Due to Money Laundering and Social Responsibility Failures Casino 36 Must Fulfill New License Condition
As part of a £300,000 penalty package for serious irregularities found by the UK Gambling Commission (UKGC), personal management license holders at Casino 36 must undertake extra training.
The commission’s investigation revealed the operator had failed to ensure adequate checks for 33 customers including the:
- Enhanced Due Diligence (EDD)
- Source of Funds (SOF)
- Source of Wealth (SOW)
The online venue also failed to ensure sufficient customer interaction when customers were potentially displaying signs of suffering gambling harm.
Penalties and Additional License Conditions for the Operator
Since the UK Gambling Commission wants fairer and safer market, it is one of the strictest regulators who doesn’t let oversights like this to slide easily.
As part of a settlement, the operator will divest £147,741 and make a £152,259 payment in lieu of a financial penalty…
… which the UKGC would otherwise impose for breaching of the License conditions and terms of practice. Also, the operator has to make a payment of £18,648 for the regulators investigative costs.
… the site will also have additional conditions added to its license.
Executive Director of the UKGC, Richard Watson, said about the matter:
“As a result of Casino 36’s failings stolen money could have flowed unchecked through their casino and vulnerable customers were placed at risk of harm. This is simply not acceptable.
Operators have to understand their customer base. This can only be achieved if they know their customers and ask the right questions to meet both their anti-money laundering and social responsibility obligations.”
Additional License Conditions to be Fulfilled
According to the specific conditions put on the operating license, the operator has to…
… “compile and put into effect a regular training needs analysis of all staff and provide training dependent on the role of individual staff members within three months from the date of the acceptance of this condition.”
Also, the Senior Director and Compliance personal management license holder must conduct an annual training need analysis for all staff. They need to act upon findings and be able to present them to the Commission on request.
… all personal management license holder’s and staff in key positions have to undertake outsourced refresher training within three months from the date of the acceptance of this condition and annually thereafter.
Additionally, it must maintain enhanced due diligence (EDD) on its top 250 customers across the group within its customer profiling system is in the additional license conditions as well.
Within six months, the operator has to agree to instruct external auditors to carry out an independent audit of its current top 100 customers…
… in order to ensure full compliance in license terms and conditions.
The Weaknesses in AML Policies and Procedures
The regulator’s investigation showed that there were weaknesses in the site’s AML policies and procedures, as well in its responsible gambling policies and procedures. Meaning that there were breaches of the license condition and SR codes.
The operator has stated that there had been several failed attempts to remedy the breach before the license review commenced. A number of key actions had already been implemented/planned prior to notification of the review, which regulator take regarded off.
According to the UKGC, Casino 36 did accept responsibility for the breaches and it has been co-operative during the review process. That is why the Commission didn’t consider that any further adjustment to a financial penalty will be necessary.
“UKGC: new licence conditions for Casino 36, with money laundering and social responsibility failures”, europeangaming.eu, July 12, 2019.