Mangion Pierre Etienne
Following a licence review, the Commission decided that it was appropriate to issue Mr Pierre Mangion with a warning under section 117(1)(a) of the Gambling Act 2005.
The Commission determined that Mr Mangion failed to comply with the general condition of his Personal management licence (PML), namely Part III, condition 1, suite of general conditions attached to his personal licence under 75 of the Act.
The reason for this decision was because, as a Personal Management Licence holder and the Money Laundering Reporting Officer and Head of Regulatory Compliance at CZ Holdings Limited, Mr Mangion failed to ensure CZ Holdings Limited complied with the conditions attached to its operating licence, in particular:
- paragraphs 1,2 and 3 of the licence condition 12.1.1 (Anti-money laundering – prevention of money laundering and terrorist financing)
- the individual licence condition attached to its operating licence on 1 November 2014 to comply with the Money Laundering Regulations as amended.
- paragraph 1 of the licence condition 12.1.2 - Anti money laundering measures for operators based in foreign jurisdictions
- 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 by virtue of section 82(1) of the Act.
As a result, Mr Mangion breached Licence Condition 1 of his personal management licence, contained at Part 3 of the Licence conditions and codes of practice.
In reaching our decision we concluded that Mr Mangion was not solely accountable for the failings which were systemic within the business. Mr Mangion has been open and transparent throughout the engagement and has, since CZ Holdings’ July 2017 compliance assessment, contributed to improving its regulatory compliance and in addition undertaken training in respect of developing his knowledge.