Following a review of the licence issued to Bestbet Limited (the Licensee), the Commission found the Licensee:
- breached conditions of its licence relating to anti-money laundering measures licence conditions 12.1.1 and 12.1.2
- failed to comply with social responsibility code provisions 3.4.1 and 3.4.1(e)
In line with the Commission's Licensing, compliance and enforcement policy statement, the Indicative sanctions guidance and the Statement of principles for determining financial penalties, the Commission has decided to:
- issue a warning under section 117(1)(a) of the Gambling Act 2005 (the Act);
- impose additional conditions to the Licensee's operating licence under section 117(1)(b) of the Act; and
- impose a financial penalty under section 121 of the Act in the sum of £230,972.
The reason for this decision was because the Licensee failed to:
- comply with the requirement to conduct an assessment of the risks to its business being used for money laundering and terrorist financing as required by Licence condition 12.1.1(1) - Anti-money laundering - Prevention of money laundering and terrorist financing
- establish and maintain appropriate risk-sensitive policies, procedures and controls relating to the management of its customers in order to prevent activities related to money laundering as required by Licence condition 12.1.1(2)
- ensure that such policies, procedures and controls were implemented effectively, kept under review and revised appropriately as required by Licence condition 12.1.1(3)
- put into effect adequate anti-money laundering controls that complied with the Money Laundering Regulations 2007 and 2017 as required by Licence condition 12.1.2 Anti-money laundering measures for operators based in foreign jurisdictions
- comply with the requirement to comply with social responsibility code 3.4.1. Compliance with an SRCP is a condition of the licence by virtue of section 82(1) of the Act.
The failings were systemic within the business but since the Licensee's assessment, it has proactively put remedial provisions in place to mitigate the risk to the licensing objectives.
More information can be found in the Commission's public statement.