Mackrill Edward William
Following a licence review, the Commission decided to issue Mr Edward Mackrill with a warning under section 117(1)(a) of the Gambling Act 2005.
The reason for this decision was because, as a Personal Management Licence holder, responsible for regulatory compliance and as the MLRO at BGO Limited (BGO), he failed to take all reasonable steps to ensure that the way in which he carried out his responsibilities in relation to licensed activities did not place BGO in breach of their licence. In particular:
- Breach of licence condition 12.1.1(1), (2), and (3)Anti-money laundering -Prevention of money laundering and terrorist financing
- Breach of licence condition 12.1.2 Anti-money laundering –Measure for operators based in foreign jurisdictions
- Failure to comply with social responsibility code provision 3.4.1(1)(e), relevant at the time of the failings-Customer interaction. Compliance with a social responsibility code of practice is a condition of the licence.
In reaching our decision we concluded Mr Mackrill was not solely accountable for the failings within the business.Mr Mackrill has been open and transparent throughout our engagements with him.