Ferguson Ross Alastair
Following a licence review, the Commission decided that it was appropriate to issue Mr Ross Ferguson 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 and the Money Laundering Reporting Officer at Silverbond Enterprises Limited, Mr Ross Ferguson failed to ensure Silverbond:
- complied with the requirement to complete a risk assessment as required by Licence condition 12.1.1 - Anti-money laundering - Prevention of money laundering and terrorist financing;
- had appropriate policies, procedures and controls to prevent money laundering and terrorist financing in breach of Licence condition 126.96.36.199
- put into effect adequate anti-money laundering controls such that it complied with the Money Laundering Regulations 2007 and 2017 as required by the Licence condition attached to the operating licence on 6 June 2016
- complied with the requirements of social responsibility Code 3.4.1 Customer interaction code of practice issued under Section 24 Gambling Act 2005 to be treated as a Licence Condition.
- Complied with ordinary code provision 2.1.1. to help prevent activities related to ML and terrorist financing. Licensees are also expected to act in accordance with the Commission’s guidance on AML.
In reaching our decision we concluded that Mr Ferguson was not solely accountable for the failings which were systemic within the business. Mr Ferguson has been open and transparent throughout his engagement with the Commission. In addition, Mr Ferguson will be required to undertake training in respect of developing his knowledge of the Commission compliance requirements’