Houareau Jean-Pierre Georges
Following a licence review, the Commission decided to issue Mr Jean Pierre Houareau with a warning under section 117(1)(a) of the Gambling Act 2005.
The reason for this decision is as a Personal Management Licence holder whilst holding the specified management office of providing PT Entertainment Services (PTES) with ‘overall management and direction of the licensee’s business or affairs, Mr Jean Pierre Houareau failed to ensure:
- that between October 2016 and 4 February 2017 a risk assessment in relation to money laundering and terrorist financing was in place at PTES as required by paragraph 1 of Licence Condition 12.1.1.
- that between October 2016 and 4 February 2017 PTES had in place appropriates policies, procedures, and controls to prevent money laundering and terrorist financing, following and having regard to a risk assessment. A breach of this licence condition occurred as a result of no proper risk assessment being in place at the time as required by Paragraph 3 of Licence Condition 12.1.1.
- that PTES policies, procedures and controls were implemented effectively, kept under review, revised appropriately to ensure they remained effective, and take into account any applicable learning or guidance issued by the commission from time to time as required by paragraph 3 of Licence Condition 12.1.1.
- compliance with the requirements for PTES to conduct ongoing monitoring of a business relationship (which included scrutinising the transactions undertaking by a customer throughout the course of the relationship including their source of funds.
- sufficient oversight to ensure that PTES put into effect policies and procedures for customer interaction where they had concerns that a customer’s behaviour may indicate problem gambling, with specific provision for those designated as high value or VIP customers.
In reaching our decision we concluded that Mr Houareau was not solely accountable for the failings within the business.
Mr Houareau has been open and transparent throughout our engagement with him.