 12.1.1(3). In particular, the Licensee:

As examples, the Commission’s concerns included:

The Commission’s review of the specific customers identified during the Compliance assessment found no evidence of criminal spend with the Licensee.

Failure to consider Ordinary Code Provision (OCP) 2.1.1 – Anti-money Laundering (Casino)1

The findings set out at 1 to 3 occurred, to an extent, because Spreadex had failed to sufficiently take into account the Commission’s AML guidance. OCP 2.1.1, states: “In order to help prevent activities related to money laundering and terrorist financing, licensees should act in accordance with the Commission’s guidance on anti-money laundering: The Prevention of Money Laundering and Combating the Financing of Terrorism - Guidance for remote and non-remote casinos.

Failure to comply with: Social Responsibility Code 3.4.12

Social Responsibility Code Practice (SRCP 3.4.1) at paragraphs 1 and 2 states “Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:

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

The Commission found, and Spreadex acknowledged, that its policies and processes were not fully compliant with SRCP 3.4.1 (1) and (2). In particular:

As an example, the Commission’s concerns included a customer who was able to deposit £1.7 million and lose £500,000 during the course of a one month period. Customer interactions had taken place but they had not been sufficiently evaluated, and did not include considering the effectiveness of restricting the account.

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

1OCP do not have the status of licence conditions but set out good practice. Any departure from OCP provision by an operator may be considered by the Commission as part of a licence review.

2Compliance with an SRCP is a condition of the licence by virtue of section 82(1) of the Act.


Ladbrokes Betting & Gaming Limited Public Statement

Published: 17 August 2022

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.

This licensee is part of the Entain Group (Entain) (formerly named the GVC group) of companies.

Operators are expected to consider the issues outlined as follows 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 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:

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review1 of Ladbrokes Betting & Gaming Limited (LBG), Combined Non-Remote Operating Licence number: 001611-N-102408-022. The regulatory review found failings in LBG’s processes which were aimed at preventing Money Laundering (ML) and safer gambling.

Between December 2019 and October 2020 LBG failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by LBG and in line with our Statement of Principles for licensing and regulation, LBG will voluntarily divest itself of £212,849.86 and pay £2,787,150.14 in lieu of a financial penalty resulting in a total payment of £3,000,000.

The investigation and our subsequent regulatory review found:

We found that, between December 2019 and October 2020, LBG had been in breach of the following licence conditions and Social Responsibility Code Provisions:

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.”

LBG accepted:

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 Social Responsibility Code Provision (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:

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

LBG accepted it was not fully in compliance with SRCP 3.4.1 as:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1The Commission commenced its regulatory review on 18 January 2021.


LC International Limited Public Statement

Published: 17 August 2022

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.

This licensee is part of the Entain Group (Entain) (formerly named the GVC group) of companies.

Operators are expected to consider the issues outlined as follows 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 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:

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review1 of LC International Limited (LCI), Combined Remote Operating Licence number: 000-054743-R-330863-00722. The regulatory review found failings in LCI’s processes which were aimed at preventing Money Laundering (ML) and safer gambling.

Between December 2019 and October 2020, LCI failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

Taking into account remedial action taken by LCI and in line with our Statement of Principles for licensing and regulation, LCI will voluntarily divest itself of £544,048.03 and pay £13,455,952 in lieu of a financial penalty resulting in a total payment in lieu of a financial penalty of £14,000,000.

The investigation and our subsequent regulatory review found:

We found that between December 2019 and October 2020 LCI had been in breach of the following licence conditions and Social Responsibility Code Provisions.

Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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.”

LCI accepted it breached this licence condition as its ML and TF risk assessment did not sufficiently reflect the Commission’s expectations or fully take into account the Commission’s ML and TF risk assessment of the British gambling industry.

The failings were that LCI’s risk assessment did not:

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.”

LCI accepted it breached this licence condition as:

Breach of paragraph 1 of licence condition 12.1.2 (Anti-Money Laundering measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires that:

“Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business”.

The Licensee accepts it breached this licence condition as the AML failings, set out above, constitute a breach of the 2017 Money Laundering Regulations, namely:

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 Social Responsibility Code Provision (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:

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

LCI accepted it was not fully in compliance with SRCP 3.4.1 as:

Failure to comply with paragraphs 1 and 2 of Social Responsibility Code Provision 3.9.1 (Identification of individual customers)

Paragraphs 1 and 2 of SRCP 3.9.1 state:

“1 Licensees must have and put into effect policies and procedures designed to identify separate accounts which are held by the same individual.

2 Where licensees allow customers to hold more than one account with them, the licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each of the others and ensure that:

LCI accepted it was not fully in compliance with SRCP 3.9.1 as:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Notes

1The Commission commenced its regulatory review on 11 November 2020.

2LCI trade under: Cheeky Bingo; Coral; Foxy Bingo; Foxy Games; Gala; Gala Bingo; Gala Casino; Gala Coral; Gala Spins; Game Bookers; Ladbrokes; Party Casino; Party Poker; Sporting Bet; bwin.

3The AML Guidance and the Commission’s MLTF risk assessment sets out a number of factors licensees must and should consider when undertaking their own MLTF 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 MLTF risk assessment.


Jumpman Gaming Limited Public Statement

Published: 17 May 2022

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.

Key failings:

Operators are expected to consider the issues outlined 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 (the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

This investigation resulted in the commencement of a section 116 regulatory review of Jumpman Gaming Limited (Jumpman Gaming), Combined Remote Operating Licence number: 039175-R-319452-022. The Commission commenced its regulatory review on 3 September 2020 following concerns identified in a compliance assessment conducted in July 2020.

The regulatory review found failings in Jumpman Gaming’s processes which were aimed at preventing money laundering (ML) and promoting safer gambling by protecting vulnerable people.

Evidence gathered during the compliance assessment and the subsequent review of the operating licence found Jumpman Gaming failed to comply with the Licence Conditions and Codes of Practice (LCCP), specifically:

Further failings of the following LCCP were also identified:

Taking into account remedial action taken by Jumpman Gaming and in line with our Statement of principles for licensing and regulation, Jumpman Gaming will pay a total of £500,000 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found:

The assessment and review focused on the period of time between February 2020 and July 2020. The Commission used a sample of customers that opened accounts during this period.

Breach of paragraph 1 of Licence Condition 12.1.1

Licence Condition 12.1.1(1) 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.”.

Jumpman Gaming acknowledged their money laundering and terrorist financing (ML and TF) risk assessment was deficient and that they were in breach of Licence Condition 12.1.1(1).

The Commission found the relevant risk assessments failed to:

Breach of paragraph 2 of license 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.”.

Jumpman Gaming accepted issues identified by the Commission during the compliance assessment indicated deficiencies in their policies and procedures and accepted they were in breach of Licence Condition 12.1.1(2).

The Commission’s concerns included:

Breach of paragraph 3 of licence condition 12.1.1

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.”.

Jumpman Gaming acknowledged their policies and processes were not fully compliant with Licence Condition 12.1.1(3).

The Commission’s concerns included:

Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering Measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires the Licensee comply with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the 2017 Regulations).

Jumpman Gaming accepted its policies and processes were not fully compliant and that there was a breach of Licence Condition 12.1.2.

Commission officials consider the Licensee failed to thoroughly implement the measures described in the relevant regulations laid out in the 2017 Regulations for reasons including:

Examples included:

Failure to comply with Social Responsibility Code Provision 3.4.1 paragraphs 1 and 2

SRCP 3.4.1 (1) and (2) states:

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

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

The Licensee accepted they were not in full compliance with this SRCP 3.4.1 (1) and (2).

The Commission was concerned in particular with the following customer interaction failings regarding SRCP 3.4.1(1):

The Commission was also concerned the Licensee failed to take into account the Commission’s guidance on customer interaction, in accordance with SRCP 3.4.1(2).

The Commission’s concerns included:

Failings in respect of Social Responsibility Code Provision 3.9.1

SRCP 3.9.1 (1) and (2) state:

"1. Licensees must have and put into effect policies and procedures designed to identify separate accounts which are held by the same individual.

  1. Where licensees allow customers to hold more than one account with them, the licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each of the others and ensure that:

The Licensee acknowledged that some customers who had opened multiple accounts across the Jumpman brands were able to circumvent our internal measures due to the misapplication of tools available at the time.

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors:

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:


Progress Play Limited Public Statement

Published: 17 May 2022

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.

Key failings

Anti-money laundering:

Safer gambling:

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

Introduction

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

This investigation resulted in the commencement of a section 116 regulatory review of Progress Play Limited’s, (Progress Play), Combined Remote Casino and Betting Operating Licence number: 000-039335-R-319313-017. The Commission commenced its regulatory review on 14 August 2020.

The regulatory review found failings in Progress Play’s processes which were aimed at preventing money laundering and protecting vulnerable people. Progress Play failed to comply with the Licence conditions and codes of practice (LCCP), specifically:

Progress Play fully cooperated throughout the course of our investigation and has accepted that its policies and procedures in respect of anti-money laundering and safer gambling were not appropriate, nor implemented effectively. It has accepted that it failed to act in accordance with conditions of its operating licence. Progress Play provided an action plan during the investigation and took action to expand and improve their compliance capacity.

Taking into account remedial action taken by Progress Play and in line with our Statement of principles for licensing and regulation, Progress Play will make a payment in lieu of a financial penalty and divestment to the sum of £175,718.00 It will also pay Commission costs of £12,466.35.

Breach of paragraph 2 of licence condition 12.1.1

Licence condition 12.1.1 (2) states that: "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.".

Commission Officials consider that Progress Play failed to establish and maintain appropriate policies, procedures and controls to prevent money laundering and terrorist financing.

Progress Play accepted:

Breach of paragraph 3 of licence condition 12.1.1

Licence condition 12.1.1(3) states that: “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.”.

Commission Officials consider Progress Play failed to ensure that their policies, procedures and controls were implemented effectively, kept under review, revised appropriately to ensure they remain effective and take into account any applicable learning or guidelines published by the Gambling Commission.

Progress Play accepted:

Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition requires that: "Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business.".

Progress Play accepted it did not:

Failure to comply with Paragraph 1 and 2 of social responsibility code provision (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:
  1. Licensees must take into account the Commission’s guidance on customer interaction.

Progress Play accepted that:

Failure to consider OCP 3.4.2 (customer interaction)

Ordinary code provisions (OCP) do not have the status of licence conditions but set out good practice. Any departure from OCP provision by an operator may be considered by the Commission as part of a licence review.

Progress Play failed to consider OCP 3.4.2 which states operators should keep a record of customer interactions, and where an interaction has been ruled out the reasons for this. Where an interaction has taken place later, this should also be recorded.

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors


BV Gaming Limited Public Statement

Published: 24 February 2022

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.

Key failings:

February 2022

Operators are expected to consider the issues previously outlined 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 (the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

Following a compliance assessment conducted in March 2020 (the Assessment), the Commission commenced a section 116 regulatory review1 of BV Gaming Limited, trading as BetVictor (BV Gaming), Combined Remote Operating Licence number: 039576-R- 319370-019. The regulatory review found failings in BV Gaming’s processes which were aimed at preventing money laundering (ML) and protecting vulnerable people.

Between 1 January 2019 to 12 March 2020 BV Gaming failed to comply with the Licence conditions and codes of practice (LCCP), specifically:

BV Gaming submitted a remedial action plan with the Commission within 2 days of receiving the notice commencing the licence review on 7 April 2020, which it then preceded to implement, as it had committed to the Commission to do.

Taking into account remedial action taken by BV Gaming and in line with our Statement of principles for licensing and regulation, BV Gaming will divest £352,000.00, gross gambling yield (GGY) gained as a result of the failings and pay a total of £1,728,000 in lieu of a financial penalty.

1 The Commission commenced its regulatory review on 7 April 2020.

The investigation and our subsequent regulatory review found:

We found that between 1 January 2019 to 12 March 2020 BV Gaming had been in:

1. Breach of paragraph 1 of licence condition 7.1.1

Licence condition 7.1.1(1) states “Licensees must ensure that the terms on which gambling is offered, and any consumer notices relating to gambling activity, are not unfair within the meaning of the Consumer Rights Act 2015. Licensees must comply with those terms.”

Although this was an isolated failing and not systemic, BV Gaming accepted:

Further, an unfair term was identified in one promotion whereby the wording suggested a promotion could be cancelled or amended by the Promoter. Operators have a legitimate interest in being able to amend or remove a promotion before a consumer has signed up or acted upon it, however a promotion should not be withdrawn, or amended where a consumer has already signed up. In this case, BV Gaming did not actually cancel or amend promotions where a consumer had already signed up but accepted the Commission’s view that the terms and conditions needed to be clearer that it would not do so. As such, the learning for the industry is to ensure terms and conditions clearly state that whilst promotions could be cancelled or amended by an operator, that is without prejudice to any customer that has already signed up to the promotion in question.

2. Breach of paragraph 1 of licence condition 12.1.1

Licence condition 12.1.1(1) 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.”

BV Gaming accepted it was in breach of licence condition 12.1.1(1) as its AML Risk assessment (the Risk Assessment) reviewed at the time of the Assessment did not sufficiently reflect the Commission’s expectations or fully comply with the Commission’s AML risk assessment as set out in our guidance.

Examples of failures included:

3. Breach of paragraph 2 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.” BV Gaming accepted at the time of the Assessment its policies and processes were not fully compliant and it was in breach of Licence condition 12.1.1(2) as:

4. Breach of paragraph 3 of licence condition 12.1.1

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.”

BV Gaming accepted at the time of the Assessment, its policies and processes were not fully compliant, and it was in breach of licence condition 12.1.1(3) and it needed a more coordinated approach to managing ML/TF risk and must focus on ensuring it can properly evidence the decisions it takes as:

5. Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering Measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires that:

BV Gaming accepted:

6. Failure to comply with Paragraph 1 and 2 of social responsibility code provision (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.

When in force, SRCP 3.4.1(e)(i) required the following: “Licensees must put into effect policies and procedures for customer interaction where they have concerns a customer’s behaviour may indicate problem gambling. The policies must include:

This SRCP was subsequently amended on 31 October 2019. This requires licensees to: “1. Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:

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

BV Gaming accepted that at the time of the Assessment it was not fully in compliance with SRCP 3.4.1 as it failed to:

7. Failure to comply with paragraph 2 of SRCP 5.19 (Other marketing requirements)

SRCP 5.1.9(2) requires:

BV Gaming accepted that at the time of the Assessment it was not in full compliance with (and therefore in technical breach of) SRCP 5.1.9 as significant conditions of a welcome offer were not displayed with sufficient prominence at the point of promotion despite there being sufficient space to do so.

This regulatory settlement consists of:

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

Aggravating factors:

The aggravating factors were:

Mitigating factors:

The mitigating factors were:

Good practice:

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:


Annexio (Jersey) Limited trading as Affiliate Empire Public Statement

Published: 20 January 2022

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.

Annexio (Jersey) Limited trading as Affiliate Empire; lottogo.com

Key failings

Operators are expected to consider the issues outlined 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 (the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

This investigation resulted in the commencement of a section 116 regulatory review1 of Annexio (Jersey) Limited (Annexio), combined remote operating licence number: 051692-R-329113-006. The Commission commenced a regulatory review on 14 April 2021. The regulatory review found failings in Annexio’s processes which were aimed at preventing money laundering (ML) and protecting vulnerable people.

Between October 2019 and November 2021 Annexio failed to comply with the Licence conditions and code of practice (LCCP), specifically:

Taking into account the remedial action taken by Annexio and in line with our Statement of principles for licencing regulation, Annexio will pay a total of £612,000 in lieu of a financial penalty.

The investigation and subsequent regulatory review found:

Breach of Paragraph 1 of Licence Condition 12.1.1 (Anti-Money Laundering) between October 2019 and November 2021

Licence condition 12.1.1(1) states: “Licensees must conduct an assessment of their 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.”

Annexio accepted its MLTF risk assessment had not addressed certain risks in sufficient detail including:

Following the Assessment Annexio updated its MLTF risk assessment.

Breach of Paragraph 2 of Licence Condition 12.1.1 between October 2019 and December 2020

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.”

Annexio acknowledged that some of its AML policies and procedures in place at the time of the Assessment were not compliant with the Licence conditions and codes of practice (LCCP).

Annexio accepted in respect of some customer accounts reviewed:

Breach of paragraph 3 of Licence Condition 12.1.1 between October 2019 and December 2020

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.”

Annexio accepted:

Annexio has implemented a number of new procedures including the following:

Failure to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction) between October 2019 and December 2020

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.

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

Annexio accepted it had:

Breach of Licence condition 15.2.1 (Reporting key events) in August 2020

A key event is an event that could have a significant impact on the nature or structure of a licensee’s business. Licence condition 15.2.1 requires licensees to notify the Commission, or ensure the Commission is notified, in such form or manner as the Commission may from time to time specify, of the occurrence of specified key events as soon as reasonably practicable and in any event within five working days of the licensee becoming aware.

Annexio failed to notify the Commission of a “bug” discovered on 11 August 2020 which was removed on 26 August 2020. The bug allowed customers to override and circumvent deposit limits set by Annexio.

This regulatory settlement consists of:

In considering an appropriate resolution to this investigation, the Commission took the following aggravating and mitigating factors into consideration:

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Footnotes

1 The Commission commenced a regulatory review on 14 April 2021.


Rank Digital Gaming (Alderney) Limited Public statement

Published: 20 January 2022

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.

Rank Digital Gaming (Alderney) Limited trading as bellacasino.com, grosvenorcasino.com, meccabingo.com, meccagames.com

Key failings

Operators are expected to consider the issues outlined above and review their own policies and 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 (the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

Following a compliance assessment of Rank Digital Gaming (Alderney) Limited (Rank) failings were identified, which resulted in the commencement of a section 116 regulatory review1 of its Combined Remote Operating Licence number: 038750-R-319345-023. The regulatory review found failings in Rank’s processes aimed at protecting vulnerable people. Between October 2019 and February 2021 Rank failed to comply with the Licence conditions and codes of practice (LCCP), specifically:

Taking into account remedial action taken by Rank and in line with our Statement of principles for licensing and regulation, Rank will pay a total of £700,557 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found:

Failure to comply with Paragraph 1 and 2 of social responsibility code provision (SRCP) 3.4.1 (Customer Interaction) between October 2019 and February 2021

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:

  1. identifying customers who may be at risk of or experiencing harms associated with gambling.
  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.
  1. Licensees must take into account the Commission’s guidance on customer interaction.”

Rank accepted that:

Failure to comply with Social Responsibility Code Provision 3.9.1 Paragraph 2 (b) - Identification of individual customers - remote, between June 2020 and February 2021

This states: “Where licensees allow customers to hold more than one account with them, the licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each of the others and ensure that:

Rank accepted that a small percentage of customers held more than one account and that some had circumvented the controls. Despite the relatively low numbers, it needed to protect customers who were limited by them or displayed at risk behaviours, from creating new accounts unchecked.

The Licensee has implemented enhanced controls for identifying duplicate accounts, particularly for restricted customers.

Failure to comply with Social Responsibility Code Provision 3.5.3 Paragraph 6 – Self-exclusion between November 2020 and February 2021

This states: “6. Licensees must put into effect procedures designed to ensure that an individual who has self-excluded cannot gain access to gambling.”

Following a platform migration in November 2020, the manual processes in place in respect of bellacasino.com and meccagames.com were not sufficient to mitigate the risk of self-excluded customers opening accounts across two platforms.

Rank accepted:

The process for dealing with such breaches has post Assessment been significantly enhanced.

This regulatory settlement consists of:

  1. £700,557 payment in lieu of a financial penalty, which will be directed towards delivering the National Strategy to Reduce Gambling Harms
  2. agreement to the publication of a statement of facts in relation to this case
  3. payment of the Commission’s costs relating to the investigating of the case.

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

Aggravating factors:

Mitigating factors:

Good practice:

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:

Footnotes

1 The Commission commenced its Regulatory review on 27 May 2021.


International Multi-Media Entertainments Limited (IMME)

Published: 22 December 2021

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.

IMME provided facilities for real event betting, i.e. betting on the outcome of international lotteries under an operating licence granted by the Gambling Commission.

Following a licence review, which commenced on 17 January 2020, the Commission concluded that it was minded to revoke the operating licence. This followed the Commission’s decision to suspend the operating licence on 16 March 2020 due to concerns regarding the risk presented by IMME’s management of the business, continued compliance issues and a lack of insight into the Commission’s concerns. IMME remained suspended throughout the investigation.

Officials were minded to revoke the operating license as IMME:

IMME decided to challenge officials’ preliminary decision at a Regulatory Panel hearing, which was scheduled to take place on 27 and 28 October 2021. On 22 September 2021 IMME surrendered its operating licence.

In line with our Statement of principles for licensing and regulation and our Licensing, compliance and enforcement under the Gambling Act 2005: policy statement, the Commission decided to determine the facts of the case and publish the findings of the investigation, as we consider that there are wider lessons to be learned by the industry about the failings we identified.

The Commission’s investigation found that IMME failed to comply with the Licence conditions and codes of practice (LCCP), specifically:

  1. Licence condition 4.2.1 (disclosure to customers)
  2. Licence condition 7.1.1 (fair and transparent practice)
  3. Licence condition 8.1.1 (display of licensed status)
  4. Licence condition 12.1.1 (Anti-money laundering, prevention of money laundering and terrorist financing)
  5. Licence condition 15.1.2 (reporting suspicion of offences)
  6. Licence condition 15.2.1 (reporting key events)
  7. Licence condition 15.3.1 (general and regulatory returns)
  8. Licence condition 17.1.1. (customer identity verification)
  9. Social Responsibility Code provision 3.1.1 (combating problem gambling)
  10. Social Responsibility Code provision 3.3.4 (remote time out facility)
  11. Social Responsibility Code provision 3.4.1 (customer interaction)
  12. Social Responsibility Code provision 5.1.6 (compliance with advertising codes)
  13. Social Responsibility Code provision 5.1.9 (other marketing requirements)
  14. Social Responsibility Code provision 7.1.2 (responsible gambling information for staff)
  15. Ordinary Code provision 1.1.1 (licensing objectives)
  16. Ordinary Code provision 3.4.2 (customer interaction)
  17. Ordinary Code provision 3.5.4 (self-exclusion).

The Commission also made further adverse findings regarding:

The Commission has further questioned the integrity of IMME with regard to:

The investigation found, in summary:

AML policies, procedures and controls

IMME’s licence and the Money Laundering Regulations 2017 require operators to establish and maintain policies to manage effectively the risks of money laundering and terrorist financing. Officials found IMME's anti-money laundering policies were deficient as the investigation found:

Social responsibility failings

Social responsibility code provision 3.4.1 requires licensees to interact with customers in a way which minimises the risk of gambling-related harm. The investigation found that IMME’s social responsibility policies and practices generally failed to comply with this Code provision.

The review found IMME was unable to evidence social responsibility measures being implemented effectively and exhibited a lack of understanding of the requirements. Some examples are set out below:

Suitability concerns

The review found serious concerns regarding IMME’s suitability, including, but not limited to:

Extensive evidence of widespread breaches.

Failure to work with the Commission in an open and cooperative way including:

Concerns regarding IMME’s customer base and its marketing practices

Concerns regarding IMME’s business and financial structure. Officials found there was insufficient clarity between the two different products offered by IMME, both in terms of finances and governance

The monies for both The Lottery Centre and Lotteries.com were found not to be adequately segregated

Key persons demonstrated a lack of knowledge and understanding throughout the Commission’s engagement during assessments, meetings and the review

IMME’s customer records appeared to be inaccessible by members of staff, making informed responsible gambling interactions and internal decision making difficult. For example, paper customer records were stored at one location but were not accessible to IMME’s sales agents making marketing calls from other parts of the world. This is despite the fact IMME operated a remote business

The review found that there were multiple complaints to the police and Action Fraud about IMME’s products. Some complaints named the Lottery Centre but the Commission found that the complainant was actually a customer of the gambling product Lotteries.com, but were unaware what service they were actually paying for

In addressing one complaint, IMME accepted that its call centre agents did not use their real names. The Commission was deeply concerned that any of IMME’s staff might resort to using an alias since this significantly diminished trust in IMME and its methods. This also raised questions as to why a staff member might be told to or choose to be dishonest about their real name

Evidence of customers complaining of being called repeatedly by IMME sales agents, including one customer in her 90s who was called several times a week. Another complainant stated that a Lotteries.com customer was called every 30-40 minutes, five or six times until the phone was answered.

IMME appeared unwilling to accept that customers were making complaints about its products. IMME’s approach throughout the review was to discredit the complaints or complainants and question their integrity rather than to provide evidence to dispute statements of complainants.

Evidence from the National Trading Standards (NTS) Scams Team showed that many of IMME’s top 20 depositing customers were identified on an NTS database that identified consumers who have been targeted on multiple occasions and replied to mailings. Some of these customers were recorded by NTS as having been targeted by scammers on multiple occasions and also identified on known or convicted scammers’ data lists as replying. IMME claimed it had referred many of its top 20 depositing customers to the NTS itself, and it maintains that this explains the crossover between IMME customers and persons on the NTS’s database.

IMME not surrendered its operating licence

As a result of the above findings, had IMME not surrendered its operating licence, the Commission would have revoked its operating licence under section 117(1)(f) and section 119(1) of the Act.

In particular, the Commission considers the following conditions set out under section 120 (1) which applied to this case, namely:

In accordance with section 120(3) in considering a licensee's suitability for the purpose of subsection (1)(d) the Commission may, in particular, have regard to:

  1. the integrity of the licensee
  2. the competence of the licensee
  3. the financial and other circumstances of the licensee.

By reference to our Indicative sanctions guidance (June 2017) at section 2.29 we found that revocation would have been appropriate as the findings set out above demonstrated IMME was unsuitable to hold a licence for the following reason:

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:


Greentube Alderney Limited Public statement

Published: 2 December 2021

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.

Key failings

Operators are expected to consider the issues outlined 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 (the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:

This investigation resulted in the commencement of a section 116 regulatory review of Greentube Alderney Limited, (Greentube), Combined Remote Operating Licence number: 039050-R-319315-014. The Commission commenced its regulatory review on 16 December 2020.

The regulatory review found failings in Greentube’s processes which were aimed at preventing money laundering (ML) and protecting vulnerable people. These failings were found on two of Greentube’s casino and betting websites, admiralcasino.co.uk and bellfruitcasino.com.

Between December 2019 and November 2020 Greentube failed to comply with the Licence conditions and codes of practice (LCCP), specifically: 

Taking into account remedial action taken by Greentube and in line with our Statement of principles for licensing and regulation, Greentube will pay a total of £685,000 in lieu of a financial penalty.

The investigation and our subsequent regulatory review found:

Between December 2019 and November 2020 Greentube has been in breach of the following licence conditions and failed to comply with the following social responsibility code provisions.

Breach of paragraph 1 of license condition 12.1.1

Licence condition 12.1.1(1) 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.”

Greentube accepted its AML Risk assessment (the Risk Assessment) did not explicitly acknowledge:

Breach of paragraph 2 of license 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.”

Greentube accepted:

Breach of paragraph 3 of licence condition 12.1.1

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.”

Greentube accepted:

Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering Measures for operators based in foreign jurisdictions)

Paragraph 1 of this condition has been in place since October 2016 and requires that: “Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business.”

Greentube accepted it did not:

Greentube accepted it relied too heavily on ineffective threshold triggers and generally lacked information regarding how much a customer should be allowed to spend based on income, wealth or any other money laundering risk factors (Regulation 33 MLR 2017).

Breach of Paragraph 15 of Licence Condition 15.2.1 (Reporting key events)

A key event is an event that could have a significant impact on the nature or structure of a licensee’s business. Licence condition 15.2.1 requires licensees to notify the Commission, or ensure the Commission is notified, in such form or manner as the Commission may from time to time specify, of the occurrence of specified key events as soon as reasonably practicable and in any event within five working days of the licensee becoming aware.

Paragraph 24 licence condition 15.2.1, applicable at the time of the breaches, and currently paragraph 15 of licence condition 15.2.1, requires the reporting of the making of a disclosure pursuant to section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (a suspicious activity report). Under this key event, the Licensee should inform the Commission of the unique reference number issued by the United Kingdom Financial Intelligence Unit of the National Crime Agency in respect of each disclosure. The requirement to submit this key event within the five working day period referred to above runs from the licensee’s receipt of the unique reference number. The licensee should also indicate whether the customer relationship has been discontinued

Greentube accepted that they failed to submit key events to the Commission within 5 working days of submission of six suspicious activity reports (SARs) to the National Crime Agency.

Failure to comply with Paragraph 1 and 2 of social responsibility code provision (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:

  1. identifying customers who may be at risk of or experiencing harms associated with gambling.
  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.
  1. Licensees must take into account the Commission’s guidance on customer interaction.”

Greentube accepted that:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors

Good practice

Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions:


VGC Leeds Limited Public statement

Published: 13 October 2021

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.

Key failings

Safer Gambling:

Anti-Money Laundering:

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.

Introduction

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

This case concerns VGC Leeds Limited t/a Victoria Gate Casino (VGC) which holds non-remote casino and ancillary remote casino operating licences.

The Commission investigated VGC’s handling of 10 customers following concerns identified at a compliance assessment in July 2019.

Our investigation identified failings in the way VGC identified and managed customers who were at higher risk of money laundering and gambling-related harm. These failings stemmed from VGC failing to effectively implement its anti-money laundering (AML) and safer gambling policies and procedures.

On 24 October 2019, we gave VGC notice that we were commencing a review of its operating licence. That review revealed VGC had breached conditions of its operating licence.

VGC cooperated with our enquiries throughout the course of our investigation and has accepted that the implementation of its policies and procedures in respect of AML and safer gambling were not effective. It has accepted that it failed to act in accordance with conditions of its operating licence between January 2017 and July 2019.

In line with our Statement of principles for licensing and regulation, VGC will pay £241,000 to represent divestment of the amount of financial gain accrued as a result of the accepted failings, and £209,000 in lieu of a financial penalty. It will also pay Commission costs of £21,578.17.

Social responsibility code provision (SRCP) 3.4.1

Social responsibility code 3.4.1 stated (at the time it was in place) that:

‘Licensees must put into effect policies and procedures for customer interaction where they have concerns that a customer’s behaviour may indicate problem gambling. The policies must include:

Our investigation identified weaknesses in VGC’s safer gambling controls and found it had failed to effectively implement its policies and procedures for customer interaction. Furthermore, VGC failed to make use of all relevant sources of information to ensure effective decision making and to guide effective customer interactions, contrary to SRCP 3.4.1, paragraph 1(e)(i).

Examples of social responsibility failings include:

Failure to implement effective AML controls

Licence condition 12.1.1 relates to the Prevention of Money Laundering and Terrorist Financing

Licence condition 12.1.1(3) requires:

VGC has accepted weaknesses and shortcomings in the relation to the implementation of some of its procedures and controls.

During the investigation we identified VGC had failed to undertake sufficient checks to verify the underlying source of the customer funds in some instances.

Examples of AML failings include:

In addition to accepting these failings, VGC has committed to an ongoing programme of improvements to ensure the implementation of its policies, procedures and controls are effective including, but not limited to, the following specific remedial action:

This regulatory settlement consists of:

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

Aggravating factors

Mitigating factors