Firth James Robert
Following a licence review, the Commission decided to issue Mr James Robert Firth 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 whilst employed by Caesars Entertainment UK Limited (CEUK) with oversight of the day to day management of a single set of premises, Mr Firth failed to ensure:
- the licensed entity had appropriate policies, procedures and controls to prevent money laundering and terrorist financing in breach of licence condition 220.127.116.11
- policies, procedures and controls were implemented effectively, kept under review and revised appropriately ensuring they remained effective, taking into account any applicable learning or guidelines published by the Gambling Commission, in breach of licence condition 18.104.22.168
- compliance with the requirements of social responsibility code provision 3.4.1 (Customer interaction) relevant at the time of the failings.
In reaching our decision we concluded that Mr Firth was not solely accountable for the failings which were systemic within the business.
Mr Firth has been open and transparent throughout our engagement with him.