Regulatory actions

DK Crown Holdings Inc

Following an investigation into a key event submission by DK Crown Holdings Inc (“the Licensee”), the Gambling Commission (“the Commission”) found that the Licensee breached:  

• Social Responsibility Code Provision (“SRCP”) 3.5.3(1) – Self-exclusion  

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”).

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Statement of principles for determining financial penalties, the Commission has decided to impose a financial penalty of £28,750 under section 121(1) of the Act.

Commission Officials note that the Licensee identified the breach and proactively reported it to the Commission. The Licensee took immediate remedial action to address the identified issues and co-operated with the Commission throughout the investigation. The Commission also notes that the SRCP breach relates to a specific exceptional issue and that the Licensee’s self-exclusion procedures, in general, continued to operate.

Goode Michael Edward

Following a licence review of Mr Michael Goode’s Personal Management Licence (“PML”), the Commission determined the Licensee breached paragraphs 1 and 2 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) and issued him with a warning under section 117(1)(a) of the Act.  

 As a PML holder acting as Chief Financial Officer (“CFO”) and board member for Eaton Gate Gaming Limited “(the Licensed Entity”), with responsibility for evaluating, development, growth and direction of the Licensed Entity’s business or affairs, Mr Goode failed to take all reasonable steps to ensure the Licensed Entity’s compliance with: 

• paragraph 1 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) between October 2020 and 24 May 2021
• paragraphs 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) from October 2020 until updated processes came into effect in February 2021
• paragraph 1(b) of Social Responsibility Code of Practice (“SRCP”) 3.4.1 – Customer Interaction from August 2020 until May 2021
• paragraph 1(c) of SRCP 3.4.1 – Customer Interaction from August 2020 until February 2021
• paragraph 2 of SRCP 3.4.1 – taking into account the Commissions guidance on Customer Interaction from 12 May 2020 to 6 May 2021.  

An assessment of the Licensed Entity was undertaken in January 2021. The review of the Licensed Entity commenced in July 2021 and concluded in December 2022.

Mr Goode has been open and transparent throughout our engagement with him.

Lee Charles Nicholas

Following a licence review of Mr Charles Lee’s Personal Management Licence (“PML”), the Commission determined the Licensee breached paragraphs 1 and 2 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) and issued him with a warning under section 117(1)(a) of the Act.

As a PML holder acting as Chief Executive Officer (“CEO”) for Eaton Gate Gaming Limited (“the Licensed Entity”), with responsibility for overall management and direction of the Licensed Entity’s business or affairs, Mr Lee failed to take all reasonable steps to ensure the Licensed Entity’s compliance with:

• paragraph 1 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) between October 2020 and 24 May 2021
• paragraphs 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) from October 2020 until updated processes came into effect in February 2021
• paragraph 1(b) of Social Responsibility Code of Practice (“SRCP”) 3.4.1 – Customer Interaction from August 2020 until May 2021
• paragraph 1(c) of SRCP 3.4.1 – Customer Interaction from August 2020 until February 2021
• paragraph 2 of SRCP 3.4.1 – Customer Interaction from 12 May 2020 to 6 May 2021
• paragraph 2 of SRCP 5.1.9 - Other marketing requirements from January 2021 to 1 March 2021.

An assessment of the Licensed Entity was undertaken in January 2021. The review of the Licensed Entity commenced in July 2021 and concluded in December 2022.  

Mr Lee has been open and transparent throughout our engagement with him.

888 UK Limited

Following an investigation into a key event submission by 888 UK Limited trading as 888 (“the Licensee”), the Commission found that the Licensee:  

• breached licence condition (“LC”) 6.1.2 – Use of Credit Cards.  

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Statement of principles for determining financial penalties, the Commission has decided to:  

• impose a financial penalty of £23,000 under section 121(1) of the Act.  

Commission Officials note that the Licensee self-identified the breach and proactively reported it to the Commission. The Licensee took immediate remedial action to address the identified failings and co-operated with the Commission throughout the investigation.

Curley Matthew Christopher

Following a licence review, the Commission determined to revoke the Personal Functional Licence (PFL) of Mr Matthew Christopher Curley (the Licensee) under the provisions of section 119 of the Gambling Act 2005 (the Act). The Commission found;

• the circumstances of the issue leading to the Licensee’s dismissal are inconsistent with the first licensing objective of preventing gambling being a source of crime or disorder, being associated with crime or disorder, or being used to support crime
• the Licensee failed to advise the Commission of his dismissal for gross misconduct, which is a breach of their licence
• the Licensee failed to cooperate with the Commission during the course of the licence review,

Jungle X UK Limited

Following a review of the operating licence undertaken in relation to Jungle X UK Limited, trading as Jungle (the Licensee), the Gambling Commission (the Commission) found that the Licensee:  

• breached paragraphs 1, 2 and 3 of Licence condition 12.1.1: Anti-money laundering - Prevention of money laundering and terrorist financing
• breached Licence condition 15.2.1: Reporting key events
• breached Licence condition 7.1.1: Fair and transparent terms and practices
• failed to comply with paragraphs 1,4,5 and 7 of Social Responsibility Code Provision (SRCP) 3.4.3: Customer interaction.
• failed to comply with Social Responsibility Code Provision (SRCP) 3.2.11: Remote SR Code
• failed to comply with Social Responsibility Code Provision (SRCP) 5.1.1: Rewards and Bonuses
• failed to comply with Social Responsibility Code Provision 4.1.1: Fair Terms
• failed to comply with Social Responsibility Code Provision 6.1.1: Complaints and Disputes.  

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:  

1. give a warning under section 117 (1) (a) of the Gambling Act 2005 (the Act)
2. impose a financial penalty of £11,550.00 under section 121 (1) of the Act.

The Licensee acted promptly and responded quickly to the Commission’s requests in this case.

Moir Philip Keith Walker

Following a licence review of Mr Philip Walker Moir’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) between May 2020 and October 2021 and issued him with a warning under section 117(1)(a) of the Act.  

As the PML holder acting as Managing Director for licensed operators WHG (International) Limited (as at May 2020), Mr Green Limited (as at May 2020) and William Hill Organization Limited (as from September 2020)  (the “Operating Licensees”), with the responsibility for the Operating Licensees’ overall management and direction of business or affairs, Mr Moir failed to take all reasonable steps to ensure that the way in which he carried out his responsibilities in relation to licensed activities did not place the Operating Licensees in breach of their licence conditions, namely:  

WHG (International) Limited:  

• Licence condition 12.1.1, paragraphs 1, 2 and 3 - Anti-money laundering - Prevention of money laundering and terrorist financing
• Licence condition 12.1.2 – AML - Measure for operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017
• Licence condition 2.3.1, paragraph 1 – Remote Technical Standards
• SRCP 3.4.1 – Customer Interaction

Mr Green Limited:  

• Licence condition 12.1.1, paragraphs 1, 2 and 3 - Anti-money laundering - Prevention of money laundering and terrorist financing
• Licence condition 12.1.2 – AML - Measure for operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017
• SRCP 3.4.1 – Customer Interaction

William Hill Organization Limited:  

• Licence condition 12.1.1, paragraphs 1,2 - Anti-money laundering - Prevention of money laundering and terrorist financing

Mr Moir has been cooperative, open and transparent throughout our engagement with him.

GiveCircle Limited

Following a licence review of the operating licence of ImpulsePay Limited (“The Licensee”), the Commission found that the Licensee breached:

• Licence Condition 2.3.1 (Technical Standards) In line with the Commission’s Licensing, compliance and enforcement policy statement and the Indicative sanctions guidance, the Commission has decided to impose a formal warning under section 117)1) (a) of the Act.

Officials acknowledge that the Licensee co-operated with the Commission throughout the investigation and took swift and corrective steps to address further failings.

Hillside (UK Gaming) ENC

The Gambling Commission commenced a section 116 regulatory review of Hillside (UK Gaming) ENC (the Licensee) - Remote Bingo and Casino Operating Licence Number 055149- R-331499-002 - following a compliance assessment conducted in March 2022.

The regulatory review found failings in the Licensee’s processes aimed at preventing Money Laundering (ML) and protecting individuals from being harmed or exploited by gambling.

The Licensee failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

• paragraph 2 of licence condition 12.1.1, requiring operators to comply with the prevention of ML and Terrorist Financing (TF), between May 2021 and July 2022
• licence condition 12.1.2, requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (the 2017 Regulations), between May 2021 and July 2022
• paragraphs 1b and 1c of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, between October 2021 and September 2022.

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will pay a total of £343,035 in lieu of a financial penalty.

More information about this case can be found in our public statement on the Commission's website: Hillside (UK Gaming) ENC Public Statement

Hillside (UK Sports) ENC

The Gambling Commission commenced a section 116 regulatory review of Hillside (UK Sports) ENC (the Licensee) - General Betting Standard - Real Event, General Betting Standard - Virtual Event, and Pool Betting – Remote, Licence Number 055148-R-331498-001 - following a compliance assessment conducted in March 2022.

The regulatory review found failings in the Licensee’s processes aimed at preventing Money Laundering (ML) and protecting individuals from being harmed or exploited by gambling.

The Licensee failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

• paragraph 2 of licence condition 12.1.1, requiring operators to comply with the prevention of ML and Terrorist Financing (TF), between May 2021 and July 2022
• paragraphs 1b and 1c of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, between October 2021 and September 2022.

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will pay a total of £239,085 in lieu of a financial penalty.

More information about this case can be found in our public statement on the Commission's website: Hillside (UK Sports) ENC Public Statement

Meckenzie Roy

Following a licence review of Mr Roy Meckenzie’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) and issued him with a warning under section 117(1)(a) of the Act.

As a PML holder acting as Chief Executive Officer (“CEO”) for Blue Star Planet Limited (“the Licensed Entity”), with responsibility for overall management and direction of the Licensed Entity’s business or affairs, Mr Meckenzie failed to take reasonable steps to ensure the Licensed Entity’s compliance with: 

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring compliance with the prevention of money laundering and terrorist financing 
• licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (the 2017 Regulations) 
• paragraph 1a of licence condition 8.1.1, requiring licensees providing facilities for remote gambling to display on every screen from which customers are able to access gambling facilities provided in reliance on this licence a statement that they are licensed and regulated by the Gambling Commission 
• paragraphs 1b, 1c and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction. 

Mr Meckenzie has been open and transparent throughout our engagement with him.

Dikov Valentin Bonchev

Following a licence review of Mr Valentin Dikov’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) and issued him with a warning under section 117(1)(a) of the Act.

As a PML holder acting as Head of Compliance and the Money Laundering Reporting Officer (“MLRO”) for Blue Star Planet Limited (“the Licensed Entity”), with overall responsibility for providing the Licensed Entity with its gambling regulatory compliance as head of that function, Mr Dikov failed to take reasonable steps to ensure the Licensed Entity’s compliance with:

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring compliance with the prevention of money laundering and terrorist financing
• licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (the 2017 Regulations)
• paragraph 1a of licence condition 8.1.1, requiring licensees providing facilities for remote gambling to display on every screen from which customers are able to access gambling facilities provided in reliance on this licence a statement that they are licensed and regulated by the Gambling Commission 
• paragraphs 1b, 1c and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction. 

Mr Dikov has been open and transparent throughout our engagement with him.

FSB Technology (UK) Limited

Following an investigation outside of a licence review, the Gambling Commission (“the Commission”) found that FSB Technology (UK) Limited (“the Licensee”), at a time when the Licensee held a combined remote operating licence, breached: 

• Licence condition 12.1.1 - paragraphs 1, 2 and 3: Anti-money laundering - Prevention of money laundering and terrorist financing
• Licence condition 7.1.1, paragraph 1: Fair and transparent terms and practices
• The Licensee also failed to comply with SRCP 3.4.1 paragraphs 1a, b, c and 2: Customer Interaction. 

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”).

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Statement of principles for determining financial penalties, the Commission has decided to impose a financial penalty of £29,237 under section 121(1) of the Act.

Commission Officials note the immediate remedial action taken by the Licensee and acknowledge that the Licensee has co-operated with the Commission throughout the investigation. Commission Officials also note the Licensee ceased providing B2C services in May 2022.

Hoskin Robert Grant

Following a licence review of Mr Robert Hoskin’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) between December 2019 and October 2020 and issued him with a warning under section 117(1)(a) of the Act.

As the PML holder acting as Group Director of Legal, Regulatory and Secretariat for licensed operators Ladbrokes Betting and Gaming Limited and LC International Limited (the “Operating Licensees”) , with the responsibility for the Operating Licensees’ legal, compliance, regulatory affairs and company secretariat functions, Mr Hoskin failed to take all reasonable steps to ensure that the way in which he carried out his responsibilities in relation to licensed activities did not place the Operating Licensees in breach of their licence conditions, namely:

Ladbrokes Betting and Gaming Limited:

• Licence condition 12.1.1, paragraphs 2 and 3 – Anti-money laundering-Prevention of money laundering and terrorist financing
• Social responsibility code provision (SRCP) 3.4.1 – Customer interaction

LC International Limited:

• Licence condition 12.1.1, paragraphs 1 – Anti-money laundering-Prevention of money laundering and terrorist financing
• Social responsibility code provision (SRCP) 3.4.1 – Customer interaction

Mr Hoskin has been cooperative, open and transparent throughout our engagement with him.

Buttigieg Paul

Following a licence review of Mr Paul Buttigieg’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) between December 2019 and October 2020 and issued him with a warning under section 117(1)(a) of the Act.

As the PML holder acting as Director of Anti-money Laundering and Money Laundering Reporting Officer for licensed operators Ladbrokes Betting and Gaming Limited and LC International Limited (the “Operating Licensees”), Mr Buttigieg failed to take all reasonable steps to ensure that the way in which he carried out his responsibilities in relation to licensed activities did not place the Operating Licensees in breach of their licence conditions, namely:

Ladbrokes Betting and Gaming Limited:

• Licence condition 12.1.1, paragraphs 2 and 3 – Anti-money laundering-Prevention of money laundering and terrorist financing

LC International Limited:

• Licence condition 12.1.1, paragraphs 1,2 and 3 – Anti-money laundering-Prevention of money laundering and terrorist financing
• Licence condition 12.1.2 - Anti-money laundering – Measures for operators based in foreign jurisdictions 

Mr Buttigieg has been cooperative, open and transparent throughout our engagement with him.

Reynolds Simon Ashley

Following a licence review of Mr Simon Reynolds’ Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) between December 2019 and October 2020 and issued him with a warning under section 117(1)(a) of the Act. 

As the PML holder acting as UK Director of Compliance for licensed operators Ladbrokes Betting and Gaming Limited and LC International Limited (the “Operating Licensees”), responsible for the management of the Operating Licensees’ compliance functions in the UK, Mr Reynolds failed to take all reasonable steps to ensure that the way in which he carried out his responsibilities in relation to licensed activities did not place the Operating Licensees in breach of their licence conditions, namely: 

Ladbrokes Betting and Gaming Limited: 

• Licence condition 12.1.1, paragraphs 2 and 3 – Anti-money laundering - Prevention of money laundering and terrorist financing 
• Social responsibility code provision 3.4.1, paragraphs 1 and 2 – Customer interaction  

LC International Limited:  

• Social responsibility code provision 3.4.1, paragraphs 1 and 2 – Customer interaction  

Mr Reynolds has been cooperative, open and transparent throughout our engagement with him. 

Banbury Neil Thomas

Following a licence review of Mr Neil Banbury’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) and issued him with a warning under section 117(1)(a) of the Act.  

As a PML holder acting as General Manager for 32Red Limited (32Red) and Platinum Gaming Limited (PGL), with responsibility for overall management and direction of the licensee’s business or affairs and marketing, Mr Banbury failed to take reasonable steps to ensure:

• 32Red and PGL’s compliance with the requirements of paragraphs 1 and 2 of social responsibility code of practice 3.4.1.(Customer Interaction).  
• 32Red and PGL had appropriate policies, procedures, and controls to prevent money laundering and terrorist financing and that these were effective in breach of licence condition 12.1.1 and 12.1.2.
• PGL’s compliance with requirements of SRCP 3.9.1 (Identification of individual customers)  

Mr Banbury has been open and transparent throughout our engagement with him.

Cook Timothy Simon Stuart

Following a licence review of Mr Timothy Cook’s Personal Management Licence (PML), the Commission determined the Licensee breached paragraph 1 of the general conditions attached to personal licences under Section 75 of the Gambling Act 2005 (the Act) and issued him with a warning under section 117(1)(a) of the Act.

As the PML holder acting as the Head of Regulatory Compliance, Money Laundering Reporting Officer (MLRO), and General Counsel of 32Red Limited (32Red) and Platinum Gaming Limited (PGL), Mr Cook failed to take reasonable steps to ensure:

1. 32Red’s compliance with the requirements of:

• a. Licence condition 12.1.1, paragraphs 2 and 3 – Anti-money laundering-Prevention of money laundering and terrorist financing 
• b. Licence condition 12.1.2 – AML-Measures for operators in foreign jurisdictions 
• c. Social responsibility code provision (SRCP) 3.4.1 – Customer interaction 

2. PGL’s compliance with the requirements of:

• a. Licence condition 12.1.1, paragraphs 1, 2 and 3 – Anti-money laundering-Prevention of money laundering and terrorist financing 
• b. Licence condition 12.1.2 – AML-Measures for operators in foreign jurisdictions 
• c. Social responsibility code provision (SRCP) 3.4.1 – Customer interaction 
• d. SRCP 3.9.1 – Identification of individual customers

Mr Cook has been open and transparent throughout our engagement with him.

Templeman Stephen Francis

Following a licence review, Mr Steven Templeman’s Personal Management Licence (PML / the Licensee) the Commission determined the Licensee breached paragraph 1 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 (the Act).

As a Personal Management Licence holder employed by TGP Europe Limited (TGP) as the Money Laundering Reporting Officer (MLRO) and Director of strategic growth, Mr Templeman failed to take reasonable steps to ensure TGP’s compliance with the requirements of paragraph 2 of social responsibility code provision 3.4.1 (Customer interaction) relevant at the time of the failings. Mr Templeman also failed to take reasonable steps to ensure TGP Europe Limited had appropriate policies, procedures, and controls to prevent money laundering and terrorist financing in breach of licence condition 12.1.1 and 12.1.2.  

Mr Templeman has been open and transparent throughout our engagement with him.

Munro Neil Alan

Following a licence review of Mr Neil Alan Munro’s Personal Management Licence (PML / the Licensee), the Commission determined the Licensee breached paragraph 1 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 (the Act).

As a Personal Management Licence holder employed by TGP Europe Limited (TGP) with responsibility for regulatory compliance, Mr Munro failed to take reasonable steps to ensure TGP’s compliance with the requirements of paragraph 2 of social responsibility code provision 3.4.1 (Customer interaction) relevant at the time of the failings. Mr Munro also failed to take reasonable steps to ensure TGP had appropriate policies, procedures, and controls to prevent money laundering and terrorist financing in breach of licence condition 12.1.1 and 12.1.2.  

Mr Munro has been open and transparent throughout our engagement with him.

SCHLEP Games, Inc.

Following a review of the operating licence of Schlep Games, Inc. (“the Licensee”), the Commission found that the Licensee:  

• failed to comply with Social Responsibility Code Provision (SRCP) 3.5.5 which states: “Licensees must participate in the national multi-operator self-exclusion scheme.”

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”).

In particular, the Commission found that the Licensee, between 17 January and 21 March 2023, failed to register with GAMSTOP, the national multi-operator self-exclusion scheme. 

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Indicative sanction guidance, the Commission has decided to impose a formal warning under section 117 (1)(a) of the Act. 

Officials acknowledge that the Licensee co-operated with the Commission throughout the investigation and took swift and effective corrective steps to address the identified failings.

SCHLEP Games, Inc.

Following a section 116 regulatory review of the operating licence of Schlep Games, Inc. (“the Licensee”), the Commission found that the Licensee:

• failed to comply with Licence Condition 2.3.1 (Technical Standards), which states: “Licensees must comply with the Commission’s technical standards and with the requirements set by the Commission relating to the timing and procedures for testing.” 

In particular, the Commission found that the Licensee, between 21 April 2023 and 25 September 2023 had inadequate information security Controls, policies and procedures. 

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Indicative sanction guidance, the Commission has decided to impose a formal warning under section 117 (1)(a) of the Gambling Act 2005. 

Officials acknowledge that the Licensee co-operated with the Commission throughout the investigation and took swift and effective corrective steps to address the identified failings.

Leisure Electronics Limited

Following a review of the operating licence of Leisure Electronics Limited (“the Licensee”), the Commission found that the Licensee:

• failed to comply with Social Responsibility Code Provision 3.5.5 (Remote Multi-Operator SR code), which states: 

“Licensees must participate in the national multi-operator self-exclusion scheme.”

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”)

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Indicative sanction guidance, the Commission has decided to impose a formal warning under section 117 (1)(a) of the Act.

The Licensee co-operated with the Commission throughout the investigation and took steps to address the identified failings.

Gamesys Operations Limited

Following a review of the operating licence of Gamesys Operations Limited (the Licensee), the Commission found that between November 2021 and July 2022 the Licensee:  

1. breached paragraph 2 of licence condition 12.1.1 Anti Money Laundering (AML) – prevention of money laundering and terrorist financing;  
2. breached paragraph 1 of licence condition 12.1.2 AML – measures for operators based in foreign jurisdictions;  
3. failed to comply with paragraphs 1 and 2 of Social Responsibility Code of Practice (SRCP) 3.4.1 – customer interaction; and,  
4. non-adherence to Ordinary Code Provision (OCP) 2.1.1 AML – Commission guidance for remote and non-remote casinos.  

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:  

• impose a warning under section 117 (a) of the Gambling Act 2005 (the Act);  
• impose a total financial penalty of £6,071,292 (which includes a divestment amount of £165,042), in respect of the Findings 1-3 above; and,
• attach an additional condition to the Licensee’s operating licence under section 117(1)(b) of the Act.  

The Licensee co-operated with the Commission throughout the investigation and advised that it had taken corrective steps.  The Commission found no evidence of criminal monies being deposited by the specific customers looked at during its review.

Kalooki Sportsbook Limited

Following a review of the operating licence of Kalooki Sportsbook Limited (“the Licensee”), the Commission found that the Licensee:  

• failed to comply with Licence Condition 2.3.1 (Technical Standards), which states: “Licensees must comply with the Commission’s technical standards and with requirements set by the Commission relating to the timing and procedures for testing.”  

In particular, the Commission found that the Licensee, between 28 March 2022 and 7 February 2023, had inadequate information security facilities, policies and procedures.  

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Indicative sanction guidance, the Commission has decided to impose a formal warning under section 117 (1)(a) of the Act.  

Officials acknowledge that the Licensee co-operated with the Commission throughout the investigation and took swift and effective corrective steps to address the identified failings.

Geelen Antonius Paul

Following a licence review, the Commission have determined to revoke the Personal Functional Licence (PFL) of Mr Antonius Paul Geelen (“the Licensee”) under section 119(1) of the Gambling Act 2005 (the Act).

The Commission found the Licensee:

• breached a condition of his personal licence, in that he failed to notify the Commission within 10 working days of a number of key events, namely
  • his subjection to a criminal investigation which is listed under Schedule 7 - Relevant Offences of the Gambling Act 2005
  • his conviction of an offence listed under Schedule 7 – Relevant Offences of the Gambling Act 2005.
  • his resignation from a position for which a personal licence is required following commencement of disciplinary proceedings in respect of gross misconduct
  • a change in his name or address.
• failed to cooperate with the Commission during the course of the licence review.

Lindar Media Limited

The Gambling Commission commenced a section 116 regulatory review of Lindar Media Limited (the Licensee), Combined Remote Operating Licence Number 051250-R-328289-006, following a compliance assessment conducted in September 2022.

The regulatory review found failings in Lindar Media Limited’s processes aimed at preventing Money Laundering (ML) and protecting individuals from being harmed or exploited by gambling.

Officials found that, between July 2021 and September 2022, Lindar Media Limited failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

• paragraphs 1, 2 and 3 of licence condition 12.1.1 requiring compliance with measures to prevent ML and Terrorist Financing (TF)
• ordinary code provision 2.1.1 requiring non-remote and remote casino licence holders to act in accordance with the Commission’s guidance on Anti-Money Laundering (AML): The Prevention of Money Laundering and Combating the Financing of Terrorism – Guidance for remote and non-remote casinos
• licence condition 15.2.1(4) – requiring licensees to notify the Commission of specific key events, such as the appointment of a person to, or a person ceasing to, occupy a key position
• licence condition 1.2.1(3) – requiring compliance relating to specified management offices
• paragraphs 1a, 1b and 2 of Social Responsibility Code Provision (SRCP) 3.4.1 - requiring licensees to identify and interact with customers who may be at risk of or experiencing gambling related harms in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction
• SRCP 5.1.6 – requiring licensees are compliant with advertising codes
• SRCP 3.1.1(2) – requiring licensees to make an annual contribution in relation to combating problem gambling.

Taking into account the remedial action taken by Lindar Media Limited prior to and immediately following the compliance assessment, and in line with our Statement of principles for licensing and regulation, Lindar Media Limited will pay a total of £690,947.

More information about this case can be found in our public statement on the Commission's website: Lindar Media Limited Public Statement

Shaftesbury Casino Limited

Following a review of the operating licence undertaken against Shaftesbury Casino Limited (the Licensee), the Commission found the Licensee: 

• Failed to comply with ordinary code provision (OCP) 1.1.1 (Cooperation) 
• Failed to comply with ordinary code provision (OCP) 8.1.1 (Information requirements). 

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 (a) of the Gambling Act 2005 (the Act).” 

The Licensee did not disclose at an early stage, information which the Commission would reasonably need to have been aware of in exercising its regulatory functions.?This includes, in particular, anything that is likely to have a material impact on the Licensee’s business. The Licensee chose to cease paying regulatory settlement instalments without advance contact with, or approval by, Commission officials. This was particularly concerning for the Commission given regulatory settlements are entered into with a degree of trust that Licensees will work openly and in a timely manner to ensure the terms of such settlements are fully met.  

The Commission expects Licensees to work with it in an open and cooperative way and to inform it of any matters it would reasonably need to be aware of in exercising its regulatory functions. These include in particular matters that will have a material impact on the Licensee’s business. The Licensee chose to suspend agreed monthly payments to a nominated charity due to financial constraints. However, this decision was made without regard to the impact this would have on the charity meeting its obligations and planned deliverables. Commission officials were concerned the Licensee decided to cease meeting the requirements of a regulatory settlement in favour of ensuring personal tax liabilities were met, entirely of its own volition, without discussion with the Commission.

Done Brothers (Cash Betting) Limited

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of Done Bros (Cash Betting) Limited’s (the Licensee/Done Bros) Non-Remote General Betting Standard, Pool Betting and Ancillary Remote Licence number: 001058-N-102469-014. The regulatory review found failings in the Licensee’s processes which were aimed at Safer Gambling (SG) and preventing Money Laundering (ML).

Between January 2021 and December 2022, Done Bros failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the conducting of an appropriate risk assessment, the implementation of appropriate policies and procedures and keeping such policies under review to ensure their effectiveness, all with the objective of preventing ML and Terrorist Financing (TF)
• paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £3,250,000, which includes a divestment of £1,052,717.

More information about this case can be found in our public statement on the Commission's website: Done Bros (Cash Betting) Limited Public Statement (gamblingcommission.gov.uk)

Videoslots Limited

This investigation followed two compliance assessments which resulted in the commencement of a section 116 regulatory review1 of Videoslots’ Limited (Videoslots).

The regulatory review found failings in the implementation of Videoslots’ processes which were aimed at preventing Money Laundering (ML) and ensuring safer gambling.

Between October 2019 and February 20222, Videoslots failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraph 3 of licence condition 12.1.1, requiring licensees to ensure that ML policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission
• paragraphs 1a, 1b and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to identify and interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

The investigation, and our subsequent regulatory review, found:

• failings in Videoslots’ implementation of Anti-Money Laundering (AML) policies, procedures and controls
• deficiencies in its responsible gambling controls and practices, and weaknesses in the implementation of the existing policies procedures and controls.

In line with our Statement of principles for licensing and regulation, Videoslots will make payments in lieu of a financial penalty of £2,000,000. 

Further information about this case can be found on our website: Videoslots Limited Public Statement (gamblingcommission.gov.uk) 

LEBOM Limited

Following a review of the operating licence of LEBOM Limited (“the Licensee”), the Commission found that the Licensee: 

• failed to comply with social responsibility code provision (SRCP) 3.5.5, which states: “Licensees must participate in the national multi-operator self-exclusion scheme.” 
• breached licence condition 15.3.1 - General and regulatory returns, which states: “On request, licensees must provide the Commission with such information as the Commission may require, in such a form or manner as the Commission may from time to time specify, about the use made of facilities provided in accordance with this licence, and the manner in which gambling authorised by this licence and the licensee’s business in relation to that gambling are carried on. In particular, within 28 days of the end of each quarterly period or, for those only submitting annual returns, within 42 days of the end of each annual period, licensees must submit an accurate Regulatory Return to the Commission containing such information as the Commission may from time to time specify.” 

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”). 

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Indicative sanction guidance, the Commission has decided to impose a formal warning under section 117 (1)(a) of the Act. 

The Licensee co-operated with the Commission throughout the investigation and took steps to address the identified failings.

Johnson Glenn William

Following a licence review, the Commission have determined to revoke Mr Glenn Johnson licence under section 119 (1) of the Gambling Act 2005. The Commission found the Licensee: 

• breached a condition of his personal licence, in that he failed to notify the Commission within 10 working days of a key event, namely his dismissal for gross misconduct and; 
• he failed to notify the Commission that he was subjected to a criminal investigation which is listed under Schedule 7 Relevant Offences of the Gambling Act 2005.

DZBT Limited

Following the submission of a key event by DZBT Limited (“the Licensee”) and an investigation outside of a Licence review, the Gambling Commission (“the Commission”) found that the Licensee failed to comply with: 

• Social Responsibility Code Provision (“SRCP”) 3.5.3 (1), which states: “Licensees must have and put into effect procedures for self-exclusion and take all reasonable steps to refuse service or to otherwise prevent an individual who has entered a self-exclusion agreement from participating in gambling.”
• SRCP 3.5.3 (2), which states: “Licensees must, as soon as practicable, take all reasonable steps to prevent any marketing material being sent to a self-excluded customer.”

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”). 

In line with the Commission’s Licensing, compliance and enforcement policy statement and the Statement of principles for determining financial penalties, the Commission has decided to impose a financial penalty of £700.00 under section 121(1) of the Act.

The Licensee has also voluntarily divested itself of the Gross Gambling Yield (GGY) which occurred as a result of its failings in the sum of £3,638.20.

Commission Officials note the remedial action taken by the Licensee and acknowledge that the Licensee has co-operated with the Commission throughout the investigation.

Skill On Net Limited

This investigation followed the commencement of a section 116 regulatory review of Skill on Net Limited (the Licensee). The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling and preventing Money Laundering (ML).

Between the period of January 2021 and December 2022, the Licensee failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

1. paragraphs 1,2 and 3 of licence condition 12.1.1 requiring compliance with the prevention of money laundering and terrorist financing
2. licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017
3. paragraphs 1a, b and 2 of social responsibility code provision (SRCP) 3.4.1 requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction
4. failed to adhere to Ordinary code provision (OCP) 2.1.1 - Anti-Money Laundering guidance

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £305,150, which includes a £105,650 divestment, and agreement to conduct an independent third-party audit as regards the effective implementation of the Licensee’s AML and safer gambling policies, procedures and controls within 12 months of the conclusion of the Licence Review.

More information about this case can be found on our website: Skill On Net Limited Public Statement (gamblingcommission.gov.uk)

PPB Counterparty Services Limited

1. PPB Counterparty Services Limited ("the Licensee") notified the Gambling Commission ("the Commission"), via a LCCP notification submitted on 26 November 2021, that on 21 November 2021, as a result of human error, a push notification was inadvertently sent to Apple devices linked to accounts of customers that had self-excluded from the Licensee.

2. Following an investigation, the Commission found that the Licensee had failed to comply with paragraphs 2 and 3 of Social Responsibility Code Provision ("SRCP") 3.5.3, requiring licensees to take all reasonable steps to prevent any marketing material being sent to a self-excluded customer and to take steps to remove the name and details of a self-excluded individual from any marketing databases within two days of receiving the completed self-exclusion notification.

3. The Licensee accepted that its actions amounted to a breach of SRCP 3.5.3.

4. The failure to comply with an SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 ("the Act").

5. The Commission decided to impose a financial penalty on the Licensee under section 121(1) of the Act 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.

6. The Licensee appealed against the said penalty to the First-Tier Tribunal.

7. The Commission and the Licensee agreed to dispose of the appeal by consent and the acceptance by the Licensee of a substitute financial penalty of £490,000.

8. Further, the Licensee agreed to instruct an independent third party to undertake an audit of its marketing communication processes and procedures, at its own expense. 

9. The Commission acknowledges that neither it nor the Licensee received any contacts or complaints from customers in respect of this matter.

10. The Commission further acknowledges that the Licensee proactively notified the Commission of the incident promptly after it occurred, took immediate remedial action, and co-operated fully with the Commission throughout its investigation.

Star Racing Limited

Following a review of the operating licence undertaken against Star Racing Limited (“the Licensee”), the Commission found that the Licensee breached:  

• Paragraphs 2 and 3 of licence condition (LC) 12.1.1: Anti-money laundering - Prevention of money laundering and terrorist financing  
• Licence Condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017, and
• Paragraphs 1 and 2 of Social Responsibility code provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

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:  

1. Impose a financial penalty of £594,000 under section 121(1) of the Act 2005
2. Give the Licensee a warning under section 117(1)(a) of the Act.
3. Attach additional conditions to the Licensee’s operating licence under section 117(1)(b) of the Act requiring the Licensee to conduct risk based due diligence on the third parties it transacts with.

WHG (International) Limited

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of WHG (International) Limited (the Licensee/WHG).

The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling and preventing Money Laundering (ML).

Between May 2020 and 18 October 2021, WHG failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• licence condition 2.3.1 (Remote Technical Standards)
• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the conducting of an appropriate risk assessment, the implementation of appropriate policies and procedures and keeping such policies under review to ensure their effectiveness, all with the objective of preventing ML and Terrorist Financing (TF)
• licence condition 12.1.2 requiring remote casino operators based in foreign jurisdictions to comply with the ML, TF and Transfer of Funds (Information of the Payer) Regulations 2017.
• paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction
• paragraphs 1a, 1c and 1d of SRCP 3.7.1 (Provision of Credit)
• paragraph 2 of SRCP 3.9.1 requiring licensees to put into effect policies and procedures designed to identify separate accounts which are held by the same individual and where customers hold more than one account, the Licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each other.

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £12,500,000, which includes a divestment of £284,361.57, and will vary its licence to add additional licence conditions. 

More information about this case can be found on the Commission's website, here: WHG (International) Limited Public Statement (gamblingcommission.gov.uk)

Mr Green Limited

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of Mr Green Limited (the Licensee/MRG). The regulatory review found failings in the Licensee’s processes which were aimed at safer gambling. and preventing Money Laundering (ML).

Between May 20203 and 18 October 2021, MRG failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the conducting of an appropriate risk assessment, the implementation of appropriate policies and procedures and keeping such policies under review to ensure their effectiveness, all with the objective of preventing ML and Terrorist Financing (TF).
• licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the ML, TF and Transfer of Funds (Information of the Payer) Regulations 2017
• paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction
• paragraphs 1 and 2 of SRCP 3.9.1 requiring licensees to put into effect policies and procedures designed to identify separate accounts which are held by the same individual and where customers hold more than one account, the Licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each other.

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £3,750,000, which includes a £218,310.20 divestment, and will vary its licence to add additional licence conditions.

More information about this case can be found on the Commission's website, here: Mr Green Limited Public Statement (gamblingcommission.gov.uk)

William Hill Organization Limited

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of William Hill Organization Limited (WH Retail / the Licensee).

The regulatory review found failings in the Licensee’s processes which were aimed at preventing Money Laundering (ML), and safer gambling.

Between 1 January 2020 and 18 October 20212, the Licensee failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the conducting of an appropriate risk assessment, the implementation of appropriate policies and procedures and keeping such policies under review to ensure their effectiveness, all with the objective of preventing ML and Terrorist Financing (TF)
• paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Taking into account remedial action taken by the Licensee and in line with our Statement of principles for licensing and regulation, the Licensee will voluntarily make a payment in lieu of a financial penalty of £2,999,850 which includes a divestment of £244,026.95, and will vary its licence to add additional licence conditions. 

More information about this case can be found on the Commission's website, here: William Hill Organization Limited Public Statement (gamblingcommission.gov.uk)

TGP Europe Limited

Following reviews of the operating licence undertaken against TGP Europe Limited (the Licensee), the Gambling Commission (the Commission) found that the Licensee:

• breached paragraph 1, 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing)
• breached licence condition 12.1.2. – Anti-Money Laundering (Measures for operators based in foreign jurisdictions)
• failed to comply with social responsibility code of practice (SRCP) 3.4.1 – Customer Interaction
• failed to adhere to Ordinary code provision (OCP) 2.1.1- Anti-Money Laundering guidance

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:

1. impose a warning under section 117 (1) (a) of the Gambling Act 2005 (the Act)
2. attach additional conditions to the Licensee’s operating licence under section 117(1)(b) of the Act
3. impose a financial penalty of £316,250 under section 121 of the Act.

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings.

Blue Star Planet Limited

This investigation resulted in the commencement of a section 116 regulatory review of Blue Star Planet Limited.

The regulatory review found failings in Blue Star Planet Limited’s processes which were aimed at preventing Money Laundering (ML) and protecting vulnerable people. These failings were identified following a compliance assessment that was conducted by Commission Officials on 22, 23, 24 and 25 June 2021.

Between November 2019 and June 2021, Blue Star Planet Limited failed to comply with the following Licence Conditions and Codes of Practice (LCCP):

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring compliance with the prevention of money laundering and terrorist financing
• licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (the 2017 Regulations)
• paragraph 1a of licence condition 8.1.1, requiring licensees providing facilities for remote gambling to display on every screen from which customers are able to access gambling facilities provided in reliance on this licence a statement that they are licensed and regulated by the Gambling Commission
• paragraphs 1b, 1c and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Considering remedial action taken by Blue Star Planet Limited and in line with our Statement of principles for licensing and regulation, Blue Star Planet Limited will pay a total of £620,000 in lieu of a financial penalty.

More information about this case can be found on our website: Blue Star Planet Limited Public Statement - Gambling Commission

Platinum Gaming Limited

Following a review of the operating licence undertaken against Platinum Gaming Limited (the Licensee), the Commission found that the Licensee: 

• breached paragraphs 1, 2 and 3 of licence condition 12.1.1. Anti-Money Laundering (AML) – Prevention of money laundering and terrorist financing.
• breached licence condition 12.1.2 - AML - Measures for operators based in foreign jurisdictions. • failed to comply with paragraphs 1 and 2 of social responsibility code of practice (SRCP) 3.4.1 - Customer Interaction.
• Failed to comply with SRCP 3.9.1 (Identification of individual customers).

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: 

• impose a warning under section 117 (a) of the Gambling Act 2005 (the Act)
• impose a financial penalty of £2,937,599. 

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings. 

32Red Limited

Following a review of the operating licence undertaken against 32Red Limited (the Licensee), the Commission found that the Licensee: 

• Breached paragraphs 2 and 3 of licence condition 12.1.1. Anti-Money Laundering (AML) – Prevention of money laundering and terrorist financing.
• Breached paragraph 1 of licence condition 12.1.2 - AML - Measures for operators based in foreign jurisdictions.
• Failed to comply with paragraphs 1 and 2 of social responsibility code of practice (SRCP) 3.4.1 - Customer Interaction.

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: 

• Impose a warning under section 117 (a) of the Gambling Act 2005 (the Act)
• Impose a financial penalty of £4,195,655.

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings. 

SCGO Limited

Following a compliance assessment carried out in April 2021, the Commission commenced a section 116 regulatory review of Vivaro Limited (Vivaro). 

The regulatory review found failings in Vivaro’s processes which were aimed at preventing money laundering (ML) and safer gambling.

Between October 2020 and June 2021 Vivaro failed to comply with certain Licence conditions and codes of practice (LCCP), specifically:

• Paragraphs 2 and 3 of Licence condition 12.1.1, requiring the prevention of money laundering and terrorist financing.
• Licence Condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017, and
• Paragraphs 1 and 2 of Social Responsibility code provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction

In line with our Statement of principles for licensing and regulation, Vivaro will make payments in lieu of a penalty package of £337,631.

More information about this case can be found in the Commission's public statement on its website. 

Houareau Jean-Pierre Georges

Following a licence review, the Commission decided to issue Mr Jean Pierre Houareau with a warning under section 117(1)(a) of the Gambling Act 2005.

The reason for this decision is as a Personal Management Licence holder whilst holding the specified management office of providing PT Entertainment Services (PTES) with ‘overall management and direction of the licensee’s business or affairs, Mr Jean Pierre Houareau failed to ensure:

• that between October 2016 and 4 February 2017 a risk assessment in relation to money laundering and terrorist financing was in place at PTES as required by paragraph 1 of Licence Condition 12.1.1.
• that between October 2016 and 4 February 2017 PTES had in place appropriates policies, procedures, and controls to prevent money laundering and terrorist financing, following and having regard to a risk assessment. A breach of this licence condition occurred as a result of no proper risk assessment being in place at the time as required by Paragraph 3 of Licence Condition 12.1.1.
• that PTES policies, procedures and controls were implemented effectively, kept under review, revised appropriately to ensure they remained effective, and take into account any applicable learning or guidance issued by the commission from time to time as required by paragraph 3 of Licence Condition 12.1.1.
• compliance with the requirements for PTES to conduct ongoing monitoring of a business relationship (which included scrutinising the transactions undertaking by a customer throughout the course of the relationship including their source of funds.
• sufficient oversight to ensure that PTES put into effect policies and procedures for customer interaction where they had concerns that a customer’s behaviour may indicate problem gambling, with specific provision for those designated as high value or VIP customers.

In reaching our decision we concluded that Mr Houareau was not solely accountable for the failings within the business. 

Mr Houareau has been open and transparent throughout our engagement with him. 

In Touch Games Limited

The Commission found In Touch Games Limited (the Licensee) had breached:

1. Licence condition 12.1.1 Paragraph 1 Anti-money laundering – Prevention of money laundering and terrorist financing 
2. Licence condition 12.1.1 Paragraph 2 Anti-money laundering – Prevention of money laundering and terrorist financing 
3. Licence condition 12.1.1 Paragraph 3 Anti-money laundering – Prevention of money laundering and terrorist financing 
4. Social responsibility code provision (SRCP) 3.4.1 Customer Interaction - paragraphs 1b, 1c and 2. 

The failure to comply with an SRCP is a breach of a licence condition of by virtue of section 82(1) of the Gambling Act 2005 (“the Act”). 

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 impose a financial penalty of £6,133,310 under section 121(1) of the Act. 

Commission Officials note the Licensee co-operated with the Commission and acknowledged the failings identified during the assessment and took immediate remedial action

Tonybet OU

Following a review of the operating licence undertaken against TonyBet (“the Licensee”), the Commission found that the Licensee breached: 

1. Licence Condition 7.1.1 (Fair and Transparent Terms and Practices) 
2. Paragraphs 1, 2 and 3 of Licence Condition 12.1.1 (Anti-money laundering - Prevention of money laundering and terrorist financing) 
3. Paragraph 1 of Licence Condition 12.1.2 (AML – Measures for operators based in foreign jurisdictions) 
4. Licence Condition 15.2.16 (Failure to report a Key Event) 
5. Social Responsibility Code of Practice 3.4.1, issued under section 24 of the Gambling Act 2005, so is to be treated as a licence condition (customer interaction

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: 

1. Impose a financial penalty of £442,750 under section 121(1) of the Act, in respect of breaches identified at findings 1,2,3 and 5 above. 
2. Issue the Licensee with a warning under section 117(1)(a) of the Act in respect of all of the breaches listed. 
3. Attach an additional condition to the operator's licence under Section 117 (1) (b) of the Act, in respect of breaches 1, 2, 3 and 5 above. 

The Commission has noted the Licensee’s ongoing improvements programme and the Licensee’s cooperation throughout. 

Shabunya Dmitry

Following a licence review, the Commission determined to issue Mr Dmitry Shabunya with a warning under section 117(a)(a) of the Gambling Act 2005.

The Commission found the Licensee:

• breached a condition of his personal licence, in that he failed to notify the Commission within 10 working days of a key event, namely his dismissal for gross misconduct

The Licensee cooperated with the Commission during course of the review.

Eaton Gate Gaming Limited

Following a review of the operating licence undertaken against Eaton Gate Gaming Limited (“the Licensee”), the Gambling Commission found that the Licensee:

• breached paragraphs 1, 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing)

• failed to comply with social responsibility code of practice (“SRCP”) 3.4.1 – Customer Interaction

• breached SRCP 5.1.9, code of practice issued under section 24 of the Gambling Act 2005, so as to be treated as a licence condition

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:

(i) impose a warning under section 117 (1) (a) of the Gambling Act 2005 (“the Act”) in respect of the breaches identified

(ii) attach an additional condition to the Licensee’s operating licence under section 117(1)(b) of the Act requiring:

the Licensee must undertake a third-party audit within 12 months of the conclusion of the review. The purpose of the audit is to examine whether the Licensee is effectively implementing its anti-money laundering and social responsibility policies, procedures and controls in accordance with its regulatory requirements. The Licensee must provide the Commission with a copy of the Audit report within five working days of it being received

(iii) impose a financial penalty of £480,305 under section 121 of the Act.

The Licensee co-operated with the Gambling Commission throughout the investigation and took corrective steps to address the identified failings.

AG Communications Limited

Following a review of the operating licence undertaken against AG Communications Limited (“the Licensee”), the Commission found that the Licensee breached:

• Paragraphs 1 and 2 of licence condition (LC) 12.1.1: Anti-money laundering - Prevention of money laundering and terrorist financing

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:

1. Impose a financial penalty of £237,600 under section 121(1) of the Act 2005
2. Give the Licensee a warning under section 117(1)(a) of the Act
3. Attach additional conditions to the Licensee’s operating licence under section 117(1)(b) of the Act requiring the Licensee to conduct risk based due diligence on the third parties it transacts with.

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings.

NSUS Limited

Following a review of the operating licence undertaken against NSUS Limited (the Licensee), the Commission found that the Licensee:

• breached paragraphs1, 2 and 3 of licence condition 12.1.1 –Anti-Money Laundering (Prevention of money laundering and terrorist financing)
• breached licence condition 12.1.2. –Anti-Money Laundering (Measures for operators based in foreign jurisdictions) 
• failed to comply with social responsibility code of practice (SRCP) 3.4.1 –Customer Interaction 

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:

1. impose a warning under section 117 (1) (a) of the Gambling Act 2005 (the Act)
    
2. impose a financial penalty of £672,829 under section 121 of the Act. 

The Licensee co-operated with the Commission throughout the investigation.

Corbett Bookmakers Limited

Following a review of the operating licence undertaken against Corbett Bookmakers Limited (the Licensee), the Commission found that the Licensee:

• breach of paragraph 1 of Licence condition 12.1.1 (Prevention of money laundering and terrorist financing)
• breach of paragraph 2 and 3 of Licence condition 12.1.1 (prevention of money laundering
• failure to comply with Social Responsibility code provision (SRCP) 3.4.1
• failure to comply with Paragraph 2 of SRCP 1.1.2 Responsibility for third parties
• failure to take into Consideration of Ordinary code provisions 2.1.1 paragraphs 1 and 2.1.2 paragraph 1

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:

i. impose a warning under section 117 (1) (a) of the Gambling Act 2005 (the Act)

ii. attach additional conditions to the Licensee’s operating licence under section 117(1)(b) of the Ac

The Licensee must undertake a third-party audit within 12 months of the conclusion of the review. The purpose of the audit is to examine whether the Licensee is effectively implementing its anti-money laundering and social responsibility policies, procedures and controls in accordance with its regulatory requirements.

iii. impose a financial penalty of £215,600 under section 121 of the Act.

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings.

Petfre (Gibraltar) Limited

Following a review of the operating licence undertaken against Petfre (Gibraltar) Limited (“the Licensee”), the Commission found that between October 2019 and December 2020 the Licensee: 

• breached paragraph 1, 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) 
• breached paragraph 1 of licence condition 12.1.2. – Anti-Money Laundering (Measures for operators based in foreign jurisdictions) 
• failed to comply with paragraph 1 and 2 of social responsibility code of practice (SRCP) 3.4.1 – Customer Interaction 
• failed to act in accordance with ordinary code provision 2.1.1 – Anti-money laundering 

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: 

• impose a financial penalty of £2,873,750 million under section 121 of the Gambling Act 2005 (the Act) 
• impose a warning under section 117(1)(a) of the Act

The Licensee co-operated with the Commission throughout the investigation and took immediate corrective steps to address the identified failings. The Commission’s review of the specific customers identified during the Compliance assessment found no evidence of criminal spend with the Licensee.

Betway Limited

Following an investigation outside of a licence review, the Commission found that Betway Limited (“the Licensee”) failed to comply with paragraphs 1 and 2 of SRCP 5.1.6 – Compliance with advertising codes, which requires the following:

1. All marketing of gambling products and services must be undertaken in a socially responsible manner.
2. In particular, Licensees must comply with the advertising codes of practice issued by the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) as applicable. For media not explicitly covered, licensees should have regard to the principles included in these codes of practice as if they were explicitly covered.

The failure to comply with a SRCP is a breach of a licence condition of by virtue of section 82(1) of the Act.

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 impose a financial penalty of £408,915 under section 121(1) of the Act.

Commission Officials note the remedial action that was taken by the Licensee and acknowledge that the Licensee has co-operated with the Commission throughout the investigation. 

Spreadex Limited

This investigation resulted in the commencement of a section 116 regulatory review of Spreadex Limited (Spreadex). The Commission commenced its regulatory review on 2 June 2021, following concerns identified in a compliance assessment conducted in May 2021.

The regulatory review found failings in Spreadex’s procedures which were aimed at preventing Money Laundering (ML) and protecting vulnerable people.

Between January 2020 and May 2021 Spreadex breached the Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the prevention of money laundering and terrorist financing. This includes its failure to act in accordance with the Commission’s guidance: The Prevention of Money Laundering and Combating the Financing of Terrorism - Guidance for remote and non-remote casinos OCP 2.1.1 – Anti-Money Laundering (Casino)
• paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Taking into account remedial action taken by Spreadex and in line with our Statement of Principles for licensing and regulation, Spreadex will pay a total of £1,363,786 in lieu of a financial penalty. 

More information about this case can be found on the Commission’s website. 

LC International Limited

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review of LC International Limited (LCI), Combined Remote Operating Licence. The regulatory review found failings in LCI’s processes which were aimed at preventing Money Laundering (ML) and safer gambling.

Between December 2019 and October 2020, LCI failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring the prevention of money laundering and terrorist financing (ML and TF)
• licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017
• paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Gambling Commission’s guidance on customer interaction
• paragraphs 1 and 2 of SRCP 3.9.1 requiring Licensees to put into effect policies and procedures designed to identify separate accounts which are held by the same individual and where customers hold more than one account, the Licensee must have and put into effect procedures which enable them to relate each of a customer’s such accounts to each other.

Taking into account remedial action taken by LCI and in line with our Statement of Principles for licensing and regulation, LCI will voluntarily divest itself of £544,048.03 and pay £13,455,952 in lieu of a financial penalty resulting in a total payment in lieu of a financial penalty of £14,000,000.

More information can be found on the Commission's public statement into this case. 

Ladbrokes Betting & Gaming Limited

This investigation followed a compliance assessment and resulted in the commencement of a section 116 regulatory review1 of Ladbrokes Betting & Gaming Limited (LBG). The regulatory review found failings in LBG’s processes which were aimed at preventing Money Laundering (ML) and safer gambling.

Between December 2019 and October 2020 LBG failed to comply with certain Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 2 & 3 of licence condition 12.1.1 – Prevention of money laundering and terrorist financing
• paragraphs 1 & 2 of Social Responsibility Code Provision (SRCP) 3.4.1 – Customer Interaction.

Taking into account remedial action taken by LBG and in line with our Statement of principles for licensing and regulation, LBG will voluntarily divest itself of £212,849.86 and pay £2,787,150.14 in lieu of a financial penalty resulting in a total payment of £3,000,000.

More information about this case can be found on the 

Commission’s website.

Smarkets (Malta) Limited

Following a review of the operating licence undertaken against Smarkets (Malta) Limited (“the Licensee”), the Commission found that the Licensee: 

• breached paragraph 1, 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) 

•failed to comply with social responsibility code of practice (SRCP) 3.4.1 – Customer Interaction 

•failed to act in accordance with ordinary code provision 2.1.2 – Anti-money laundering other than casino 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:

(i)impose a warning under section 117 (1) (a) of the Gambling Act 2005 (the Act) in respect of the breaches identified 
(ii) attach an additional condition to the Licensee’s operating licence under section 117(1)(b) of the Act requiring the Licensee to conduct a third-party audit within 12 months of the conclusion of the review, to examine whether the Licensee is effectively implementing its anti-money laundering and social responsibility policies, procedures and controls 
(iii) impose a financial penalty of £630,000 under section 121 of the Act. 

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings. The Commission’s review of the specific customers identified during the Compliance assessment found no evidence of criminal spend with the Licensee. The Licensee has co-operated with the Commission throughout the investigation and taken appropriate remedial action to address the identified failings.

LeoVegas Gaming PLC

Following a review of the operating licence undertaken against LeoVegas Gaming PLC (the Licensee), the Commission found that between October 2019 and October 2020 the Licensee:

• breached paragraphs 2 and 3 of licence condition 12.1.1. Anti-Money Laundering (AML) – Prevention of money laundering and terrorist financing
• breached paragraph 1 of licence condition 12.1.2. Anti-Money Laundering (AML)
• failed to comply with paragraphs 1(a),1(b) and 2 of social responsibility code of practice (SRCP) 3.4.1 (Customer Interaction)
• failed to comply with SRCP 3.9.1 (Identification of customers)
• failed to act in accordance with ordinary code provision (OCP) 2.1.1 (Anti-money laundering).

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:

• imposed a warning under section 117(1)(a) of the Gambling Act 2005 (the Act)
• attach an additional condition to the Licensee’s operating licence under section 117(1)(b) of the Act requiring:

“The Licensee must undertake a third-party audit within 12 months of the conclusion of the review. The purpose of the audit is to examine whether the Licensee is effectively implementing its anti-money laundering and social responsibility policies, procedures and controls in accordance with its regulatory requirements.

The Licensee must provide the Commission with a copy of the Audit report within 5 working days of it being received by it.”

• impose a financial penalty of £1,320,000.

The Commission’s review of the specific customers identified during the Compliance assessment found no evidence of criminal spend with the Licensee. The Licensee has co-operated with the Commission throughout the investigation and taken appropriate remedial action to address the identified failings.

Martin Henry Bailey

Following a licence review under section 116 of the Gambling Act 2005 (“the Act”), the Commission determined to revoke the operating licence issued to Martin Henry Bailey (“the Licensee”), under section 119(1) of the Act.  

The Commission found the Licensee: 

1. Breached the following conditions of its operating licence:? 

• Licence condition 5.1.1 - Cash and cash equivalents  
• Paragraph 2 of licence condition 7.1.1 - Fair and transparent terms and practices 
• Paragraph 1 of licence condition 12.1.1 Anti-money laundering - Prevention of money laundering and terrorist financing 
• Paragraph 2 of licence condition 12.1.1 Anti-money laundering - Prevention of money laundering and terrorist financing 
• Paragraph 3 of licence condition 12.1.1 Anti-money laundering - Prevention of money laundering and terrorist financing 
• Licence condition 14.1.1 - Access to Premises  
• Licence condition 15.2.1 - Reporting key events
   

2. Breached section 82 of the Act by failing to comply with the following social responsibility code provisions:? 

• Paragraphs 1, 2 (a), 3 and 6 of social responsibility code provision 3.2.7 - Access to Gambling by Children and Young Persons 
• Paragraphs 1 and 2 (a to d), 3 and 4 of social responsibility code provision 3.3.1 - Responsible gambling information 
• Paragraphs 1 (a and b) and 2 of social responsibility code provision 3.4.1 - Customer interaction 
• Paragraphs 1, 6 (a to d) and 7 of social responsibility code provision 3.5.1 - Self-exclusion 
• Social responsibility code provision 3.5.6 - Multi-operator non-remote SR code 
• Paragraphs 1 (a to j) and 3 of social responsibility code provision 4.2.6 - Display of Rules 
• Paragraph 1, and acted contrary to Paragraph 2 (a and b), of social responsibility code provision 10.1.1 - Local Risks to the Licensing Objectives
   

3. was unsuitable to carry on the licensed activities.?

ProgressPlay Limited

This investigation resulted in the commencement of a section 116 regulatory review of Progress Play Limited’s, (Progress Play). The Commission commenced its regulatory review on 14 August 2020.

The regulatory review found failings in Progress Play’s processes which were aimed at preventing money laundering and protecting vulnerable people. Progress Play failed to comply with the Licence conditions and codes of practice (LCCP), specifically:

• paragraphs 2 and 3 of Licence Condition 12.1.1, requiring measures for the prevention of money laundering and terrorist financing
• Licence Condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017
• paragraphs 1 (a), (b), (c) and 2 of social responsibility code provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Taking into account remedial action taken by Progress Play and in line with our Statement of principles for licensing and regulation, Progress Play will make a payment in lieu of a financial penalty and divestment to the sum of £175,718.00 It will also pay Commission costs of £12,466.35.

More information about this case can be found on the Commission’s website. 

Jumpman Gaming Limited

This investigation resulted in the commencement of a section 116 regulatory review of Jumpman Gaming Limited (Jumpman). The Commission commenced its regulatory review on 3 September 2020 following concerns identified in a compliance assessment conducted in July 2020.

The regulatory review found failings in Jumpman’s processes which were aimed at preventing money laundering (ML) and promoting safer gambling by protecting vulnerable people. Evidence gathered during the compliance assessment and the subsequent review of the operating licence found Jumpman failed to comply with the Licence Conditions and Codes of Practice (LCCP), specifically:

• paragraphs 1, 2 and 3 of Licence Condition (LC) 12.1.1, requiring compliance with the prevention of money laundering and terrorist financing
• Licence Condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (“the 2017 Regulations”)
• paragraphs 1 and 2 of Social responsibility code provision (SRCP) 3.4.1: requiring licensees interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Further failings of the following LCCP were also identified:

• paragraphs 1 and 2 of SRCP 3.9.1, requiring policies and procedures are put into effect that are designed to identify separate accounts held by the same individual, and requirements where licensees allow customers to hold more than one account with them.

Taking into account remedial action taken by Jumpman and in line with our Statement of principles for licensing and regulation, Jumpman will pay a total of £500,000 in lieu of a financial penalty.

More information about this case can be found on the Commission’s website.

Lottery England Limited

Following a review of the operating licence undertaken against Lottery England Limited (“the Licensee”) the Commission found that the Licensee: 

• Breached (and remains in breach) of paragraphs 13 and 14 of licence condition 11.2.1: Lotteries – Managers 
• Breached paragraph 2 of licence condition 15.3.1: General and regulatory returns 

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:  

• in respect of paragraphs 13 and 14 of licence condition 11.2.1, suspend the Licensee’s operating licence under section 117(1)(e) and section 118(1) of the Gambling Act 2005 (“the Act”) until the Licensee demonstrates it is compliant with these conditions 
• in respect of paragraph 2 of licence condition 15.3.1 – General and regulatory returns, give the Licensee a warning under section 117(1)(a) of the Act 
• attach an additional condition to the Licensee’s operating licence under section 117(1)(b) of the Act.

Mackrill Edward William

Following a licence review, the Commission decided to issue Mr Edward Mackrill 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 regulatory compliance and as the MLRO at BGO Limited (BGO), he failed to take all reasonable steps to ensure that the way in which he carried out his responsibilities in relation to licensed activities did not place BGO in breach of their licence. In particular:

• Breach of licence condition 12.1.1(1), (2), and (3)Anti-money laundering -Prevention of money laundering and terrorist financing
• Breach of licence condition 12.1.2 Anti-money laundering –Measure for operators based in foreign jurisdictions
• Failure to comply with social responsibility code provision 3.4.1(1)(e), relevant at the time of the failings-Customer interaction. Compliance with a social responsibility code of practice is a condition of the licence.

In reaching our decision we concluded Mr Mackrill was not solely accountable for the failings within the business.Mr Mackrill has been open and transparent throughout our engagements with him.

Scout Limited

Following an investigation outside of a Licence review, the Gambling Commission (“the Commission”) found that Scout Limited t/a Fanteam (“the Licensee”) failed to comply with:

• Social responsibility code provision (“SRCP”) 3.5.3(2), which states: “Licensees must, as soon as practicable, take all reasonable steps to prevent any marketing material being sent to a self-excluded customer.”

• SRCP 5.1.11, which states: “Unless expressly permitted by law consumers must not be contacted with direct electronic marketing without their informed and specific consent. Whenever a consumer is contacted the consumer must be provided with an opportunity to withdraw consent. If consent is withdrawn the licensee must, as soon as practicable, ensure the consumer is not contacted with electronic marketing thereafter unless the consumer consents again. Licensees must be able to provide evidence which establishes that consent.”

The failure to comply with a SRCP is a breach of a licence condition by virtue of section 82(1) of the Gambling Act 2005 (“the Act”).

In line with the Commission’s Licensing, compliance and enforcement policy statement, the Indicative sanction guidance and the Statement of principles for determining financial penalties, the Commission has decided to impose a financial penalty of £56,700.00 under section 121(1) of the Act.

Commission Officials note the immediate remedial action taken by the Licensee and acknowledge that the Licensee has co-operated with the Commission throughout the investigation.

BV Gaming Limited

Following a compliance assessment conducted in March 2020 (the Assessment), the Commission commenced a section 116 regulatory review1 of BV Gaming Limited, trading as BetVictor (BV Gaming). The regulatory review found failings in BV Gaming’s processes which were aimed at preventing money laundering (ML) and protecting vulnerable people.

Between 1 January 2019 to 12 March 2020 BV Gaming failed to comply with the Licence conditions and codes of practice (LCCP), specifically:

• Paragraph 1 of Licence condition 7.1.1 requiring compliance with fair and transparent terms and practices.
• Paragraphs 1, 2 and 3 of Licence condition 12.1.1, requiring licensees to take steps to prevent money laundering and terrorist financing.
• Licence Condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (the 2017 Regulations).
• Paragraphs 1 and 2 of Social responsibility code provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.
• Paragraph 2 of SRCP 5.1.9 requiring licensees to comply with marketing requirements.

BV Gaming submitted a remedial action plan with the Commission within 2 days of receiving the notice commencing the licence review on 7 April 2020, which it then preceded to implement, as it had committed to the Commission to do.

Taking into account remedial action taken by BV Gaming and in line with our Statement of principles for licensing and regulation, BV Gaming will divest £352,000.00, gross gambling yield (GGY) gained as a result of the failings and pay a total of £1,728,000 in lieu of a financial penalty.

Further information about this case can be found on the Commission’s website. 

888 UK Limited

Following a review of the operating licence undertaken against 888 UK Limited (the Licensee) the Commission found that the Licensee: 

• breached paragraphs 1, 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing) 
• breached paragraph 1 of licence condition 12.1.2 – Anti-Money Laundering (Measures for operators based in foreign jurisdictions) 
• failed to comply with paragraphs 1 and 2 of social responsibility code provision of practice (SRCP) 3.4.1 – Customer Interaction 
• failed to comply with SRCP 3.9.1 – Identification of individual customers - remote 

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: 

(i) impose a warning under section 117 (1) (a) of the Gambling Act 2005 (the Act) in respect of the breaches identified 

(ii) attach an additional conditions to the Licensee’s operating licence under section 117(1)(b) of the Act requiring the Licensee to conduct a third-party audit within 12 months of the conclusion of the review, to examine whether the Licensee is effectively implementing its anti-money laundering and social responsibility policies, procedures and controls 

(iii) impose a financial penalty of £9,409,756.48 under section 121 of the Act. 

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings

Bonne Terre Limited

Following an investigation outside of a Licence review, the Commission found that Bonne Terre Limited t/a Sky Betting and Gaming (the Licensee) had failed to comply with: 

• Social responsibility code of practice (SRCP 3.5.3(2)) “Licensees must, as soon as practicable, take all reasonable steps to prevent any marketing material being sent to a self-excluded customer.” 
• SRCP 5.1.11 “Unless expressly permitted by law consumers must not be contacted with direct electronic marketing without their informed and specific consent. Whenever a consumer is contacted the consumer must be provided with an opportunity to withdraw consent. If consent is withdrawn the licensee must, as soon as practicable, ensure the consumer is not contacted with electronic marketing thereafter unless the consumer consents again. Licensees must be able to provide evidence which establishes that consent.” 

The failure to comply with an SRCP is a breach of a licence condition of by virtue of section 82(1) of the Gambling Act 2005 (“the Act”). 

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 impose a financial penalty of £1,170,000 under section 121(1) of the Act.

Commission Officials note the immediate remedial action that was taken by the Licensee and acknowledge that the Licensee has co-operated with the Commission throughout the investigation. 

Annexio (Jersey) Limited

This investigation resulted in the commencement of a section 116 regulatory review of Annexio (Jersey) Limited (Annexio) operating licence. The regulatory review found failings in Annexio’s processes which were aimed at preventing money laundering and protecting vulnerable people.

Between October 2019 and November 2021 Annexio failed to comply with the Licence conditions and code of practice, specifically: 

• Paragraphs 1, 2 and 3 of licence condition 12.1.1, requiring Licensee’s to conduct an assessment of the risks to their business being used for money laundering and terrorist financing; have appropriate policies, procedures and controls to prevent money laundering and terrorist financing and ensure they are kept under review, revised appropriately and take into account any applicable learning or guidelines published by the Commission.  
• Paragraph 1 and 2 of social responsibility code provision (SRCP) 3.4.1, requiring licensees to identify customers who may be at risk of or experiencing harms associated with gambling, interact with such customers and understanding the impact on the customer andthe effectiveness of their actions and approach. Licensees must also take into account the Commission’s guidance on customer interaction.
• Licence Condition 15.2.1 requiring operators to report key events to the Commission. 

Taking into account the remedial action taken by Annexio and in line with our Statement of principles for licencing regulation, Annexio will pay a total of £612,000 in lieu of a financial penalty. 

More information about this case can be found on the Gambling Commission’s website. 

Rank Digital Gaming (Alderney) Limited

Following a compliance assessment of Rank Digital Gaming (Alderney) Limited (Rank) failings were identified, which resulted in the commencement of a section 116 regulatory review of its operating licence. The regulatory review found failings in Rank’s processes aimed at protecting vulnerable people. 

Between October 2019 and February 2021 Rank failed to comply with the Licence conditions and codes of practice, specifically:

• Paragraphs 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling and to take into account the Commission’s guidance on customer interaction.
• Paragraph 2 (b) of SRCP 3.9.1 - Paragraph 2 (b) requires that licensees who allow customers to hold more than one account must ensure that all accounts are monitored and that decisions that trigger customer interaction are based on behaviour and transactions across all accounts.
• Paragraph 6 of SRCP 3.5.3 - licensees must ensure that any individual who has self-excluded cannot gain access to gambling.

Taking into account remedial action taken by Rank and in line with our Statement of principles for licensing and regulation, Rank will pay a total of £700,557 in lieu of a financial penalty.

More information about this case can be found on the Gambling Commission's website. 

Genesis Global Limited

Following a review of the operating licence undertaken against Genesis Global Limited (“the Licensee”), the Commission found that the Licensee: 

• breached paragraph 1, 2 and 3 of licence condition 12.1.1 – Anti-Money Laundering (Prevention of money laundering and terrorist financing)
• breached licence condition 12.1.2. – Anti-Money Laundering (Measures for operators based in foreign jurisdictions)
• failed to comply with social responsibility code of practice (SRCP) 3.4.1 – Customer Interaction
• failed to comply with SRCP 3.9.1 – Identification of individual customers
• failed to act in accordance with ordinary code provision 2.1.1 – Anti-money laundering

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:  

• impose a warning under section 117(1)(a) of the Gambling Act 2005 (the Act)
• attach additional conditions to the Licensee’s operating licence under section 117(1)(b) of the Act
• impose a financial penalty of £3,769,920 under section 121 of the Act.

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings. 

Caltabiano Fabio

Following a licence review, the Commission decided to revoke the Personal Functional Licence issued to Mr Fabio Caltabiano under the provisions of section 119 of the Act on the grounds that he was considered unsuitable to carry on the licensed activities permitted by the licence.

The Commission found that:

• The Licensee had failed to provide the information required by the Commission as part of the Personal License Maintenance process to assess the continued suitability of the Licensee to hold a personal licence.

• The Licensee had failed to cooperate with the review under section 120(1)(c) of the Gambling Act 2005.

Greentube Alderney Limited

The Commission carried out an investigation into the actions of Greentube Alderney Limited (“Greentube”). The regulatory review found failings in Greentube’s processes which were aimed at preventing money laundering (ML) and protecting vulnerable people. These failings were found on two of Greentube’s casino and betting websites, admiralcasino.co.uk and bellfruitcasino.com.

The Commission found that between December 2019 and November 2020 Greentube failed to comply with the Licence conditions and codes of practice (“LCCP”), specifically: 

• Paragraphs 1, 2 and 3 of Licence condition 12.1.1, requiring compliance with the prevention of money laundering and terrorist financing
• Licence Condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (“the 2017 Regulations”), and 
• Licence Condition 15.2.1 requiring operators to report key events to the Commission
• Paragraphs 1 and 2 of Social responsibility code provision 3.4.1, requiring licensees to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, and to take into account the Commission’s guidance on customer interaction.

Taking into account remedial action taken by Greentube and in line with our Statement of principles for licensing and regulation, the Commission agreed a regulatory settlement with Greentube consisting of: 

1. £685,000 payment in lieu of a financial penalty, which will be directed towards delivering the National Strategy to Reduce Gambling Harms
2. Agreement to the publication of a statement of facts in relation to this case
3. Greentube has agreed to vary its operating licence to add a specific condition to carry out a third-party audit to review its compliance with the Licensing condition and codes of practice within twelve months, the findings of which it will share with the Commission
4. Payment of £8,789.86 towards the Commission’s costs of investigating the case.

Buzz Group Limited

Following a review of the operating licence undertaken against Buzz Group Limited (the Licensee), the Commission found that the Licensee:

• breached paragraph 2 and 3 of licence condition 12.1.1. Anti-Money Laundering (AML) – Prevention of money laundering and terrorist financing
• failed to comply with paragraph 1 of social responsibility code of practice (SRCP) 3.4.1 (Customer Interaction)
• failed to act in accordance with the principles of ordinary code provision (OCP) 2.1.1 (Anti-money laundering)

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:

• impose a warning under section 117 (a) of the Gambling Act 2005 (the Act)
• impose a financial penalty of £780,000.00.

The Licensee co-operated with the Commission throughout the investigation and took corrective steps to address the identified failings. 

VGC Leeds Limited

The Commission investigated VGC’s handling of 10 customers following concerns identified at a compliance assessment in July 2019. Our investigation identified failings in the way VGC identified and managed customers who were at higher risk of money laundering and gambling-related harm. 

On 24 October 2019, we gave VGC notice that we were commencing a review of its operating licence. That review revealed VGC had breached conditions of its operating licence.

VGC cooperated with our enquiries throughout the course of our investigation and has accepted that the implementation of its policies and procedures in respect of AML and safer gambling were not effective. It has accepted that it failed to act in accordance with conditions of its operating licence between January 2017 and July 2019.

In line with our Statement of principles for licensing and regulation, VGC will pay £241,000 to represent divestment of the amount of financial gain accrued as a result of the accepted failings, and £209,000 in lieu of a financial penalty. It will also pay Commission costs of £21,578.17.

Agreement to the publication of a statement of facts in relation to this case - with the news story/ public statement being linked off the "a statement of facts".