McDowell David Michael
Following review of Mr David Michael McDowell’s Personal Management Licence (“PML”), the Commission found he breached paragraph 1 and 2 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 and issued him with a warning under Section 117(1)(a) of the Gambling Act 2005.
As PML holder, with primary responsibility for the overall strategy and delivery at FSB Technologies (UK) Limited (“FSB"), he failed to ensure FSB:
- had appropriate policies, procedures and controls to prevent money laundering and terrorist financing (Licence condition 184.108.40.206) and that such policies, procedures and controls were implemented effectively, kept under review and revised appropriately (Licence condition 220.127.116.11)
- adhered to Licence condition 16.1.1 (Responsible placement of digital adverts)
- complied with the requirements of social responsibility code provision 3.4.1 (Customer interaction).
- Complied with the requirements of social responsibility code provision 3.5.3 (Self-exclusion)
In addition, we found that Mr McDowell had failed to ensure that FSB carried out sufficient due diligence on its third-party partners.
In reaching our decision we concluded that Mr McDowell was not solely accountable for the failings within the business. Mr McDowell accepted at an early stage of our investigation; he has been open, transparent and co-operative throughout the engagement with the Commission.