Cronje Izak Stephanus
Following a licence review, the Commission decided that it was appropriate to issue Mr Izak Cronje 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 overall management and direction at Daub Alderney Limited (Daub), Mr Cronje failed to ensure Daub:
- 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 and such policies, procedures and controls were implemented effectively, kept under review and revised appropriately in breach of Licence condition 188.8.131.52;
- 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 licence on 1 November 2014 and Licence Condition 12.1.2 Anti money laundering measures for operators based in foreign jurisdictions;
- 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, and;
- complied with the requirement of social responsibility code SR code 6.1.1 to have a Complaints and disputes procedure issued under Section 24 Gambling Act 2005 to be treated as a Licence Condition
In reaching our decision we concluded that Mr Cronje was not solely accountable for the failings which were systemic within the business. Mr Cronje has been open and transparent throughout the engagement and has since Daub’s corporate evaluation made a significant contribution to improving its regulatory compliance.