WHG (International) Limited
This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of WHG (International) Limited (the Licensee/WHG).
The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling and preventing Money Laundering (ML).
Between May 2020 and 18 October 2021, WHG failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:
- licence condition 2.3.1 (Remote Technical Standards)
- paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the conducting of an appropriate risk assessment, the implementation of appropriate policies and procedures and keeping such policies under review to ensure their effectiveness, all with the objective of preventing ML and Terrorist Financing (TF)
- licence condition 12.1.2 requiring remote casino operators based in foreign jurisdictions to comply with the ML, TF and Transfer of Funds (Information of the Payer) Regulations 2017.
- paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction
- paragraphs 1a, 1c and 1d of SRCP 3.7.1 (Provision of Credit)
- paragraph 2 of SRCP 3.9.1 requiring licensees to put into effect policies and procedures designed to identify separate accounts which are held by the same individual and where customers hold more than one account, the Licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each other.
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.
More information about this case can be found on the Commission's website, here: WHG (International) Limited Public Statement (gamblingcommission.gov.uk)