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Raising Standards for consumers - Compliance and Enforcement report 2020 to 2021

The Gambling Commission's report on Compliance and Enforcement action 2020 to 2021. Archived: Report represents information and guidance valid at the time of publication.

  1. Contents
  2. Case studies

Case studies

A licensee held an operating licence which permitted it to produce and supply gambling software, to offer remote general betting (live events) products, remote general betting (virtual events) and to provide an online casino.

There had been compliance issues identified historically and a further compliance assessment was planned. During the website review, breaches of licence conditions and social responsibility codes were identified. Before the assessment could be completed by reviewing live customer accounts the licensee informed the Commission it would no longer co-operate with the assessment but would provide records if requested.

Despite efforts encouraging them to reconsider their position, agreement could not be reached. The matter was considered, and a decision was taken to suspend the operating licence as the situation posed an unacceptable risk to the licensing objectives and to consumers given the continuous failures to operate compliantly. Taken together with the refusal to allow the Commission to assess the licensee’s facilities as required, this brought into question the licensee’s suitability to hold a licence. As a result, an s116 licence review commenced.

On the same day, Commission employees identified that the licensee’s website had a banner which appeared to make light of the compliance issues which had been raised as grounds for licence review and suspension. Officials contacted the licensee’s legal representatives with a screenshot of the banner content highlighting that it raised questions regarding the operator’s suitability to hold a licence. The banner was subsequently removed.

The licensee appealed the suspension, asserting that they had not carried out the licensed activity in a manner inconsistent with the licensing objectives or in breach of a licence condition, and the only reason for the Commission suspending the licence was based on suitability (section 120 (1)(d)). In particular, they argued the licence was suspended because the licensee would not agree to participate in a Skype call.

The Third Tier Tribunal considered the appeal and found in the Commission’s favour, concluding that there were grounds to suspect that one of the section 120(1) conditions may apply, that the licensee had breached numerous conditions of their licence, that the breaches were serious enough to warrant suspension, and that their failure to attend the compliance assessment exacerbated these breaches, and so the licence should be suspended. It is of note that the Judge went on to comment that there was nothing to indicate that the Commission was not justified in its original decision.

The finding also confirmed that the Commission has the power to require licensees to attend remote compliance assessments. It confirmed that the Commission can require licensees to provide records and documentation during the course of the assessment and can view customer and audit records. Following this decision, the operating licence was surrendered, and two Personal Management Licence holders also surrendered their licences.

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