Wilson Simon Robert
Following a section 116 review of Mr Simon Robert Wilson’s Personal Management Licence (“PML”), which commenced in July 2019, the Commission determined the Licensee breached paragraph 1 and 2 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 and issued him with a warning under Section 117(1)(a) of the Gambling Act 2005.
As PML holder, with primary responsibility for the overall management and direction at In Touch Games Limited (“ITG"), the Licensee failed to ensure ITG:
- had an appropriate money laundering risk assessment in place (12.1.1 (1))
- had appropriate policies, procedures and controls to prevent money laundering and terrorist financing (Licence condition 12.1.1(2)) and that such policies, procedures and controls were implemented effectively, kept under review and revised appropriately (Licence condition 12.1.1.(3)
- complied with the requirements of social responsibility code provision 3.4.1 (Customer interaction).
In reaching our decision we concluded that Mr Wilson was not solely accountable for the failings within the business. Mr Wilson accepted at an early stage of our investigation; he has been open, transparent and co-operative throughout the engagement with the Commission. In addition, we took into account that Mr Wilson has voluntarily undertaken AML and social responsibility training.