Public statements

Public Statements

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Available gambling operators have a legal obligation to guarantee that the gambling facilities will be provided according to the 2005 gambling method (opened on the new tab), approval conditions, and the following approval purpose:

Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
Gamble will be performed in a fair, safe and open way.
Make sure that children and other vulnerable are not damaged or exploited by gambling.

The Gambling Committee has received a compliance evaluation conducted in March 2022 and has launched a regulation review of Hillside (UK GAMING) Enc Section 116 (Remote Bingo and Casino License Number 055149; R-331499-002). 。

Regulatory officials revealed that there was a defect in the procedures for licensing to prevent money laundering (ML) and protect individuals from gambling damage and exploitation.

Licensei does not comply with the following license conditions and implementation norms (LCCP):

The license conditions 12. 1. 1 are obliged to follow the prevention of ML and terrorist funding (TF) from May 2021 to July 2022.
Licensing conditions 12. 1. 2: 2021 From May 2021 to July 2022, for businesses based in foreign jurisdictions, money laundering, terrorist funding, and fund transfer (Payment information) Rules 2017 (2017 Regulations) Cord for compliance.
From October 2021 to September 2022, a social responsibility standard (SRCP) 3. 4. 1, which calls for a franchhaie to treat customers in a way to minimize the risk of gamblin g-related damage, is 1B. And 1C section.

In consideration of the rescue measures taken by License, Licensei pays £ 343.

The review of our surveys and the subsequent regulations revealed that Licensei did:

Breached paragraph 2 of licence condition 12.1.1 (Prevention of money laundering and terrorist financing) between May 2021 and July 2022

License Status 12: "Upon completion of a risk assessment and taking into account any review of the assessment, the licensee must ensure that it has adequate policies, procedures and controls to prevent money laundering and terrorist financing.

The licensee acknowledged that at the time of its assessment:

Enhanced customer due diligence triggers were ineffective in managing ML risk.
It failed to conduct financial sanctions checks before first deposits for new customers.
It relied on annual customer self-retention of customer due diligence information such as identity documents rather than conducting independent verification checks.
Its process documentation had insufficient detail on who was considered "at risk" and "not at risk" in the customer risk profile.

The Commission's review of specific customers identified during the compliance assessment found no evidence of criminal spending with the licensee or the acceptance of funds from persons subject to financial sanctions.

Breached licence condition 12.1.2 (Anti-Money Laundering - Measures for operators based in foreign jurisdictions) between May 2021 and July 2022

License 12. 1. 2 status has been in effect since October 2016 and requires: "The Licensee agrees that the Money Laundering Regulations as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of UK law as amended or replaced in so far as they relate to casinos (MLR), apply to its business whether or not the MLR applies to its business."

Hillside (UK gaming) admitted that the AML failures referred to above were a breach of the 2017 regulations, i. e. a breach of this license condition:

Regulation 28(11)(a) requires ongoing monitoring of business relationships, including verifying sources of funds where necessary, to ensure that business relationships are consistent with customer knowledge, customer profile and risk.
Regulation 33 requires enhanced customer due diligence measures and enhanced ongoing monitoring to be implemented in situations identified as having a high risk of ML or TF.

Failed to comply with paragraphs 1b and 1c of SRCP 3.4.1 (Customer Interaction) between October 2021 to September 2022

Compliance with the SRCP is a condition of authorisation under Article 82(1) of the Act. SRCP3. 4. 1 (effective from 31 October 2019 to 11 September 2022) states:

"1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:

b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
c. understanding the impact of interactions on customers and the effectiveness of the licensee's actions and approach."

The licensee acknowledged that at the time of the assessment:

Interactions were often not tailored to specific customer journeys or scope of harm and therefore the interactions were not meaningful.
Early risk detection systems were not clearly effective in understanding the impact of individual interactions on client behaviour and whether further action was required.
The approach to the assessment did not allow for effective checking whether customers had read and understood information and advice provided in customer interactions.

The regulatory arrangements were as follows:

Pay £343. Pay £343. 035 in lieu of a fine, which will be put towards socially responsible activities.
Consent to publish a statement of facts in the matter.
Pay £15. 684, 50 towards the Commission's investigation costs.

In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:

Aggravating factors

There were repeated violations or defaults by the operator.
The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
The continuation of violations after the licensee became aware of them
The scale of the violations of the license conditions across licensed entities
The impact on customers and the public
The absence of internal controls or procedures designed to prevent the violations
The duration of the violations

Mitigating factors

The extent of the measures taken to remedy the violations
Timely cooperation with any investigation conducted by the Commission.

Good practice

Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:

Do they have formal procedures in place to measure the effectiveness of their anti-money laundering and problem gambling measures and properly record the results?
Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
Have you incorporated lessons learned from published content into your policies and procedures?
Are financial sanctions checks carried out before a new client's first deposit?
Are client risk profiles updated or linked to ML and TF risk assessments?
Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
Do your employees receive appropriate anti-money laundering and social responsibility training?

Publication closed

Hillside (UK Sports) ENC Public Statement

Published: 4 April 2024

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
Gamble will be performed in a fair, safe and open way.
Make sure that children and other vulnerable are not damaged or exploited by gambling.

The Gambling Commission has commenced a regulatory review of Hillside (UK Sports) Enc (MiceneEs) following a compliance assessment carried out in March 2022.

Regulatory officials revealed that there was a defect in the procedures for licensing to prevent money laundering (ML) and protect individuals from gambling damage and exploitation.

Licensei does not comply with the following license conditions and implementation norms (LCCP):

The license conditions 12. 1. 1 are obliged to follow the prevention of ML and terrorist funding (TF) from May 2021 to July 2022.
From October 2021 to September 2022, a social responsibility standard (SRCP) 3. 4. 1, which calls for a franchhaie to treat customers in a way to minimize the risk of gamblin g-related damage, is 1B. And 1C section.

In consideration of the rescue measures taken by Licensee, Licensee pays a total of £ 239. 085 in accordance with statements on the principles of licensing and regulations.

The review of our surveys and the subsequent regulations revealed that Licensei did:

Breached paragraph 2 of licence condition 12.1.1 between May 2021 and July 2022

The licensee acknowledged that at the time of its assessment:

Knowledge of customer activity behavior was not effective in managing ML risks.
We did not carry out financial sanctions check (opened on a new tab) before the first payment of new customers.
We did not conduct an independent verification check, and rely on our customers' sel f-verification once on customer knowledge about customer details such as identification.
Its process documentation had insufficient detail on who was considered "at risk" and "not at risk" in the customer risk profile.

Failed to comply with paragraphs 1b and 1c of Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction) between October 2021 to September 2022

Compliance with the SRCP is a condition of authorisation under Article 82(1) of the Act. SRCP3. 4. 1 (effective from 31 October 2019 to 11 September 2022) states:

"1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:

b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
c. understanding the impact of interactions on customers and the effectiveness of the licensee's actions and approach."

Licensee accepted the following at the time of evaluation:

Interactions were often not tailored to specific customer journeys or scope of harm and therefore the interactions were not meaningful.
Early risk detection systems were not clearly effective in understanding the impact of individual interactions on client behaviour and whether further action was required.
The approach to the assessment did not allow for effective checking whether customers had read and understood information and advice provided in customer interactions.

The regulatory arrangements were as follows:

Payment of £239. 085 in lieu of a penalty, which will be put towards socially responsible activities.
Consent to publish a statement of facts in the matter.
Pay £15. 684, 50 towards the Commission's investigation costs.

In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:

Aggravating factors

There were repeated violations or defaults by the operator.
The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
The continuation of violations after the licensee became aware of them
The scale of the violations of the license conditions across licensed entities
The impact on customers and the public
The absence of internal controls or procedures designed to prevent the breaches
The duration of the violations

Mitigating factors

The extent of the measures taken to remedy the violations
Timely cooperation with any investigation conducted by the Commission.

Good practice

Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:

Do they have formal procedures in place to measure the effectiveness of their anti-money laundering and problem gambling measures and properly record the results?
Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
Have you incorporated lessons learned from published content into your policies and procedures?
Are financial sanctions checks carried out before a new client's first deposit?
Are client risk profiles updated or linked to ML and TF risk assessments?
Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
Do your employees receive appropriate anti-money laundering and social responsibility training?

Publication closed

Lindar Media Limited Public Statement

Agreement to the publication of the facts of the matter

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
Gamble will be performed in a fair, safe and open way.
Make sure that children and other vulnerable are not damaged or exploited by gambling.

The impact on customers and the public

The absence of internal controls or procedures designed to prevent the violations

The duration of the violations

The extent of the actions taken to remedy the violations
The timeliness of cooperation with investigations conducted by the European Commission
Gaming operators should take into account the failures uncovered in this investigation to ensure industry learning. Operators should consider the following questions:
Do they have a formal process in place to measure the effectiveness of their anti-money laundering and safer gambling policies?
Are they able to effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
Are they incorporating lessons learned from public disclosures into their policies and procedures?
Are financial sanctions checks being carried out before a new customer makes their first deposit?

Are customer risk profiles updated or linked to ML and TF risk assessments?

Interactions were often not tailored to specific customer journeys or harm spectra, which made the interactions less meaningful.

The early risk detection system was clearly not effective in understanding the impact of individual interactions on customer behaviour and whether further action was required.
The assessment approach did not allow for effective verification that customers had read and understood the information and advice provided in their interactions.
Contents of the regulatory settlement
Payment of £239. 085 in lieu of a fine, to be put towards socially responsible activities.
Agreement to the publication of the facts of the matter
Payment of £15, 684. 00 to contribute £50 towards the costs of the Commission's investigation.

In considering an appropriate solution for this investigation, the Commission took into account the following aggravating and mitigating factors:

Breach of paragraph 1 of licence condition 12.1.1

There were repeated breaches or defaults by the business.

The infringements occurred in circumstances similar to those faced by the Commission in the past, resulting in the publication of lessons to be learned for the wider industry.

If the violations continued after the licensee became aware of them
The scale of the breaches of the license conditions across licensed entities
The impact on customers and the public
The absence of internal controls or procedures designed to prevent the breaches

The duration of the breaches

The extent of the actions taken to remedy the breaches
The timeliness of cooperation with investigations conducted by the European Commission
Gaming operators should take into account the failings uncovered in this investigation to ensure industry learning. Operators should consider the following questions:
Do they have a formal process in place to measure the effectiveness of their anti-money laundering and safer gambling policies?
Are they able to effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?

Breach of paragraph 2 of licence condition 12.1.1

Are financial sanctions checks carried out before a new customer makes their first deposit?

Are customer risk profiles updated or linked to ML and TF risk assessments?
Do you have a formal process for analysing the effectiveness of customer interactions and ensuring that reviews are appropriately documented and consistent in their approach?

Breach of paragraph 3 of licence condition 12.1.1

Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?

Have your employees received appropriate anti-money laundering and social responsibility training?

Failure to take into account Ordinary Code Provision 2.1.1

Public Statement End

Published: 20 September 2023

Our public statement refers to breaches of the requirements of the Licence Conditions and Code of Practice (LCCP). In some cases, the requirements have since been updated.
Operators are expected to review their practices to consider the issues set out below and to identify and implement improvements in the management of customer accounts.
Licensed gaming operators have a legal duty to ensure that their gaming premises are provided in accordance with the Gaming Act 2005 (opens in a new tab) (ACT), the conditions of their licence and the following licence objectives:

Breach of licence condition 15.2.1 (4) - Reporting key events

To prevent gambling from causing, being associated with or being used to support crime or disorder.

Ensuring that gambling is conducted in a fair, safe and open manner.

Protecting children and other vulnerable people from harm and exploitation through gambling.

Breach of licence condition 1.2.1(3) - Specified management offices – personal management licences

The Gambling Commission has commenced a regulatory review of Lindar Media Limited (the Licensee), which holds Combined Distance Operating Licence 051250-R-328289-006, following a compliance assessment carried out in September 2022.

The regulatory review found deficiencies in Lindar Media Limited's processes aimed at preventing money laundering (ML) and protecting individuals from harm and exploitation through gambling.

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

Failure to comply with paragraph 1b, 1c and 2 of SRCP 3.4.1 (Customer Interaction)

Compliance with the SRCP is a condition of authorisation under Article 82(1) of the Act. SRCP3. 4. 1 (effective from 31 October 2019 to 11 September 2022) states:

"1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:

Licence condition 15. 2. 1(4) - requires franchisees to notify the Commission of certain significant events, such as the appointment or loss of key personnel.
b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
(SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.

SRCP 5. 1. 6 - Licence requirements comply with the Advertising Code.

SRCP3. 1. 1(2) - requires licensees to make an annual gambling problem contribution.

Taking into account the corrective actions taken by Lindar Media Limited before and immediately after the compliance assessment and in accordance with the Commission's Statement of Authority for Licensing and Regulation, Lindar Media Limited will pay a total of £690. 947.
European Commission compliance assessment and subsequent regulatory review:

Linder Media Limited's deficiencies in the implementation of AML policies, procedures and controls

Identify

Failures in responsible policies, procedures, controls and practices
Failures in reporting significant events
The head of the gambling compliance function (Regulatory Compliance Officer) held other management roles without European Commission approval.

Interact

Failure to promote marketing products in a socially responsible manner.

Failure to comply with SRCP 5.1.6 - the advertising codes

Failure to make annual financial contributions to organisations supporting research, prevention and treatment of people harmed by gambling.

Our investigation and subsequent regulatory review found that Lindal Media Limited was in breach of the following:

License Status 12: "Licensees must carry out an assessment of the risk that their business will be used for money laundering and terrorist financing. The risk assessment must be appropriate and must be reviewed as necessary in light of changing circumstances, including the introduction of new products or technologies, new ways in which customers pay, changes in customer demographics, or other significant changes."

The licensee did not carry out an adequate ML and TF risk assessment:

Failure to comply with SRCP 3.1.1(2) – Combating problem gambling

Customers

Payment instruments

The regulatory arrangements were as follows:

New risks Operator management
Consent to publish a statement of facts in the matter.
Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present higher ML and TF risks, having taken all other relevant factors into account (para. 2. of the AML Guidance).

In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:

Aggravating factors

The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
Licence condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has in place appropriate policies, procedures and controls to prevent money laundering and terrorist financing.

Mitigating factors

The following procedures and controls were not adequate:

At the time of customer registration, all customers were automatically assigned a low ML risk score.
At the start of the business relationship, there was insufficient information about the customer to fully establish a profile and assess the ML or TF risk, which resulted in excessive reliance on economic triggers to identify and manage ML risk.
The Commission finds that the licensee had in place triggers other than economic triggers.
The licensee did not carry out an adequate ML and TF risk assessment:
Customers

Good practice

Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:

Additional inherent risks
New risks
Operator controls
Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
Disproportionate spending – Casino operators should obtain information about the financial resources of customers to enable them to determine whether their spending is proportionate to their income or wealth (AML Guidance para. 2. 22).
Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
When a customer is a national of a third country and has applied for residence or citizenship in that country in exchange for a transfer of capital, purchase of real estate, purchase of government bonds or investment in a legal entity in that country (AML Guidance para. 6. 33).
License Condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has adequate policies, procedures and controls in place to prevent money laundering and terrorist financing.

Notes

The following procedures and controls were not adequate:

Publication closed

Done Bros (Cash Betting) Limited Public Statement

There was insufficient information about customers at the start of the business relationship to fully establish a profile and assess their ML or TF risk.

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Customers

Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
Additional inherent risks
Make sure that children and other vulnerable are not damaged or exploited by gambling.

Furthermore, the ML and TF risk assessment did not specifically address certain important risk factors set out in the Money Laundering Regulations 2017 (Regulations) and the Prevention of Money Laundering and Combating Terrorist Financing (PDF)(opens in a new tab) (February 2021) (AML Guidance), such as:

Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present higher ML and TF risks, having taken all other relevant factors into account (para. 2. of the AML Guidance).

Disproportionate spending – casino operators should obtain information about customers’ financial sources to be able to determine whether their spending is proportionate to their income or wealth (AML Guidance para. 2. 22).
The business relationship takes place in unusual circumstances (AML Guidance section 6. 33)

The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).

The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).

License condition 12: “When a risk assessment has been completed and a review of the assessment has been carried out, the licensee must ensure that adequate policies, procedures and controls are in place to prevent money laundering and terrorist financing.”
The following procedures and controls were not adequate:

At the time of customer registration, all customers were automatically assigned a low ML risk score.

Breached licence condition 12.1 Prevention of money laundering and terrorist financing

Breach of paragraph 1 of licence condition 12.1.1

There were repeated breaches or defaults by the business.

Therefore, there was excessive reliance on economic triggers to identify and manage ML risk.

The Commission acknowledges that the licensee had triggers other than economic triggers.

The specific fund limit set to determine the risks related to ML and TF was set to the level that allows customers to deposit £ 10. 000 and lose, but this amount is appropriate for risk. I didn't think it was based. Other triggers did not prevent some customers from losing £ 10. 000 in a short period of time. Officials have taken aggressive measures for Licensei to deal with this issue, and acknowledges that this problem is currently being corrected.
Licensing conditions 12: "Licensei is effectively implemented with these policies, procedures, and management, are constantly revised, and appropriate to maintain the effects, We must guarantee that we are taking into account.
The policy and procedure had been reviewed, but it was not reviewed in a timely or necessary frequency to take into account the guidance published by the committee. There was no signature of Money Laundering Reporter (MLRO). Officials have acknowledged that Licensei had taken measures to deal with this issue.

Breach of paragraph 2 and 3 of licence condition 12.1.1

The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.

It did not follow the requirements specified in the guidance section 2 that requires threats, vulnerabilities, and results.

In order to reflect the guidance in the AML policy, it did not deal with customer risks appropriately.
Licensei's AML policy had measures against customer default (CDD) and reinforced duployment (EDD), but they were not necessarily implemented effectively.
If an important event occurs, the committee is notified as soon as possible, as soon as possible, in any case, in any case, in any case, in any case, in any case, in any case, in the format or method specified by the committee. I have to do it.
Licensei did not notify the European Commission when the Chief Compliance Officer, who had been in the job from August 1, 2019 to June 14, 2022).
The committee has found that Franchisie violated the conditions of 15. 2. 1 in the license between June 20, 2022 and September 2022.
"The person in charge of the franchise gaming regulation compliance function must not be a designated manager, except in the case of a clear approval of the committee."
- At the time of the evaluation, those who were in charge of regulatory compliance were also multiple designated managers without obtaining the explicit approval of the committee.
- The committee has found that Licensei violated the license conditions 1. 2. 1 (3) between June 20, 2022 and October 3, 2022.
- The compliance with SRCP is a condition of the license according to Article 82, Paragraph 1 of the Act. SRCP3. 4. 1 (valid from October 31, 2019 to September 11, 2022) is described as follows:
Failed to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)

"1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:

"1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:
- Licence condition 15. 2. 1(4) - requires franchisees to notify the Commission of certain significant events, such as the appointment or loss of key personnel.
- b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
- (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
1. SRCP 5. 1. 6 - Licence requirements comply with the Advertising Code.
The scope of the financial trigger, which is safe and no n-money, is used to actively identify when the customer may be harmful, and may be deposited at a particularly high percentage. New customers were not necessarily effective.
- License had no process to identify customers who are at risk of harmful harm in gambling in real time, or to respond early and promptly.
- Authorities have a Licensee's official customer-compatible guidance in the following fields "customer support-official guidance for remote gambling operators (opened on new tabs) (July 2019) 1 (July 2019) 1 (CI Guidance) "I didn't see how well I took into account:
- The applied procedures were almost always identified, for gambling harm, danger, or dialogue with customers. The committee hopes that Licensei will be able to monitor customer activities and dialogue early and quickly. A review of a customer account confirmed that there was no management system to intervene until the money was lost, and that there were customers who could lose more than £ 10. 000 (CI guidance, paragraph 2. 9).
- Some customers who were unbalanced customers related to the customer's personal situations have been deposited and have not been dealt with until they lose.
- When the financial situation was considered, the model rely on the court's ruling and bankruptcy data to identify the margin concern, but this may not necessarily be effective in identifying the client (CI Guidance). Section 2. 10 & amp; amp; 2. 11).
The regulatory arrangements were as follows:
- On June 29, 2022, an advertisement posted by a franchisie agent was published on Reddit on the MRQ website. The ad was drawn three Spide r-Man figures.
- Consent to publish a statement of facts in the matter.
- In each case, the displayed images were particularly likely to appeal to children. The European Commission has acknowledged that Franchiage had taken this advertisement and then took prompt measures to delete them.
In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:

Aggravating factors
- The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
- The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
- The content of this reconciliation is as follows:
Mitigating factors
- Pay £ 690. 947 instead of fine, which includes £ 50. 947 assets. This fund is used for socially responsible activities.
- Agree to publish facts about this matter
- Payment of the European Commission's investigation costs
Good practice

Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
- The serious nature of the discovered violation
- Impact on license purposes
- The violation occurred in a situation similar to the case that the committee handled in the past in the past, as a result, a lesson to be learned in a wider industry.
- Due to the nature of the violation, it may have affected other customers that the committee did not consider.
- Licensei
- Immediately taking measures to correct the identified violation, some, in some cases, made changes before the compliance evaluation.
- License Condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has adequate policies, procedures and controls in place to prevent money laundering and terrorist financing.
Notes

The first opportunity accepted the violation.
Publication closed
Videoslots Limited Public Statement

He fully cooperated with the European Commission.

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Are all important incidents a proper procedure so that the European Commission is reported in a timely manner?
- Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
- Is it possible to effectively record all decisions related to compliance and provide evidence of continuous evaluation, evaluation, and improvement according to the request of the committee?
- Is the lessons learned from the public statement reflected in your policy and procedure?
Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?

Do you have a formal process to analyze the effectiveness of interacting with customers to make sure that the reviews are properly documented and the approach is consistent? Agreement on publishing facts about this matter

Payment of the European Commission's investigation costs
- In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
- The serious nature of the discovered violation
Impact on license purposes

The violation occurred in a situation similar to the case that the committee handled in the past in the past, as a result, a lesson to be learned in a wider industry.
- Due to the nature of the violation, it may have affected other customers that the committee did not consider.
- Licensei
Immediately taking measures to correct the identified violation, some, in some cases, made changes before the compliance evaluation.

Breach of licence condition 12.1.1(3)

All related facts were disclosed in a timely manner.

The first opportunity accepted the violation.
- We proposed reconciliation by regulatory authorities early.
- He fully cooperated with the European Commission.
- Gambling operators should take into account the weaknesses revealed in this survey and to learn by the industry. The operator needs to consider the following questions:
- Is an official process for measuring the effectiveness of AML and more secure gambling policies, and the results are appropriately recorded?
Failure to comply with SRCP 3.4.1 Customer interaction

Are all important incidents a proper procedure so that the European Commission is reported in a timely manner?

Is gambling product and service marketing performed in a socially responsible way? Are you complying with the advertising practice issued by the Advertising Practice Committee (CAP) and the Advertising Practice Committee (BCAP)? Please understand the latest advice from the CAP about gambling, betting, games "(Appeal to Children" (May 2023) (Open on a new tab)

"1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:
- Is the lessons learned from the public statement reflected in your policy and procedure?
- Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
- (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
Payment of the European Commission's investigation costs

In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
- The serious nature of the discovered violation
- Impact on license purposes
- The violation occurred in a situation similar to the case that the committee handled in the past in the past, as a result, a lesson to be learned in a wider industry.
Due to the nature of the violation, it may have affected other customers that the committee did not consider.
- Licensei
- Immediately taking measures to correct the identified violation, some, in some cases, made changes before the compliance evaluation.
- All related facts were disclosed in a timely manner.
- The first opportunity accepted the violation.
- We proposed reconciliation by regulatory authorities early.
- He fully cooperated with the European Commission.
- Gambling operators should take into account the weaknesses revealed in this survey and to learn by the industry. Operator needs to consider the following questions:
Is an official process for measuring the effectiveness of AML and safer gambling policies and records the results appropriately?
- Are all important incidents a proper procedure so that the European Commission is reported in a timely manner?
- Is gambling product and service marketing performed in a socially responsible way? Are you complying with the advertising practice issued by the Advertising Practice Committee (CAP) and the Advertising Practice Committee (BCAP)? Please understand the latest advice from the CAP about gambling, betting, games "(Appeal to Children" (May 2023) (Open on a new tab)
- Is it possible to effectively record all decisions related to compliance and provide evidence of continuous evaluation, evaluation, and improvement according to the request of the committee?
- Is the lessons learned from the public statement reflected in your policy and procedure?
Conclusion

Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?

In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:

Aggravating factors:
- Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
- The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
- Do your staff have appropriate training on ant i-bowl and social responsibilities?
- 1 This guidance has lost its effect on September 11, 2022.
Mitigating factors:
- Discontinuation
- Published: July 18, 2023
- Our public statement describes violations of license conditions and LCCP requirements (LCCP) that were valid at the time of violation. In some cases, the requirements may be updated.
- Operators are hoped that they will reconsider their practices in order to address the questions described below, identify and implement customer account management.
Good practice

A licensed gambling operator has a legal obligation to guarantee that gambling facilities will be provided according to the 2005 gambling method (law) (law) (law) (law), approval conditions, and the purpose of approval.
- Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
- Gamble is performed in a fair and open way.
- Protect children and other vulnerable so that they are not damaged or exploited by gambling.
Notes

This survey is following the compliance evaluation and Done BROS (CASH BETTING) Limited (License/Done Bros) non-remote general betting standard, pool betting, auxiliary remote license number: 001058- N-102469-014 regulatory reviews 116. It has started. Regulatory officials found that the license procedure was inadequate to prevent more secure gambling (SG) and money laundering (ML).

From January 2021 to December 1, 2022, Done Bros did not comply with specific license conditions and implementation norms (LCCP):
Publication closed
Skill On Net Limited Public Statement

Under paragraphs 1 and 2 of the Social Responsibility Code 3. 4. 1, franchisees are required to engage with customers in a manner that minimises the risk of gambling-related harm to them and to take into account the European Commission's guidance on how to engage with customers.

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Customers
- Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
- Additional inherent risks
- Make sure that children and other vulnerable are not damaged or exploited by gambling.
The Licensee admitted that it breached this Licence Condition because its ML/TF risk assessment did not adequately reflect the European Commission's expectations and did not take sufficiently into account the European Commission's ML/TF risk assessment of the UK gambling industry.

The failures were that the Licensee's ML/TF risk assessment:
- Failed to take sufficient account of the European Commission's latest POCA guidance.
- Failed to demonstrate that all risks to the operation had been considered, for example risks associated with third party suppliers, payment providers and processors and customers using prepaid cards.
- Failed to demonstrate that all risks to the operation had been considered, including risks associated with third party suppliers, payment providers and processors and customers using prepaid cards.
- Failed to demonstrate that it had taken into account potential ML It details the risks and measures to monitor customer transactions across many licensed bookmakers, products and platforms to mitigate them.
License Condition 12: "Once a risk assessment has been completed and taking into account any review of the assessment, the licensee must satisfy itself that it has adequate policies, procedures and controls to prevent money laundering and terrorist financing."

The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
- While analysis of certain customer records identified in the regulator's review found no evidence that the licensee had committed a crime, the licensee nevertheless admitted to breaching this licence condition as well:
- There were weaknesses and deficiencies in relation to the adequacy and maintenance of policies and procedures, and their implementation.
Record-keeping was inadequate and financial notices (thresholds) were set too high. For example, customer A lost approximately £61. 000 over a four-month period, but no action was taken because the licensee had previously concluded that there were "no AML concerns". As the licensee relied solely on ID documents, no action was taken against this customer even when further checks were completed.

Breach of paragraph 1 of licence condition 12.1.1

There were repeated breaches or defaults by the business.

There was excessive reliance on open source information and further steps should have been taken to verify the SoF information of the customer.

Some customers were able to bet large sums of money without the Licensee carrying out adequate KYC checks. For example,
- Customer A made a net loss of £61. 000 in 4 months without adequate KYC being carried out.
- Customer C made bets and lost £72. 000 within 9 months because the Licensee relied on unverified open source information.
- Customer D bet £429. 222 and lost £120. 353 within 11 months because the Licensee relied on unverified open source information.
Breach of paragraph 2 of licence condition 12.1.1

Compliance with the SRCP is a condition of a licence under section 82(1) of the Act. SRCP 3. 4. 1 (amended 31 October 2019) states:

"1. Licensees must deal with customers in a manner that minimises the risk to them of gambling-related harm. This includes:

a. identifying customers who may or may suffer or suffer gambling.
- b. To contact customers who are in danger of harm or experienced gambling.
- c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach.
- Licensei should take into account the European Commission's guidance on interaction with customers. "
- Licensei acknowledged that it was not completely compliant with SRCP 3. 4. 1:
Breach of paragraph 3 of licence condition 12.1.1

The management system to protect new customers was inadequate, monitoring hig h-speed play and play time costs that expose customers to great risks without dialogue with SG.

He assumed that the customer had no risk just because he gained a customer. For example, Franchisy did not interact with customers (customer E) with £ 517. 499 between March 21, 2022 and May 18, 2022. The basis was that Licensei was a professional poker player, signed a sign that encouraged the staff, and was expected to gain £ 8. 585 during the period. The customer has been able to participate in the total amount of net assets close to the entire net asset within two months (based on the open source check performed by Licensei), and it was found to be SG.

a. identifying customers who may or may suffer or suffer gambling.
- The exchange they went to was not always effective. For example, the client F played for five months, deposited £ 337. 029, lost £ 19. 336, 28, and made a total of 1. 375 bets. The customer exchanged twelve times, pointing out that franchisies show that their exchanges are positive and their customers are satisfied with their spending levels. However, in some exchanges, customers showed signs of potential harm, such as decreasing cards and big bets. The exchange has not been escalated, and there is no evidence that the customer has provided information and support. The only factor that seems to have been considered is whether the customer seems to be satisfied with continuing the bet.
- There was a lack of evidence to evaluate the effectiveness of exchanges with individual customers, and the preservation of records was insufficient, so the effectiveness of future exchanges was restricted.
- This regulation settlement consists of the following:
- Pay a total of 3. 250. 000 pounds instead of a fine, and use it for socially responsible activities.
Breach of paragraph 1 of licence condition 12.1.2 (Anti-money laundering - measures for operators based in foreign jurisdictions)

Agree to publish facts about this matter

Payment of the committee's expenses required to conduct the survey

In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
- The serious nature of the discovered violation
- Impact on license purposes
- Licensei executives must have recognized the problem of governance that leads to violations due to their seriousness.
Failure to comply with SRCP 3.4.1 paragraphs 1 and 2

The degree of measures taken to correct the violation-Did Franchiage implement an early action plan to correct the failure?

"1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:
- Is the lessons learned from the public statement reflected in your policy and procedure?
- Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
- Is it at least once a year to review the ML/TF risk assessment, measure the effectiveness of SG and SG policies and procedures, and introduce a formal process for appropriately document?
1. Is all compliance decisions effectively? Can the European Commission be shown to the European Commission in response to the request for continuous evaluation, evaluation, and improvement?
Are the published statements and lessons learned from other regulation decisions properly incorporated into their policy and procedures?
- Is customer risk profile reviewed in light of new information?
- Do you have a formal process to analyze the effectiveness of dialogue with customers so that reviews are properly documented and performed with a consistent approach?
- Do you record the types of behaviors that triggered the dialogue with customers, and keep the appropriate record of dialogue, especially with the dialogue, in connection with the detailed levels provided?
Did the employee take appropriate AML and social responsibilities?
- 1 This date indicates a overall violation period, and there are some differences in individual violations in each state.
- Announcement end date
- Publication: June 15, 2023 Pay a total of 3. 250. 000 pounds instead of a fine, and use it for socially responsible activities.
- Agree to publish facts about this matter
- Payment of the committee's expenses required to conduct the survey
- In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
The serious nature of the discovered violation
- Impact on license purposes
The regulatory arrangements were as follows:
- The degree of measures taken to correct the violation-Did Franchiage implement an early action plan to correct the failure?
- Consent to publish a statement of facts in the matter.
- The European Commission's survey results were accepted early and voluntarily, and the regulation settlement procedures were requested in a timely manner.
- Gaming operators should take into account the failures revealed in this survey to ensure the study in the industry. The operator should consider the following questions:
In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:

Aggravating factors:
- Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
- The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
- Is customer risk profile reviewed in light of new information?
- Do you have a formal process to analyze the effectiveness of dialogue with customers so that reviews are properly documented and performed with a consistent approach?
Mitigating factors:
- Do you record the types of behaviors that triggered the dialogue with customers, and keep the appropriate record of dialogue, especially with the dialogue, in connection with the detailed levels provided?
- Did the employee take appropriate AML and social responsibilities?
- 1 This date indicates a overall violation period, and there are some differences in individual violations in each state.
Good practice

Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
- Additional inherent risks
- Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
- Payment of the committee's expenses required to conduct the survey
- In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
- The serious nature of the discovered violation
Notes

Impact on license purposes
Publication closed
William Hill Organization Limited Public Statement

The degree of measures taken to correct the violation-Did Franchiage implement an early action plan to correct the failure?

Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.

Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.

Introduction

Customers
- Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
- Additional inherent risks
- Make sure that children and other vulnerable are not damaged or exploited by gambling.
Is customer risk profile reviewed in light of new information?

Do you have a formal process to analyze the effectiveness of dialogue with customers so that reviews are properly documented and performed with a consistent approach?

Do you record the types of behaviors that triggered the dialogue with customers, and keep the appropriate record of dialogue, especially with the dialogue, in connection with the detailed levels provided?
- Disproportionate spending – casino operators should obtain information about customers’ financial sources to be able to determine whether their spending is proportionate to their income or wealth (AML Guidance para. 2. 22).
- The business relationship takes place in unusual circumstances (AML Guidance section 6. 33)
Announcement end date

Published: June 15, 2023
- License condition 12: “When a risk assessment has been completed and a review of the assessment has been carried out, the licensee must ensure that adequate policies, procedures and controls are in place to prevent money laundering and terrorist financing.”
- Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
- A licensed gaming carrier has a legal obligation to guarantee that the gaming facility will be provided according to the 2005 gaming method (open on a new tab) (ACT), the conditions of the license, and the following license purposes.
Prevents gambling from being caused by crime, disorder, being associated with crime, or being used to support crime.

Breach of paragraph 1 of licence condition 12.1.1

Gamble is performed in a fair and open way.

Therefore, there was excessive reliance on economic triggers to identify and manage ML risk.

Following two compliance reviews, the survey led to the launch of a limited remote video review and video composite license: 039380-R-319311-032.
- Reviews of regulatory authorities revealed that there was a defect in the implementation of video procedures designed to prevent money laundering (ML) and secure safer gaming.
- 2 from October 2019 to February 2022, videos did not comply with specific license conditions and implementation norms (LCCP), specifically:
- Paragraph 3 of the license conditions 12. 1. 1 has been r e-implemented in Licensei effectively, procedures, and management, and is always reviewed, and is appropriately reviewed, and has been published by the Gambling Committee. We are seeking to consider the applicable learning or guidance.
Breach of paragraphs 2 and 3 of licence condition 12.1.1

The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.

Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?

What was revealed in our surveys and the underlying regulatory authorities.
- Inadequate money laundering prevention (AML) policy, procedure, management system
- Responsible gambling operators' drawbacks in management and comparison, and weaknesses in implementation of existing procedures and management policies.
 - We discovered that a video slot machine was installed:
 - In the licensed conditions 12. 1. 1 (3), "Licensei has been revised appropriately so that these policies, procedures, and management are performed effectively, are constantly reviewed, and continuing to be effective, and the gambling committee. It must be taken into account the applicable knowledge or guidance to be announced at any time. "
 - It turned out that the video slot machine violated this license for the following reasons between March 2021 and April 2022:
 - For example, customer A violated multiple AML trigger rules and could not deposit £ 112. 225. AML analysts did not take all the actions required by the AML policy and procedure of Licensei. Similar failures were seen by other customers
 Under the ris k-based approach, it did not satisfy the elements of the customer Dew Dirgence, which had been assumed for a long time.
 
 Failure to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 - Is the lessons learned from the public statement reflected in your policy and procedure?
 - Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 - (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 Payment of the European Commission's investigation costs
 
 The scope of the financial trigger, which is safe and no n-money, is used to actively identify when the customer may be harmful, and may be deposited at a particularly high percentage. New customers were not necessarily effective.
 - c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach.
 - 2. Licensei should consider the guidelines of the European Commission on dialogue with customers.
 - The video slot acknowledged that he had not completely complied SRCP 3. 4. 1 in the following period:
 - SRCP 3. from March 2021 to October 2022
 - SRCP 3. from March 2021 to March 2022
 The regulatory arrangements were as follows:
 - Video Slots admitted to breaching this SRCP for the following reasons:
 - Consent to publish a statement of facts in the matter.
 - Failed to use restrictive measures such as mandatory deposit limits and play blocks as regularly as possible.
 - Failed to consider whether deposits and losses were appropriate and to determine whether customers were at risk of harm. For example, Customer C had a self-reported income of between £60. 000 and £80. 000 and savings of between £20. 000 and £50. 000. This customer deposited and lost £98. 000 over a six-month period, more than all his savings and estimated income combined. Reviews and interactions with this customer did not take into account the fact that this customer was disproportionately paying his declared salary.
 - Allowed customers who showed signs of harm, as well as medium and high-risk customers, to continue gambling large amounts after interactions despite their ongoing behavior. For example, Customer A deposited £112. 225 and lost £58. 725 between 21 November 2021 and 7 January 2022. During this period, this customer hit many triggers, including long periods of gambling, early morning gambling, and losses that exceeded limits based on his declared source of wealth. As a result of the behavior, the licensee completed three account audits (one resulting in the customer's top winners) and sent automated emails. However, for this customer, an account check was not conducted on 8 December 2021 and was postponed to 29 December. The operator's approach to interactions set out in its responsible gambling policies and procedures was not implemented as it should have. The customer did not change their behaviour, which ultimately indicates that interactions were not effective in minimising the risk of harm.
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 - The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 - The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 - A reconstructed penalty package of £ 2. 000. 000 consisting of the following elements was agreed:
 - The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 - The content of this reconciliation is as follows:
 Mitigating factors
 - Agreement on fact announcement by the European Commission
 - £ 11 as a survey cost
 Good Practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 - In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 - Impact on license purposes
 - Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 - Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 - This is the second S116 assessment received by Licensee. In the first assessment, a million pounds were paid.
 - License Condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has adequate policies, procedures and controls in place to prevent money laundering and terrorist financing.
 Notes
 
 Licensee accepted the main failure.
 
 Licensee acted in a timely manner and cooperated in the investigation.
 
 During the examination period, Licensee was transparent and emphasized that Cobbit's trend had a serious effect on business efficiency.
 Publication closed
 WHG (International) Limited Public Statement
 
 The degree of measures taken to correct the violation-Did Franchiage implement an early action plan to correct the failure?
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.
 
 Introduction
 
 Customers
 - Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 - Additional inherent risks
 - Make sure that children and other vulnerable are not damaged or exploited by gambling.
 Our publication mentions violations of license conditions and LCCP requirements (LCCP) that were valid in the event of violation. In some cases, the requirements may be updated.
 
 Operators are hoped that they will reconsider their practices in order to address the questions described below, identify and implement customer account management.
 
 A licensed gambling operator has a legal obligation to guarantee that gambling facilities will be provided according to the 2005 gambling method (law) (law) (law) (law), approval conditions, and the purpose of approval.
 - Prevents gambling from being used to support crime, disorder, associated with crime, disorder, and support crime.
 - Disproportionate spending – casino operators should obtain information about customers’ financial sources to be able to determine whether their spending is proportionate to their income or wealth (AML Guidance para. 2. 22).
 - Protects children and other vulnerable children who are damaged or exploited by gambling.
 - The survey was started to review the regulation of section 116 by Skill On Net Limited, composite remote license number: 039326-R-319358-050. Regulatory officials confirmed that the procedures for more secure gambling and Money Laundering (ML) were defended.
 - From January 2021 to December 1, 2022, Licensei did not comply with the following license conditions and norms (LCCP):
 - Licensing conditions 12. 1. 1, paragraphs 1, 2, and 3 of the license conditions that require Zenophobia and the provision of terrorism (TF).
 Licensing conditions 12. 1. 2 require operators based in foreign jurisdictions to comply with ML, TF and fund transfer (payments information) rules 2017.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 - License condition 12: “When a risk assessment has been completed and a review of the assessment has been carried out, the licensee must ensure that adequate policies, procedures and controls are in place to prevent money laundering and terrorist financing.”
 - There were weaknesses and deficiencies in relation to the adequacy and maintenance of policies and procedures, and their implementation.
 Our survey and subsequent regulatory authorities revealed the following:
 
 Breach of paragraph 1 of licence condition 2.3.1
 
 Policy, procedure, and management were inadequate to comply with Money Laundering Prevention (AML).
 
 Responsible policies, procedures, deficiencies in management and implementation (including weaknesses in implementation).
 - Between January 2021 and December 2022, the capacity of the net was as follows:
 - License status 12: "Licensei must carry out the risks used by the business for money laundering and terrorism funding. Risk evaluation must be appropriate, and new products and new technologies. It must be reviewed as needed, in light of the introduction, new payment methods, changes in customers, or other significant changes.
 - Licensei did not properly reflect the expectations of the committee from May 2021 to December 2022, or did not take into account the ML/TF risk assessment of the British lottery industry committee. Therefore, he acknowledged that he had violated the license conditions.
 Breach of paragraph 1 of licence condition 12.1.1
 
 There were repeated breaches or defaults by the business.
 
 Therefore, there was excessive reliance on economic triggers to identify and manage ML risk.
 
 Following two compliance reviews, the survey led to the launch of a limited remote video review and video composite license: 039380-R-319311-032.
 - Considering the risk information about the ML/TF risk provided by the committee and reviewing it properly.
 - In the license conditions 12. 1. 1 (2), "Once the risk assessment and assessment are reviewed, Licensei must secure a proper policy, procedure, and management system to prevent money launding and terrorism. It will not be. "
 Breach of paragraphs 2 and 3 of licence condition 12.1.1
 
 The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.
 
 Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?
 
 Failed to maintain adequate procedures for investigating clients' salaries and assets and identifying disproportionate expenditure, and relied on client representations to mitigate ML risks;
 - In order to reflect the guidance in the AML policy, it did not deal with customer risks appropriately.
 - Failed to rely on verbal comments and monetary thresholds that were not provided by the licensee when considering disproportionate expenses;
 - Failed to require the applicant to submit an annual report covering the operation and effectiveness of the operator's systems and controls to combat ML and TF, and to take the necessary measures to remedy deficiencies identified by the report in a timely manner. Licence Status 12: "Licensees must ensure that such policies, procedures and controls are effectively implemented, constantly reviewed and appropriately revised to remain effective, taking into account any applicable learning or guidelines issued by the Gambling Commission from time to time.".
 - The Licensee admitted that between May 2021 and December 2022, its policies and procedures did not fully comply with Licence Condition 12. 1. 1 (3).
 - The Commission's concerns included:
 - Failed to take into account the anti-money laundering and counter-terrorist financing measures in force at the time of the assessment.
 - Allowed multiple customers to deposit and lose more than double the £2. 000 limit that the Licensee had in place to mitigate the risk of untested payment methods.
 - Excessive reliance on redirecting gambling winnings, believing that funds won and withdrawn by customers were evidence of funds available until 30 days later.
 - The Licensee assumed that customers were recycling their winnings without obtaining evidence from customers to support this assertion.
 - Clause 1 of this condition It has been in force since October 2016 and requires licensees to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (2017 Regulations).
 
 The licensee admitted that its policies and procedures were not fully complied with and that there had been breaches of licence condition 12. 1. 2 between May 2021 and December 2022.
 
 Standards of the European Commission believe that Franchisie did not properly implement measures stated in the related rules stipulated in the 2017 Regulations:
 
 Franchisie did not take appropriate measures to identify and evaluate the risks of ML and TF.
 
 Franchisie could not establish and maintain an effective policy, procedure, and control.
 
 Breach of paragraph 1 of licence condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)
 
 In accordance with the rules 17 (9), the information provided by the director authorities (Gambling Committee) was not fully considered.
 
 SRCP (1) and (2) are described as follows:
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 a. identifying customers who are risky or may have experienced harm related to gambling.
 
 b. To contact customers who may experience harm related to gambling.
 
 c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach. ".
 
 Licensei should consider the European Commission's guidance on dialogue with customers. "
 
 Under the ris k-based approach, it did not satisfy the elements of the customer Dew Dirgence, which had been assumed for a long time.
 
 Failure to comply with paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 Payment of the European Commission's investigation costs
 
 The scope of the financial trigger, which is safe and no n-money, is used to actively identify when the customer may be harmful, and may be deposited at a particularly high percentage. New customers were not necessarily effective.
 
 Because the procedure was not properly followed, he could not recognize night play as an indicator of harm-one customer acknowledged that he had been working at night with mobile phones for 7 hours.
 
 Relying on automatic po p-ups, he could not effectively dialogue with a specific customer.
 
 In exchange with customers, customers did not effectively minimize the risk of gambling related damage. For example, a customer deposited a total of £ 16, 000 and paid £ 3224, 74 in 41 days. The customer received multiple po p-ups and e-mails of automated secure gaming and received two notifications on activities. Customers performed many secure gambling chat, which provide important information to agent questions, and as a result, customers were able to continue gambling. The franchise exchange was not effective in gaining the necessary information to evaluate whether individuals were at risk. The exchanges conducted were minimal, and the customer's words were received at face value without trying to consider further information or seek further information to support decisio n-making.
 
 The committee is also SRCP 3: franchisie
 
 Failure to comply with paragraphs 1a, 1c and 1d of SRCP 3.7.1 (Provision of Credit)
 
 There was no evidence to suggest that the highly accumulated behavior after the victory was considered as a potential marker of harm (CI Guidance-Section 2.)
 
 The arrangement of this regulation is as follows:
 
 305. Payment of £ 150 to replace the fine.
 
 Agree to publish facts about this matter
 
 9. 079 Payment 00 pounds are used for the European Commission's investigation costs
 
 Within 12 months after the license screening, we agree to implement an independent thir d-party institution for licensing policies, procedures, management, and licensed secure gambling, procedures, and implementation of management. Do it.
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Due to the nature of the violation, it may be affected by other customers who have not considered the committee.
 
 The violation occurred in a situation similar to the case of the European Commission in the past, and as a result, the lessons to be learned in a wider range of industries were published.
 
 Licensei was evaluated three times, but all of them were pointed out that they were incompatible, resulting in prolonged incompatibility.
 
 Failure to comply with paragraph 2a of SRCP 3.9.1 (Identification of individual customers)
 
 Violations have been pointed out after two special measures.
 
 Franchisie is currently taking measures to correct the violations that have been pointed out.
 
 Licensee was not effective in minimizing the risk of gambling damage by interacting with customers who accepted the main violations. For example, a customer deposited a total of £ 16, 000 and paid £ 3224, 74 in 41 days. The customer received multiple po p-ups and e-mails of automated secure gaming and received two notifications on activities. Customers performed many secure gambling chat, which provide important information to agent questions, and as a result, customers were able to continue gambling. The franchise exchange was not effective in gaining the necessary information to evaluate whether individuals were at risk. The exchanges conducted were minimal, and the customer's words were received at face value without trying to consider further information or seek further information to support decisio n-making.
 
 The committee is also SRCP 3: franchisie
 
 There was no evidence to suggest that the highly accumulated behavior after the victory was considered as a potential marker of harm (CI Guidance-Section 2.)
 
 The regulatory arrangements were as follows:
 
 305. Payment of £ 150 to replace the fine.
 
 Consent to publish a statement of facts in the matter.
 
 Failed to use restrictive measures such as mandatory deposit limits and play blocks as regularly as possible.
 
 Failed to consider whether deposits and losses were appropriate and to determine whether customers were at risk of harm. For example, Customer C had a self-reported income of between £60. 000 and £80. 000 and savings of between £20. 000 and £50. 000. This customer deposited and lost £98. 000 over a six-month period, more than all his savings and estimated income combined. Reviews and interactions with this customer did not take into account the fact that this customer was disproportionately paying his declared salary.
 
 Allowed customers who showed signs of harm, as well as medium and high-risk customers, to continue gambling large amounts after interactions despite their ongoing behavior. For example, Customer A deposited £112. 225 and lost £58. 725 between 21 November 2021 and 7 January 2022. During this period, this customer hit many triggers, including long periods of gambling, early morning gambling, and losses that exceeded limits based on his declared source of wealth. As a result of the behavior, the licensee completed three account audits (one resulting in the customer's top winners) and sent automated emails. However, for this customer, an account check was not conducted on 8 December 2021 and was postponed to 29 December. The operator's approach to interactions set out in its responsible gambling policies and procedures was not implemented as it should have. The customer did not change their behaviour, which ultimately indicates that interactions were not effective in minimising the risk of harm.
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 A reconstructed penalty package of £ 2. 000. 000 consisting of the following elements was agreed:
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Licensee was not effective in terms of gamblin g-related risks in interacting with customers who accepted the main violations. For example, a customer deposited a total of £ 16, 000 and paid £ 3224, 74 in 41 days. The customer received multiple po p-ups and e-mails of automated secure gaming and received two notifications on activities. Customers performed many secure gambling chat, which provide important information to agent questions, and as a result, customers were able to continue gambling. The franchise exchange was not effective in gaining the necessary information to evaluate whether individuals were at risk. The exchanges conducted were minimal, and the customer's words were received at face value without trying to consider further information or seek further information to support decisio n-making.
 
 The content of this reconciliation is as follows:
 
 Mitigating factors
 
 Pay £ 690. 947 instead of fine, which includes £ 50. 947 assets. This fund is used for socially responsible activities.
 
 The arrangement of this regulation is as follows:
 
 305. Payment of £ 150 to replace the fine.
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 9. 079 Payment 00 pounds are used for the European Commission's investigation costs
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Impact on license purposes
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 Disproportionate spending – Casino operators should obtain information about the financial resources of customers to enable them to determine whether their spending is proportionate to their income or wealth (AML Guidance para. 2. 22).
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 This is the second S116 assessment received by Licensee. In the first assessment, a million pounds were paid.
 
 License Condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has adequate policies, procedures and controls in place to prevent money laundering and terrorist financing.
 
 Notes
 
 Licensee accepted the main violation
 
 Franchisie acted in a timely manner and cooperated in the investigation.
 
 Gaming operators should take into account the failures revealed in this survey in order to ensure industry learning. The operator should consider the following questions:
 
 Is there a formal process to measure the effectiveness of AML and more secure gambling policy, and the survey results are appropriately recorded?
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Does ML and TF Risk Assessment meet all requirements?
 Publication closed
 Mr Green Limited Public Statement
 
 The degree of measures taken to correct the violation-Did Franchiage implement an early action plan to correct the failure?
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.
 
 Introduction
 
 Customers
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Additional inherent risks
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 Prevents gambling from being caused by crime, disorder, being associated with crime, or being used to support crime.
 
 Gamble is performed in a fair and open way.
 
 Protects children and other vulnerable from gambling damage and exploitation.
 
 Failed to demonstrate that all risks to the operation had been considered, for example risks associated with third party suppliers, payment providers and processors and customers using prepaid cards.
 
 The survey was started to review the regulation of section 116 by Skill On Net Limited, composite remote license number: 039326-R-319358-050. Regulatory officials confirmed that the procedures for more secure gambling and Money Laundering (ML) were defended.
 
 From January 1, 2020 to October 18, 2021, franchisie did not comply with specific license conditions and implementation norms (LCCP):
 
 License conditions 12. 1. 1, paragraph 1, 2 and 3. In order to prevent ML and terrorist funding and terrorism (TF), we will carry out appropriate risks, implement appropriate policies and procedures, and continue to review that such policies are valid. Request that.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 License condition 12: “When a risk assessment has been completed and a review of the assessment has been carried out, the licensee must ensure that adequate policies, procedures and controls are in place to prevent money laundering and terrorist financing.”
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
 
 Instructions, procedures, and management defaults by Admission Management Licensee (AML)
 
 Responsible policies, procedures, control, comparative deficiencies (including implementation weak points)
 
 Breach of paragraph 1 of licence condition 12.1.1
 
 There were repeated breaches or defaults by the business.
 
 Therefore, there was excessive reliance on economic triggers to identify and manage ML risk.
 
 Following two compliance reviews, the survey led to the launch of a limited remote video review and video composite license: 039380-R-319311-032.
 
 Considering the risk information about the ML/TF risk provided by the committee and reviewing it properly.
 
 The inadequate risk assessment of Licensee is as follows:
 
 Not clearly mentions specific risks related to TF.
 
 Breach of paragraphs 2 and 3 of licence condition 12.1.1
 
 The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.
 
 Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?
 
 License status 12: "Following the completion of a risk assessment, and taking into account any review of the assessment, the licensee must ensure that it has appropriate policies, procedures and controls to prevent money laundering and terrorist financing."
 
 In order to reflect the guidance in the AML policy, it did not deal with customer risks appropriately.
 
 Failed to rely on verbal comments and monetary thresholds that were not provided by the licensee when considering disproportionate expenses;
 
 Weaknesses and deficiencies in the adequacy and maintenance of policies and procedures, and their implementation
 
 Some customers identified by the Commission were able to handle large amounts of money without being monitored or inspected to the level expected by the Commission:
 
 Customer A played £34. 000 between 20 May and 1 June 2021, after which a customer profile was created for him, losing £16. 000. A single bet of £19, 000 was charged but no source of funds (SOF) was charged.
 
 Customer B gambled £39, 324 between 16 and 28 October 2020 and lost £20, 360, 67. No documentation was received from the licensee to support the gambling expenditure levels.
 
 Allowed multiple customers to deposit and lose more than double the £2. 000 limit that the Licensee had in place to mitigate the risk of untested payment methods.
 
 The franchisee confirmed that its AML thresholds had since been revised and that it had subsequently amended its betting acceptance process.
 
 The Commission's checks with certain customers identified in the compliance assessment found no evidence that the licensee had incurred punitive costs.
 
 Compliance with the SRCP is a condition of licence under section 82(1) of the Act. SRCP 3. 4. 1 (revised 31 October 2019) states:
 
 Breach of Paragraph 1 of licence condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)
 
 In accordance with the rules 17 (9), the information provided by the director authorities (Gambling Committee) was not fully considered.
 
 SRCP (1) and (2) are described as follows:
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 c. Understand the effects of dialogue with customers on customers, and the effectiveness of licensing and approach.
 
 2) Franchisie must pay attention to the European Commission's guidance on how to interact with customers. "
 
 c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach. ".
 
 Licensei should consider the European Commission's guidance on dialogue with customers. "
 
 Under the ris k-based approach, it did not satisfy the elements of the customer Dew Dirgence, which had been assumed for a long time.
 
 Failure to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 Payment of the European Commission's investigation costs
 
 Licensee has changed the license and agreed to add the following conditions:
 
 At the council level, appoint a sponsor directly to the chairman or the chairman of the executive committee, and be responsible for creating and progressing a 1 2-month action plan to deal with the case activity.
 
 By February 13, 2024, an independent follo w-up audit about the relevant policies and procedures will be implemented to confirm that the independent audit has been implemented effectively. 。
 
 In considering the appropriate solution to this survey, the committee, taking into account the following additional factors and mitigation factors: b. Contact a customer;
 
 c. Understand the effects of dialogue with customers on customers, and the effectiveness of licensing and approach.
 
 2) Franchisie must pay attention to the European Commission's guidance on how to interact with customers. "
 
 Franchisie acknowledged that it was not completely compliant with SRCP 3. 4. 1:
 
 For some customers, franchisie did not confirm the changes in the behavior of customers that should have been caused by the customs of the customer:
 
 Failure to comply with paragraph 1 and 2b of SRCP 3.9.1 (Identification of individual customers)
 
 Only after the customer D bet £ 18, 000 and accepted it, more secure gambling exchanges were performed.
 
 Customer A usually performs a small amount of bed, but has a £ 19, 000 bed. A safer gambling exchange was conducted, and at that time, Customer A stated that "his expense is no problem," but Licensei could not further consider the responsible gambling prospectors.
 
 After locking out of the COVID pandemic, after the retail state was resumed, Licensee allowed customer F to lose £ 10. 600 in two days without a safer gambling exchange.
 
 Despite being beds of £ 42. 253 in three days, the staff did not recognize customer G as a risk of experiencing harmful harm on gambling, and did not interact with customers.
 
 Configuration of this regulation reconciliation
 
 The total payment of £ 2. 999. 850 to replace the fine is for social responsibilities, including £ 244 business. 361. 57
 
 The regulatory arrangements were as follows:
 
 Licensee has changed the license and agreed to add the following conditions:
 
 Consent to publish a statement of facts in the matter.
 
 Failed to use restrictive measures such as mandatory deposit limits and play blocks as regularly as possible.
 
 Failed to consider whether deposits and losses were appropriate and to determine whether customers were at risk of harm. For example, Customer C had a self-reported income of between £60. 000 and £80. 000 and savings of between £20. 000 and £50. 000. This customer deposited and lost £98. 000 over a six-month period, more than all his savings and estimated income combined. Reviews and interactions with this customer did not take into account the fact that this customer was disproportionately paying his declared salary.
 
 Allowed customers who showed signs of harm, as well as medium and high-risk customers, to continue gambling large amounts after interactions despite their ongoing behavior. For example, Customer A deposited £112. 225 and lost £58. 725 between 21 November 2021 and 7 January 2022. During this period, this customer hit many triggers, including long periods of gambling, early morning gambling, and losses that exceeded limits based on his declared source of wealth. As a result of the behavior, the licensee completed three account audits (one resulting in the customer's top winners) and sent automated emails. However, for this customer, an account check was not conducted on 8 December 2021 and was postponed to 29 December. The operator's approach to interactions set out in its responsible gambling policies and procedures was not implemented as it should have. The customer did not change their behaviour, which ultimately indicates that interactions were not effective in minimising the risk of harm.
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 A reconstructed penalty package of £ 2. 000. 000 consisting of the following elements was agreed:
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
 
 The content of this reconciliation is as follows:
 
 Mitigating factors
 
 Pay £ 690. 947 instead of fine, which includes £ 50. 947 assets. This fund is used for socially responsible activities.
 
 £ 11 as a survey cost
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Impact on license purposes
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 Disproportionate spending – Casino operators should obtain information about the financial resources of customers to enable them to determine whether their spending is proportionate to their income or wealth (AML Guidance para. 2. 22).
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 This is the second S116 assessment received by Licensee. In the first assessment, a million pounds were paid.
 
 License Condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has adequate policies, procedures and controls in place to prevent money laundering and terrorist financing.
 
 Notes
 
 Licensee accepted the main violation
 
 Licensei executives must have recognized the problem of governance that leads to violations due to its importance.
 
 The degree of measures taken to correct the violatio n-Licensee has implemented an action plan to correct the violation.
 
 Licensee complied the European Commission's timetable on the provision of materials in the procedure, and requested an extension if such materials could not be provided within the scheduled period.
 Publication closed
 Blue Star Planet Limited Public Statement
 
 Is the AML and more secure gambling policies and the formal procedure to measure the validity of the procedure, and the results are appropriately recorded?
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Is the lessons learned from the public statement reflected in the policy and procedure?
 
 Introduction
 
 Available gambling operators have a legal obligation to guarantee that the gambling facilities will be provided according to the 2005 gambling method (opened on the new tab), approval conditions, and the following approval purpose:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 2. License clause 12. 1. 1 violated between January 1, 2020 and May 2, 2022.
 
 3 AML Guidance and European Commission's ML/TF risk assessment stipulates many factors that must be considered and considered in Licensee when conducting their own ML/TF risk assessment. In addition, Licensei is required to consider these documents when conducting unique ML/TF risk assessments by Article 18 (2) (a) of the Rules.
 
 Announcement fee
 
 Published: March 28, 2023
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.
 
 A licensed gambling operator has a legal obligation to provide gambling facilities according to the 2005 gambling method (law) (law) (law) (law), license conditions, and license purposes.
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 Prevents children and other vulnerable from being damaged or exploited by gambling.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
 
 A licensed gaming carrier has a legal obligation to guarantee that the gaming facility will be provided according to the 2005 gaming method (open on a new tab) (ACT), the conditions of the license, and the following license purposes.
 
 From May 3, 2020 to October 18, 2021, WHG (International) Limited did not comply with specific license conditions and norms (LCCP):
 
 Breach of paragraph 1 of license condition 12.1.1
 
 There were repeated breaches or defaults by the business.
 
 Permit conditions 12. 1. 1 (1, 2, 3 (TF), which will prevent foreigners and terrorist funding (TF), implement appropriate risks and implement appropriate policies and procedures, and these policies are effective. A clause that requires monitoring to confirm that
 
 Licensing conditions 12. 1. 2 requests a remote casino business operator based in foreign jurisdictions to comply with ML, TF, and fund transfer (payments information) rules 2017.
 
 Social liability Code (SRCP) 3. 4. 1 1 and 2. The provisions require franchisei to treat customers with customers in a way to minimize the risk of gamblin g-related harm to customers, and to consider the European Commission's guidance on how to interact with customers.
 
 Breach of paragraph 2 of license condition 12.1.1
 
 License Status 12: "Upon completion of a risk assessment and taking into account any review of the assessment, the licensee must ensure that it has adequate policies, procedures and controls to prevent money laundering and terrorist financing.
 
 Section 2 of SRCP 3. 9. 1 requires licensees to implement policies and procedures designed to identify separate accounts held by the same person, and where a customer holds multiple accounts, licensees must have and implement procedures that enable them to link each of those customer's accounts to each other.
 
 In light of the licensee's corrective actions, and in accordance with the license and regulator's statements, licensee will pay £12. 361. 57, including the sale of £284. 361. 57, and will amend its license and add license conditions.
 
 The investigation and subsequent regulator's review found:
 
 Inadequacies in anti-money laundering (AML) policies, procedures and controls
 
 Breach of paragraph 3 of licence condition 12.1.1
 
 Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?
 
 We found that between 4 May 2020 and 18 October 2021, the Licensee had:
 
 License Condition 2: "The Licensee must comply with the Commission's technical standards and the requirements established by the Commission regarding the timing and procedure of examinations.
 
 The Licensee admitted that it had not fully complied with clause 2. 3. 1:
 
 The Licensee did not ensure that organisational policies and procedures were implemented within the trading room.
 
 There was evidence that certain customer relationships in the trading room were not under the supervision or control of management.
 
 Breach of paragraph 1 of licence condition 12.1.2 (Anti-Money Laundering Measures for operators based in foreign jurisdictions)
 
 Trading desk staff who knew customers' usernames and passwords placed bets at the customers' instructions in their online accounts.
 
 License Condition 12: "The Licensee must carry out a risk assessment of the risk of the business being used for money laundering and terrorist financing. This risk assessment must be appropriate and must be reviewed as necessary in light of changing circumstances, including the introduction of new products and new technologies, new ways in which customers pay, changes in the customer demographics or other significant changes.
 
 The Licensee must not have fully complied with clause 2. 3. 1:
 
 Breach of licence condition 8.1.1 (Display of Licensed Status) 2
 
 The Licensee failed to ensure that organisational policies and procedures were implemented within the trading room.
 
 There was evidence that certain customer relationships in the trading room were not under the supervision or control of management.
 
 Trading desk staff who knew customers' usernames and passwords placed bets at the customers' instructions in their online accounts.
 
 License Condition 13: "The Licensee must carry out a risk assessment of the risk of the business being used for money laundering and terrorist financing. This risk assessment must be appropriate and must be reviewed as necessary in light of changing circumstances, including the introduction of new products and new technologies, new ways in which customers pay, changes in the customer demographics or other significant changes.
 
 The Licensee must not have fully complied with clause 2. 3. 1:
 
 The Licensee failed to ensure that its ML/TF We acknowledge that we breached this licence condition because our risk assessment did not adequately reflect the European Commission's expectations and did not take full account of the European Commission's ML/TF risk assessment of the UK gambling industry.
 
 The weaknesses were that the Licensee's risk assessment:
 
 We found that between 4 May 2020 and 18 October 2021, the Licensee had:
 
 did not specifically mention the use of third parties or agents to conceal the origin of funds played by customers, high limits, or the use of mule accounts by organized crime groups5.
 
 Failure to comply with paragraph 1b, 1c and 2 of Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 
 Licence condition 15. 2. 1(4) - requires franchisees to notify the Commission of certain significant events, such as the appointment or loss of key personnel.
 
 b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
 
 c. understanding the impact of interactions on customers and the effectiveness of the licensee's actions and approach."
 
 Payment of the European Commission's investigation costs
 
 Some clients were allowed to deposit large amounts of money without enhanced customer due diligence (ECDD) in a timely manner.
 
 Failure to provide adequate information to the due diligence team after changes in trigger data delayed the completion of ECDD checks.
 
 Assumed that the fact that some clients were making profits reduced ML risk without gathering evidence to support this assertion. Furthermore, for some clients, the licensee failed to demonstrate that it had sufficient evidence or point to a documented decision that would allow it to assert that reusing client profits reduced ML risk.
 
 It placed undue reliance on open source information and should have taken further steps to verify client Source of Funds (SoF) information.
 
 There were weaknesses in the documented procedures for managing the small number of accounts directly managed by the trading team.
 
 AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Some customers were able to deposit large amounts of money without the licensee having sufficient knowledge of customer checks:
 
 The regulatory arrangements were as follows:
 
 Customer C was a winning customer who was able to place bets through the trading team without adequate monitoring.
 
 The depth and frequency of ongoing account monitoring was lacking, allowing customers to place bets on behalf of unknown third parties, defeating the purpose of licensing – the licensee had information that strongly suggested Customer C was placing bets on behalf of others. When the account was suspended in February 2021, the customer had lost approximately £195.
 
 Customer D had lost £38. 00 between 21 April 2021 and 27 May 2021. The operator's profile established the client was a sales manager, but no financial information was collected.
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
 
 The AML training provided to staff provided insufficient information on the risks and how to manage them.
 
 Mitigating factors
 
 The extent of the measures taken to remedy the violations
 
 Customer B was 71. Deposited £427 and lost £70. 134 without the Licensee having knowledge of the SOF or holding details.
 
 Customer C was a winning customer who was able to place bets through the trading team without proper oversight. The lack of depth and frequency of ongoing account monitoring allowed customers to place bets on behalf of unknown third parties, defeating the purpose of licensing - the Licensee had information that strongly suggested Customer C was placing bets on behalf of others. When the account was suspended in February 2021, the customer had lost approximately £195.
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Additional inherent risks
 
 Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 In so far as it relates to the Money Laundering Regulations (MLR), the requirements of any UK statutory instrument which it amends or replaces must be complied with, whether or not the MLR applies to its business.
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
 
 When a customer is a national of a third country and has applied for residence or citizenship in that country in exchange for a transfer of capital, purchase of real estate, purchase of government bonds or investment in a legal entity in that country (AML Guidance para. 6. 33).
 
 The AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Notes
 
 Some customers were able to deposit large sums without the licensee having sufficient knowledge of customer checks:
 
 Customer B deposited £71, 427 and lost £70, 134 without the licensee having knowledge of the SOF or holding details.
 Publication closed
 Vivaro Limited Public Statement
 
 The lack of depth and frequency of ongoing account monitoring allowed customers to place bets on behalf of unknown third parties, defeating the purpose of licensing – the licensee had information that strongly suggested that customer C was placing bets on behalf of others.
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Customer D had deposited £38. 00 between 21 April 2021 and 27 May 2021.
 
 Introduction
 
 The operator profile established that the client was a sales manager, but no financial information was collected.
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Is it possible to effectively record all decisions related to compliance and provide evidence of continuous evaluation, evaluation, and improvement according to the request of the committee?
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 The franchisee accepts that it has breached this license condition because the above AML failures amounted to a breach of the Money Laundering Regulations 2017, i. e. a breach of the Money Laundering Regulations:
 
 Rule 18 required "relevant persons" to take appropriate measures to identify and access the ML and TF risks to which their activities are subject.
 
 The 19th Rules (1) (a) maintain policies, management and procedures for reducing and managing ML and TF risks specified by the relevant risk assessment implemented by the relevant. I'm looking for something I have to do.
 
 Rules 28 (11) (a) includes reviews of funding sources in order to secure the knowledge of related people related to customer, business, and customer risk profiles. It requires continuous monitoring of the busines s-related relationship.
 
 Rules 33 imposes duty to implement ECDD measures and continuous monitoring in a situation identified as high ML or TF risk.
 
 The business relationship takes place in unusual circumstances (AML Guidance section 6. 33)
 
 SRCP compliance is a condition of a license based on Article 82, Paragraph 1 of the Act. The SRCP 3. 4. 1 (revised on October 31, 2019) is described as follows:
 
 The violation occurred in a situation similar to the case that the committee handled in the past in the past, as a result, a lesson to be learned in a wider industry.
 
 a. identifying customers who may suffer or suffer gambling.
 
 There were weaknesses and deficiencies in relation to the adequacy and maintenance of policies and procedures, and their implementation.
 
 c. Understand the effects of exchanges on customers, and the effectiveness of licensing and approach.
 
 Breach of licence condition 12.1.1.2 and 12.1.1.3
 
 2. Licensee must consider the European Commission's guidance on dialogue with customers.
 
 All related facts were disclosed in a timely manner.
 
 A specific customer who had the risk of harm associated with gambling could not be identified, did not perform sufficiently checking such customers in advance, and did not intervene in relevant situations.
 
 Customer F opened an account on February 15, 2021 and filled the 7. 500 ECDD on February 19, 2021 on February 19, 2021, but the customer profile was completed in 2021 due to delay. It was March 17th. In the last four weeks, customers have lost £ 54. 252, but operators use other effective ways to seek income, perform sufficient checks, and identify the risk of damage. I didn't. Licensei acknowledges that the interaction with customers was shortage at a very early stage.
 
 Customer G has opened an account and lost £ 11. 400 in the first 30 days without sufficient checks to minimize the risk of gamblin g-related damage.
 
 Customer H did not exchange calls until the loss reached 45 pounds.
 
 The 1A section of SRCP is described as follows:
 
 "Licensee, who chose to provide credit to ordinary people who are not gambling operators, must do the following:
 
 a. Check, score, set the credit limit, and have a procedure to increase the amount.
 
 Breach of licence condition 12.1.2.1
 
 In accordance with the rules 17 (9), the information provided by the director authorities (Gambling Committee) was not fully considered.
 
 SRCP (1) and (2) are described as follows:
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 d. Provide a 2 4-hour delay before acknowledging that the amount of the credit limit exceeds the limit set by the operator in advance.
 
 Licensei acknowledged that it was not completely compliant in SRCP 3. 7. 1:
 
 Despite the credit limit of Customer C at £ 70. 000, a £ 100. 000 bet was immediately allowed.
 
 Failure to comply with Social Responsibility Code Provision (SRCP) 3.4.1 Customer Interaction
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 
 Licence condition 15. 2. 1(4) - requires franchisees to notify the Commission of certain significant events, such as the appointment or loss of key personnel.
 
 b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 With no n-effective management, we were able to gamble with WHG (International) Limited, despite the fact that 331 customers were sel f-excluded from Mr Green Limited, another operator in the group. Such customers were sel f-excluded from Mr Green Limited before MR Green Limited was acquired by WILLIAM HILL.
 
 The agreement for this regulation is as follows:
 
 Total £ 12. 361, 57 instead of fine
 
 Agreement to publish facts related to this matter
 
 Licensee agrees to fix the license to add conditions to the license:
 
 To appoint a counci l-level sponsor directly to the chairman or the chairman of the executive committee, and take responsibility for creating and progressing an action plan for 12 months to deal with the activity.
 
 By February 13, 2024, an independent monitoring audit of relevant policies and procedures shall be implemented to confirm that the independent audit has been implemented effectively for further recommendations, procedures, and management.
 
 In considering the appropriate solution to this survey, the committee took into account the following additional factors and the easing factors:
 
 The serious nature of the discovered violation
 
 Impact on license purposes
 
 Having repeated violations or defaults by the operator or other pool companies
 
 The violation occurred in a situation similar to the case that the European Commission encountered in the past, and as a result, the lessons to be learned for a wider area have been published.
 
 Due to the nature of the violation, other customers who did not know the European Commission may have been affected.
 
 Conclusion
 
 Franchisie senior managers should recognize the importance of governance issues that lead to violations.
 
 The degree of measures taken to correct the violatio n-Franchiage implemented an early action plan to correct the violation.
 
 Franchisie complained of the European Commission's timetable on providing materials, and requested an extension if the material could not be provided within the scheduled period.
 
 Early spontaneous committee report s-franchise reports to early spontaneous committees 6.
 
 Gaming operators should pay attention to the mistakes specified in this survey to ensure industry learning. The operator should consider the following questions:
 
 Have you confirmed that your organization's policy and procedure are valid in your trade area?
 
 Good Practice
 
 A licensed gambling operator has a legal obligation to guarantee that gambling facilities will be provided according to the 2005 gambling method (law) (law) (law) (law), approval conditions, and the purpose of approval.
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Impact on license purposes
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 By February 13, 2024, an independent monitoring audit of relevant policies and procedures shall be implemented to confirm that the independent audit has been implemented effectively for further recommendations, procedures, and management.
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 This is the second S116 assessment received by Licensee. In the first assessment, a million pounds were paid.
 
 The AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Publication closed
 Spreadex Limited Public Statement
 
 The violation occurred in a situation similar to the case that the European Commission encountered in the past, and as a result, the lessons to be learned for a wider area have been published.
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Franchisie senior managers should recognize the importance of governance issues that lead to violations.
 
 The degree of measures taken to correct the violatio n-Franchiage implemented an early action plan to correct the violation.
 
 Franchisie complained of the European Commission's timetable on providing materials, and requested an extension if the material could not be provided within the scheduled period.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in the management of customer accounts.
 
 Introduction
 
 Gaming operators should pay attention to the mistakes specified in this survey to ensure industry learning. The operator should consider the following questions:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 The lessons learned from public statements are reflected in your policy and procedure?
 
 Is the customer risk profile updated or linked to the risk assessment of money laundering and terrorism? To appoint a counci l-level sponsor directly to the chairman or the chairman of the executive committee, and take responsibility for creating and progressing an action plan for 12 months to deal with the activity.
 
 By February 13, 2024, an independent monitoring audit of relevant policies and procedures shall be implemented to confirm that the independent audit has been implemented effectively for further recommendations, procedures, and management.
 
 In considering the appropriate solution to this survey, the committee considers the following additional factors and easing factors:
 
 The business relationship takes place in unusual circumstances (AML Guidance section 6. 33)
 
 Impact on license purposes
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 The violation occurred in a situation similar to the case that the European Commission encountered in the past, and as a result, the lessons to be learned for a wider area have been published.
 
 There were weaknesses and deficiencies in relation to the adequacy and maintenance of policies and procedures, and their implementation.
 
 Breach of paragraph 1 of licence condition 12.1.1
 
 Franchisie senior managers should recognize the importance of governance issues that lead to violations.
 
 The degree of measures taken to correct the violatio n-Franchiage implemented an early action plan to correct the violation.
 
 Franchisie complained of the European Commission's timetable on providing materials, and requested an extension if the material could not be provided within the scheduled period.
 
 Early spontaneous committee report s-franchise reports to early spontaneous committees 6.
 
 Breach of paragraph 2 of licence condition 12.1.1
 
 Gaming operators should pay attention to the mistakes specified in this survey to ensure industry learning. The operator should consider the following questions:
 
 Have you confirmed that your organization's policy and procedure are valid in your trade area?
 
 Is there a formal procedure to measure the gaming policy and the effectiveness of the procedure, and the results are appropriately recorded?
 
 Is it possible to effectively record all decisions on compliance and provide evidence of continuous evaluation, evaluation, and improvement to the European Committee at the request?
 
 The lessons learned from public statements are reflected in your policy and procedure?
 
 Is the customer risk profile updated or linked to the risk assessment of money laundering and terrorism?
 
 Do you have a formal process for analysing the effectiveness of your customer interactions and ensuring that reviews are appropriately documented and consistent in their approach?
 
 Do you record the type of behaviour that triggered your customer interaction and maintain an appropriate record of the interaction, particularly the level of detail provided, along with any decision not to interact?
 
 Breach of paragraph 3 of licence condition 12.1.1
 
 The management system to protect new customers was inadequate, monitoring hig h-speed play and play time costs that expose customers to great risks without dialogue with SG.
 
 1 The European Commission launched its regulatory review on 30 September 2021.
 
 2 WHG (International) Restricted Trading: William Hill Online
 
 3 There is some variation in the start of breaches but they generally fall within this common period. Licensee also noted that breaches of license provisions 2. 3. 1 occurred for an unknown period between December 2020 and February 2021, SRCP 12. 4. 1 between December 4, 2020 and October 18, 2021, SRCP 3. 4. 1, between February 7, 2021 and February 12, 2021, SRCP 3. 7. 1, and between June 2021 and October 2021, SRCP 3.
 
 The lessons learned from public statements are reflected in your policy and procedure?
 
 5 The AML Guidance and the European Commission's ML/TF risk assessment include provisions that Licensee may use to assess its own ML/TF risk assessment. A number of factors are set out that can and must be taken into account when conducting a risk assessment. Furthermore, Article 18(2)(a) of the Regulation requires licensees to take these documents into account when conducting their own ML/TF risk assessment.
 
 6 Licensees have timely and voluntarily reported non-compliance to the Commission, including the issues detailed in Observation 1 (Remote Technology Requirements in A. 7. 2. 2), Observation 6 (SRCP 3. 7. 1), and Observation 7 (SRCP 3. 7. 1).
 
 a. Check, score, set the credit limit, and have a procedure to increase the amount.
 
 Failure to consider Ordinary Code Provision (OCP) 2.1.1 – Anti-money Laundering (Casino) 1
 
 Publication Date: 28 March 2023
 
 Failure to comply with: Social Responsibility Code 3.4.1 2
 
 Our public statements refer to non-compliance with the License Conditions and Code of Practice Requirements (LCCPs) that were in force at the time of the non-compliance. In some cases, the requirements have since been updated.
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 With no n-effective management, we were able to gamble with WHG (International) Limited, despite the fact that 331 customers were sel f-excluded from Mr Green Limited, another operator in the group. Such customers were sel f-excluded from Mr Green Limited before MR Green Limited was acquired by WILLIAM HILL.
 
 Protect children and other vulnerable so that they are not damaged or exploited by gambling.
 
 Following the compliance evaluation, this survey led to the start of the Mr Green Limited (License/MRG), Combined Operating License Number: 000-039264-319432-019 2 section 116 regulation review 1. The regulatory screening revealed that there was a defect in the licensed procedure to prevent more secure gambling and money laundering (ML).
 
 From May 3, 2020 to October 18, 2021, MRG did not comply with specific license conditions and implementation norms (LCCP):
 
 License conditions 12. 1. 1, paragraph 1, paragraphs 2, and 3, in order to prevent ML and terrorism and terrorism (TF), implement appropriate risk assessments, appropriate policies and procedures and procedures. It is obliged to maintain the policy under the review and its effectiveness to ensure its effectiveness.
 
 License status 12. 1. 2 Operators based in overseas jurisdictions are obliged to comply with ML, TF, and fund transfer (payment person information) rules 2017
 
 The regulatory arrangements were as follows:
 
 In paragraphs 1 and 2 of SRCP3. 9. 1, Licensei is required to introduce policies and procedures for identifying separate accounts held by the same person, and customers have multiple accounts. , Licensee must have a procedure to interact with each customer account and introduce it.
 
 Consent to publish a statement of facts in the matter.
 
 The following things have been revealed by our surveys and the underlying regulatory authorities:
 
 Instructions, procedures, and management defaults by Admission Management Licensee (AML)
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 We found that between 20 September 2020 and 22 October 2021, MRG had:
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Licence condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has in place appropriate policies, procedures and controls to prevent money laundering and terrorist financing.
 
 Mitigating factors
 
 The weaknesses were that the licensee's risk assessment did not:
 
 Clearly mention the specific risks associated with TF;
 
 Specifically mention the use of high money thresholds and mule accounts by organised crime groups4.
 
 We found that between May 2020 and 18 October 2021, During the day, we found that MRG had been in:
 
 Good practice
 
 License condition 12: "A licensee must ensure that, on completion of the risk assessment and review of the assessment, it has in place appropriate policies, procedures and controls to prevent money laundering and terrorist financing.
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Impact on license purposes
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 Its policies, procedures and controls lacked guidance on appropriate actions to be taken following the outcome of a customer profile and how the findings should be used to determine an appropriate outcome.
 
 Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
 
 Some customers have been able to deposit large money without a timely manner of enhanced customered dudidritations (ECDD).
 
 After the trigger was changed, the Dudidjence team did not complete the Duddyjence, and the ECDD review was not completed.
 Publication closed
 Ladbrokes Betting & Gaming Limited Public Statement
 
 Excessive dependence on open source information should have taken further measures to confirm customer funding (SOF).
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 The European Commission has revealed that some customers have deposit large amounts of money without the appropriate dudillization on customer checks.
 
 Customer D had deposited £38. 00 between 21 April 2021 and 27 May 2021.
 
 Introduction
 
 Paragraph 1 of this provision has been enforced since October 2016, and is requested as follows:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Additional inherent risks
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 After the trigger was changed, the Dudidjence team did not complete the Duddyjence, and the ECDD review was not completed.
 
 The fact that some customers are winning assumed that the risk of ML is reduced without gathering evidence to support this claim. Furthermore, for some customers, franchisie could not prove that there was sufficient evidence, or that the customer could claim that the ML risk brought to the business by reusing profits has decreased. I couldn't point out that it was done.
 
 Excessive dependence on open source information should have taken further measures to confirm customer funding (SOF).
 
 AML staff training was inadequate information on risks and management methods, especially the risks related to political exposed countries and hig h-risk laws.
 
 The European Commission has revealed that some customers have deposit large amounts of money without the appropriate dudillization on customer checks.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 Paragraph 1 of this provision has been enforced since October 2016, and is requested as follows:
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
 
 A licensed gaming carrier has a legal obligation to guarantee that the gaming facility will be provided according to the 2005 gaming method (open on a new tab) (ACT), the conditions of the license, and the following license purposes.
 
 Rules 18 calls for "related people" to identify the ML and TF risks targeted by their activities and take appropriate measures to access them. Some customers have been able to deposit large money without a timely manner of enhanced customered dudidritations (ECDD).
 
 Breach of paragraphs 2 and 3 of licence condition 12.1.1
 
 The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.
 
 Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?
 
 Inadequate money laundering prevention (AML) policy, procedure, management system
 
 AML staff training was inadequate information on risks and management methods, especially the risks related to political exposed countries and hig h-risk laws.
 
 The European Commission has revealed that some customers have deposit large amounts of money without the appropriate dudillization on customer checks.
 
 Customer B deposits £ 73. 535 pounds and lost 14. 068 pounds in four months, Licensee does not determine personal income due to salaries and dividends, but is a company identified as a director. Focused on net assets.
 
 Under the ris k-based approach, it did not satisfy the elements of the customer Dew Dirgence, which had been assumed for a long time.
 
 Failure to comply with paragraph 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 With no n-effective management, we were able to gamble with WHG (International) Limited, despite the fact that 331 customers were sel f-excluded from Mr Green Limited, another operator in the group. Such customers were sel f-excluded from Mr Green Limited before MR Green Limited was acquired by WILLIAM HILL.
 
 The Commission's consideration of certain customers identified during the compliance assessment did not result in them substantiating criminal liability against the licensee.
 
 Compliance with the SRCP is a condition of licence under section 82(1) of the Act. SRCP 3. 4. 1 (amended 31 October 2019) states:
 
 "1 Franchisees must interact with customers in a way that minimises the risk that they will experience gambling-related harm. This includes:
 
 a. identifying customers who may experience gambling-related harm.
 
 b. interacting with customers who are at risk or who may have experienced gambling-related harm.
 
 c. understanding the impact of interactions on customers and the effectiveness of the licensee's actions and approach.
 
 The regulatory arrangements were as follows:
 
 MRG admitted that it did not fully comply with SRCP3. 4. 1:
 
 Consent to publish a statement of facts in the matter.
 
 Customer C opened an account on 3 January 2021 and deposited £23, 000 within 24 hours.
 
 Customer D opened an account on March 16, 2021 and lost £14, 902 in 70 minutes, indicating a lack of effective activation to capture and prevent high-speed gambling without interaction.
 
 Customer E opened a new account in January 2021 and lost £32.
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 A reconstructed penalty package of £ 2. 000. 000 consisting of the following elements was agreed:
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
 
 MRG acknowledged that it was not completely compliant with SRCP 3. 9. 1 as.
 
 Mitigating factors
 
 A survey by the European Commission has revealed that franchisie could not prove that at least four consumers had opened an account in WHG before traveling or opened. The linked account was discovered when the MRG completed the ECDD and was giving a lot of bets in the account.
 
 £ 11 as a survey cost
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Impact on license purposes
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 This is the second S116 assessment received by Licensee. In the first assessment, a million pounds were paid.
 
 The AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Notes
 
 Impact on license purposes
 Publication closed
 LC International Limited Public Statement
 
 Excessive dependence on open source information should have taken further measures to confirm customer funding (SOF).
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 The European Commission has revealed that some customers have deposit large amounts of money without the appropriate dudillization on customer checks.
 
 Customer D had deposited £38. 00 between 21 April 2021 and 27 May 2021.
 
 Introduction
 
 Paragraph 1 of this provision has been enforced since October 2016, and is requested as follows:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Additional inherent risks
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 Payment of £ 3. 750. 000 to replace the fine. This payment is suitable for social responsibility, which includes £ 218. 310 business.
 
 Agree to publish facts regarding this matter
 
 Agree to change the license and add the following conditions to the license:
 
 To appoint a sponsor at the board of directors, which belongs to the president directly or the chairman of the executive chairman, to be responsible for the preparation and progress of the 1 2-month action plan to deal with the activities of the matter.
 
 By February 13, 2024, an independent follo w-up audit about the relevant policies and procedures will be implemented to confirm that the independent audit has been implemented effectively. 。
 
 In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
 
 The serious nature of the discovered violation
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 Customer C opened a new account in 20 minutes on January 3, 2021 without any checks due to repeated violations or default by the operator or other pool companies.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
 
 SRCP 3. 9. 1 is described as follows:
 
 "Franchisies must have a policy and procedure for identifying separate accounts held by the same person and implemented.
 
 Breach of paragraph 1 of licence condition 12.1.1
 
 There were repeated breaches or defaults by the business.
 
 "If Licensee has multiple accounts on customers, Licensee has a procedure to enable the relationship between the customer's account and the other accounts, and this must be implemented.
 
 MRG acknowledged that it was not completely compliant with SRCP 3. 9. 1 as.
 
 A survey by the European Commission has revealed that franchisie could not prove that at least four consumers had opened an account in WHG before traveling or opened. The linked account was discovered when the MRG completed the ECDD and was giving a lot of bets in the account.
 
 The breakdown of payment by this regulatory authorities is as follows:
 
 Breach of paragraphs 2 and 3 of licence condition 12.1.1
 
 The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.
 
 Agree to publish facts regarding this matter
 
 Agree to change the license and add the following conditions to the license:
 
 In order to reflect the guidance in the AML policy, it did not deal with customer risks appropriately.
 
 By February 13, 2024, an independent follo w-up audit about the relevant policies and procedures will be implemented to confirm that the independent audit has been implemented effectively. 。
 
 In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
 
 The serious nature of the discovered violation
 
 Impact on license purposes
 
 Having repeated violations or defaults by the operator or other pool companies
 
 The violation occurred in a situation similar to the case of the European Commission in the past, and as a result, lessons to be learned in a wider industry.
 
 Due to the nature of the violation, it may have affected other customers that the European Commission did not consider.
 
 Breach of paragraph 1 of licence condition 12.1.2 (Anti-Money Laundering measures for operators based in foreign jurisdictions)
 
 In accordance with the rules 17 (9), the information provided by the director authorities (Gambling Committee) was not fully considered.
 
 SRCP (1) and (2) are described as follows:
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 Gaming operators should take into account the failures revealed in this survey in order to ensure industry learning. The operator should consider the following questions:
 
 c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach. ".
 
 Is it possible to effectively record all decisions on compliance and provide evidence of continuous evaluation, evaluation, and improvement to the European Committee at the request?
 
 Under the ris k-based approach, it did not satisfy the elements of the customer Dew Dirgence, which had been assumed for a long time.
 
 Failure to comply with paragraph 1 and 2 of Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 In some cases, some hig h-risk customers were able to keep a lot of money because analysts did not properly apply Licensei's AML policy and procedures.
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 With no n-effective management, we were able to gamble with WHG (International) Limited, despite the fact that 331 customers were sel f-excluded from Mr Green Limited, another operator in the group. Such customers were sel f-excluded from Mr Green Limited before MR Green Limited was acquired by WILLIAM HILL.
 
 3 There are several variations at the start of the violation, but all within this common period. Specifically, if a violation of 12. 1. 1 permissions occurs between September 20, 2020 and October 22, 2021, SRCP3 between December 4, 2020 and October 18, 2021. If you do not comply with the . 4. 1 paragraphs, you may not comply with SRCP 3. 9. 1 between December 4, 2020 and October 18, 2021.
 
 4 AML Guidance and European Commission's ML/TF risk assessment stipulates a certain fact that Licensee should consider and take into account the unique ML/TF risk assessment. In addition, Licensei is required to consider these documents when conducting their own ML/TF risk assessment based on Article 18 (2) (a) of the rules.
 
 Public declaration fee
 
 Published: 2023 February 16,
 
 Failure to comply with paragraphs 1 and 2 of Social Responsibility Code Provision 3.9.1 (Identification of individual customers)
 
 Our publication referring to violations of license conditions that were valid at the time of violation and the requirements of the Code of Business (LCCP). In some cases, the requirements may be updated.
 
 Operators are hoped to review the above issues, identify and implement customer account management improvements, to review their practices.
 
 A licensed gambling operator has a legal obligation to guarantee that the gambling facility will be provided in accordance with the 2005 gambling method (law) (law) (law), license conditions and license purposes.
 
 Prevents gambling from being used to support crime, disorder, associated with crime, disorder, and support crime.
 
 Gamble is performed in a fair, safe and safe way.
 
 Protect children and other vulnerable so that they are not damaged or exploited by gambling.
 
 This survey has begun to review the regulations on Blue Star Planet Limited sections 116 1 (complex remote operating license number: 000-043173-R-322899-020).
 
 Regulatory officials have revealed that there is a defect in the procedures for the purpose of preventing the BLUE STAR PLANET LIMITED money laundering (ML) and protecting the vulnerable. These weaknesses were identified after the compliance review conducted by the European Commission on June 22, 23, 23, and 25 by the European Commission.
 
 From November 2019 to June 2021, Blue Star Planet Limited did not comply with the following license conditions and implementation norms (LCCP):
 
 Requests to comply with the prevention of licensing conditions 12. 1. 1, paragraph 1, paragraphs 2 and 3, money launding and terrorism.
 
 The regulatory arrangements were as follows:
 
 Licence condition 8. 1. 1 subsection 1a, which requires licensees offering remote gaming facilities to display on each screen through which customers can access gaming facilities offered under this licence, that they are licensed and regulated by the Gambling Commission.
 
 Consent to publish a statement of facts in the matter.
 
 In light of the corrective actions taken by Blue Star Planet Limited and based on the licence and regulator's statements, Blue Star Planet Limited will pay a total of £620. 000 in lieu of fines.
 
 Customer D opened an account on March 16, 2021 and lost £14, 902 in 70 minutes, indicating a lack of effective activation to capture and prevent high-speed gambling without interaction.
 
 Customer E opened a new account in January 2021 and lost £32.
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 A reconstructed penalty package of £ 2. 000. 000 consisting of the following elements was agreed:
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
 
 License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensee has been confirmed that it is properly carried out, procedures, and management to prevent money laundering and terrorism funding. I have to do it.
 
 Mitigating factors
 
 Pay £ 690. 947 instead of fine, which includes £ 50. 947 assets. This fund is used for socially responsible activities.
 
 £ 11 as a survey cost
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 In considering the appropriate solution to this survey, the committee takes into account the following additional factors and the easing factors:
 
 Impact on license purposes
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 In so far as it relates to the Money Laundering Regulations (MLR), the requirements of any UK statutory instrument which it amends or replaces must be complied with, whether or not the MLR applies to its business.
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 This is the second S116 assessment received by Licensee. In the first assessment, a million pounds were paid.
 
 The AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Notes
 
 Blue Star Planet Limited accepted it at the time of the assessment:
 
 The financial management, which was established to automatically limit the amount of money deposited by the customer, was excessive, and as a result, the policy and procedure were not implemented effectively or appropriately in accordance with the license conditions 12. 1. 1 (2). 。
 
 After reaching the AML risk warning, the financial limit was too high to manage how many customers could deposit and play before the satisfactory risk profile was achieved.
 Publication closed
 Jumpman Gaming Limited Public Statement
 
 License conditions 12. 1. 1 (3) said, "Licensei is an effectively carried out, and it has been reviewed, and the Gamble Committee is appropriately reviewed, and continues to be effective. We must make sure that the relevant learning or guidance is presented at any time. "
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Before automatic restrictions were applied to the customer account, some customers could bet at a high rate.
 
 There were cases where some customers were required to demand evidence at an earlier stage.
 
 Due to the ML/TF risk, some of the interaction customers should have restricted more play.
 
 The limit of financial deposits was too high, so it had no effect on suppressing hig h-speed expenditures and allowed some customers to exceed the limit of AML risk. License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensee has been confirmed that it is properly carried out, procedures, and management to prevent money laundering and terrorism funding. I have to do it.
 
 Introduction
 
 Blue Star Planet Limited accepted it at the time of the assessment:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 License conditions 12. 1. 1 (3) said, "Licensei is an effectively carried out, and it has been reviewed, and the Gamble Committee is appropriately reviewed, and continues to be effective. We must make sure that the relevant learning or guidance is presented at any time. "
 
 Blue Star Planet Limited acknowledged the following at the time of assessment:
 
 Before automatic restrictions were applied to the customer account, some customers could bet at a high rate.
 
 There were cases where some customers were required to demand evidence at an earlier stage.
 
 Due to the ML/TF risk, some of the interaction customers should have restricted more play.
 
 The limit of financial deposits was too high, so it had no effect on suppressing hig h-speed expenditures and allowed some customers to exceed the limit of AML risk.
 
 Clause 1 of this condition has been in force since October 2016 and requires that: "A licensee must comply with the money laundering regulations as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of UK law as amended or replaced in so far as those regulations relate to casinos (the MLR), whether or not the MLR applies to its business in relation to that business."
 
 Blue Star Planet Limited accepted this:
 
 Break of licence condition 12. 1. 2 under the conditions detailed in sections 1 to 3.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 "1 A licensee offering a remote gaming facility shall display on each screen from which customers can access the gaming facility offered under this license:
 
 There were weaknesses and deficiencies in relation to the adequacy and maintenance of policies and procedures, and their implementation.
 
 b. An account number.
 
 Breach of paragraph 1 of Licence Condition 12.1.1
 
 c. A link (to be provided by the Commission) to the current license status recorded on the Commission's website.
 
 2 The statements, account numbers and links shall contain the form, means and information specified from time to time by the Commission in the technical standards applicable to the type of gaming facility offered under this license or notified to the licensee for the purposes of this condition.
 
 3 The franchisee may also display, on screens accessible from Great Britain, information about any licences or other rights held by the Regulator or by law of any jurisdiction outside Great Britain, provided that it is clear on those screens which jurisdictions offer gaming to citizens of Great Britain under a license from the Gambling Commission."
 
 Blue Star Planet Limited acknowledged that during the assessment:
 
 Website links were not working but were promptly corrected after identification.
 
 Compliance with the SRCP is a condition of licence under section 82(1) of the Act. SRCP 3. 4. 1 (amended 31 October 2019) states:
 
 Breach of paragraph 2 of license condition 12.1.1
 
 "1 Licensees must deal with customers in a manner that minimises the risk that they will experience gambling-related harm. This includes:
 
 a. Identifying customers who are likely to experience gambling-related harm.
 
 a. identifying customers who may or may suffer or suffer gambling.
 
 c. understand the impact of interactions on customers and the effectiveness of the licensee's actions and approach. ”
 
 2 Franchisees should take into account the European Commission's guidance on customer interactions. ”
 
 Blue Star Planet Limited accepted this at the time of the assessment:
 
 The company did not use dedicated compliance staff to monitor safer gambling announcements overnight. Customers who hit safer gambling triggers are manually reviewed the following day.
 
 Breach of paragraph 3 of licence condition 12.1.1
 
 The need for manual review and failure to monitor safer gambling alerts overnight resulted in some customers hitting multiple safer gambling activators without real-time risk assessment and interaction occurring
 
 Failure to implement high-speed risk alerts allowed some customers to gamble at high speeds without real-time interaction occurring.
 
 a. identifying customers who may or may suffer or suffer gambling.
 
 It could have been clearer how the effectiveness of interactions with clients was assessed.
 
 It did not identify and interact with two customers seen by officers during the assessment, both of whom showed signs of possible gambling problems, promptly enough.
 
 Conditions of this settlement with the regulator
 
 Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering Measures for operators based in foreign jurisdictions)
 
 Agree to publish facts about this matter
 
 Agree to the publication of the facts relevant to this matter.
 
 Pay £3, 571, 25 towards the Commission's investigation costs.
 
 The serious nature of the discovered violation
 
 The serious nature of the breaches found
 
 Impact on licensing purposes
 
 A lesson was published in a widespread industry, as the violation occurs in a situation similar to the case that the European Commission was handled in the past in the past.
 
 Requires to encourage other businesses' compliance
 
 Failure to comply with Social Responsibility Code Provision 3.4.1 paragraphs 1 and 2
 
 Due to the nature of the violation, it may have been affected by other customers who have not investigated by the committee.
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 Is it at least once a year to review the ML/TF risk assessment, measure the effectiveness of SG and SG policies and procedures, and introduce a formal process for appropriately document?
 
 Is all compliance decisions effectively? Can the European Commission be shown to the European Commission in response to the request for continuous evaluation, evaluation, and improvement?
 
 Gaming operators should take into account the weaknesses identified in this survey to ensure industry learning. Businesses should consider the following questions:
 
 Did the employee take appropriate AML and social responsibilities?
 
 Effective record of all decisions on compliance, can the committee provide the committee in response to the request for continuous evaluation, evaluation, and improvement;
 
 Do you reflect the lessons learned from public statements in your policy and procedure?
 
 Is the customer risk profile formulated or linked to AML/CFT risk assessment?
 
 Do you have a formal process to analyze the effectiveness of dialogue with customers, make the reviews properly documented, and make sure that the approach is consistent?
 
 a. identifying customers who may or may suffer or suffer gambling.
 
 Do you make an overtime arrangement?
 
 Do your staff take appropriate training to compete with the use of the main street and gravity?
 
 1. The committee started a review of Article 116 on September 7, 2021.
 
 Failings in respect of Social Responsibility Code Provision 3.9.1
 
 2. Licensei accepts violations, but is an isolated event that the link on the website has been cut out should not justify the license clause 8. 1. 1 violation.
 
 Public statement ends
 
 Release date: January 17, 2023
 
 Our public statement referring to violations of license conditions and LCCP (LCCP) requirements that were valid in the event of violation. In some cases, the requirements may be updated.
 
 Operators are expected to review their practices to consider the following issues and to identify and implement improvements in the management of customer accounts.
 
 This survey has begun to review the regulations on Blue Star Planet Limited sections 116 1 (complex remote operating license number: 000-043173-R-322899-020).
 
 Prevent gambling from causing, being associated with or being used to support crime or disorder.
 
 The regulatory arrangements were as follows:
 
 Protect children and other vulnerable people from harm and exploitation through gambling.
 
 Consent to publish a statement of facts in the matter.
 
 The regulatory review found deficiencies in Vivaro's procedures aimed at preventing money laundering (ML) and safer gambling.
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 Licence Condition 12. 1. 1 clauses 2 and 3, which require the prevention of money laundering and terrorism.
 
 Licence Condition 12. 1. 1, which requires operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Payer Information) Act 2017.
 
 Social Responsibility Code Clause 3. 4. 1 clauses 1 and 2, which require licensees to interact with customers in a manner that minimises the risk that customers experience gambling-related harm and to take into account the European Commission's guidance on customer interactions.
 
 According to the Licensing and Regulatory Authority statement, Vivaro will make a payment in lieu of a penalty package of £337. 631. The allocation of the regulator's settlement funds is set out in the section below.
 
 Mitigating factors:
 
 Our investigation and subsequent regulatory review found:
 
 Vivaro's implementation of anti-money laundering (AML) policies, procedures and controls.
 
 Vivaro's deficiencies in responsible policies, procedures, controls and implementation, including weaknesses in implementation.
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Additional inherent risks
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 Vivaro acknowledged that it violated these license conditions for the following:
 
 In so far as it relates to the Money Laundering Regulations (MLR), the requirements of any UK statutory instrument which it amends or replaces must be complied with, whether or not the MLR applies to its business.
 
 Its policies, procedures and controls lacked guidance on appropriate actions to be taken following the outcome of a customer profile and how the findings should be used to determine an appropriate outcome.
 
 Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
 
 Customers who have been verified by compliance evaluation have received an AML check that is not effective in judging the use of SOF for gaming, and the Bank Transactions in the Bank Transactions is not scrutinized to judge other income, and from other entities. I rely on the profits of. According to the European Commission's opinion, some checks were conducted, but it was not enough to meet the "very high AML" standard set by Licensei. According to the European Commission's views, Vivaro was excessively relying on the customer's internet gambling position. Another customer has submitted a bank statement indicating more than £ 270. 000. It was 00 pounds. Vivaro did not fully consider the risks related to the rolled prize money. In particular, no additional checks were performed to confirm the source of the funds used for gambling. Customers could fraudulently divert funds and r e-deposit new criminal expenditures.
 
 Publication closed
 Progress Play Limited Public Statement
 
 License conditions 12. 1. 1 (3) said, "Licensei is an effectively carried out, and it has been reviewed, and the Gamble Committee is appropriately reviewed, and continues to be effective. We must make sure that the relevant learning or guidance is presented at any time. "
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 "Licensei is amended or replaced, regardless of whether the MLR is applied to that business, as far as the Money Laundering Rules (Revised) Rules 2007 (MLR) are related to the 2007 (MLR). Requirements for British legal documents.
 
 Licensee accepts that the abov e-mentioned AML default has violated this license because it configures a violation of the money laundering regulation 2017:
 
 Due to the ML/TF risk, some of the interaction customers should have restricted more play.
 
 Rule 24 (a) is appropriate measures for related employees to recognize the laws related to money loaneding and terrorism funding, as well as data protection requirements related to the application of these rules. We are obliged to take. In addition, provide regular training for transactions and other activities or situations that may be related to money laundering or terrorism funding.
 
 Introduction
 
 Rules 28 (11) (a) continues, including auditing funds as needed to confirm that business relationships are in line with customer knowledge, customer profile and customer risk. We are demanding a monitoring.
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Is it possible to effectively record all decisions related to compliance and provide evidence of continuous evaluation, evaluation, and improvement according to the request of the committee?
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 b. To contact customers who are risky or may have experienced harm related to gambling.
 
 c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach.
 
 2. Licensee must consider the European Commission's guidance on dialogue with customers.
 
 Rules 33 imposes duty to implement ECDD measures and continuous monitoring in a situation identified as high ML or TF risk.
 
 Until the protection of new customers and the customer reached the "higher" AML activation, it was insufficient to take the high speed and period of play spending. In some cases, the customer deposited 4000 pounds in four days and lost.
 
 The KYC representatives were short of human resources to manage requirements in terms of identifying risky customers and involved in dialogue with customers. System stops were only related to financial triggers. He did not properly respond to other risk factors.
 
 There were no sufficient resources or effective automatic blocks to manage claims related to dialogue with customers. The committee staff believe that if Licensee had sufficient resources, the exchange with customers (such as telephone) could be adjusted quickly and more appropriately.
 
 Breach of paragraph 2 of licence condition 12.1.1
 
 When the customer was notifying a safer gambling, he rely on Vivaro in email exchanges. Although e-mail was not automated, it was not enough to respond to the specific situation of the customer.
 
 Vibaro's log recording level was low and did not evaluate the effects of customer usage and responsible gambling tools and the effects of exchanges with customers. Customers with a monthly wage of 5. 000 were able to deposit £ 20. 000 between September 9, 2020 and February 5, 2021, which is equivalent to about 80%of customer salaries, and Licensei is at this level. We did not consider the expenditure.
 
 337. 631 Poun d-based settlement packages are agreed and consists of the following elements:
 
 An alternative payment of £ 302. 500 is assigned to the National Responsible Gambling Strategy project, which is considered appropriate to address harmful gambling risks.
 
 Breach of paragraph 3 of licence condition 12.1.1
 
 Abandon right £ 35.
 
 Based on Article 117 (1) (b) of the Act, voluntarily insert additional conditions into the license of Vivaro:
 
 337. 631 Poun d-based settlement packages are agreed and consists of the following elements:
 
 Submit the audit report to the European Commission within 5 business days after receiving it.
 
 Our survey revealed that the system on customer management methods aimed at AML and social responsibility had a serious weakness, and Vibaro accepted it.
 
 In determining the appropriate results, we take into account the following factors:
 
 There were lon g-term serious license status violations. This prevents gambling from being used to support the purpose of licensing, especially for crime support, and has affected people who are weak from gambling damage and exploitation.
 
 Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)
 
 VIVARO actively and timely to deal with all specified issues.
 
 Vibaro was open, transparent and completely cooperative from the beginning of the survey.
 
 Vibaro's business content (including funding power).
 
 Gaming operators should take into account the failures specified in this survey to ensure the study in the industry. The operator should also consider the following questions:
 
 Do you have a formal procedure to measure gambling policies and procedures and to properly record safer and reliable results?
 
 Is it possible to effectively record all decisions on compliance and show evidence of continuous evaluation, evaluation, and improvement in response to the request of the committee?
 
 Failure to comply with Paragraph 1 and 2 of social responsibility code provision (SRCP) 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 Is the customer risk profile updated or linked to the risk evaluation of money loaning and terrorism?
 
 Is the lessons learned from the public statement reflected in your policy and procedure?
 
 Is the customer risk profile up to the latest or the risk evaluation of money loaneding and terrorism procurement?
 
 (SRCP) 3. 4. 1 - requires licensees to identify and engage with customers who may experience gambling-related harm in a manner that minimises the risk of customers experiencing gambling-related harm, and requires licensees to take into account the Commission's guidance on how to engage with customers.
 
 Discontinuation
 
 Published: August 25, 2022
 
 Our publication referring to violations of license conditions and implementation (LCCP) requirements that were valid at the time of violation. In some cases, the requirements have been updated.
 
 License Conditions 12. 1. 1 Displa y-Submit the Audit Report to the European Commission within 5 business days after receiving the < ban> prevention prevention of money launding and terrorism.
 
 Our survey revealed that the system on customer management methods aimed at AML and social responsibility had a serious weakness, and Vibaro accepted it.
 
 In determining the appropriate results, we take into account the following factors:
 
 There were lon g-term serious license status violations. This prevents gambling from being used to support the purpose of licensing, especially for crime support, and has affected people who are weak from gambling damage and exploitation.
 
 Failure to consider OCP 3.4.2 (customer interaction)
 
 VIVARO actively and timely to deal with all specified issues.
 
 Vibaro was open, transparent and completely cooperative from the beginning of the survey.
 
 The regulatory arrangements were as follows:
 
 Gaming operators should take into account the failures specified in this survey to ensure the study in the industry. The operator should also consider the following questions:
 
 Do you have a formal procedure to measure gambling policies and procedures and to properly record safer and reliable results?
 
 Is it possible to effectively record all decisions on compliance and show evidence of continuous evaluation, evaluation, and improvement in response to the request of the committee?
 
 Instructions, procedures, and management defaults by Admission Management Licensee (AML)
 
 Aggravating factors
 
 Is the customer risk profile updated or linked to the risk evaluation of money loaning and terrorism?
 
 Do you have a formal process to analyze the effectiveness of the interaction with customers, the reviews are properly documented, and that it was consistent approach?
 
 Are you recording the types of behavior that triggered the interaction with your customers, maintaining the appropriate recording of the interaction, especially the detailed levels provided, with the decision not to interact?
 
 Did the employee receive appropriate AML and SR training?
 
 Discontinuation
 
 Mitigating factors
 
 Published: August 25, 2022
 
 Our publication referring to violations of license conditions and implementation (LCCP) requirements that were valid at the time of violation. In some cases, the requirements have been updated.
 
 License Conditions 12. 1. 1 Overwhelmin g-Submit the European Commission to the European Committee within 5 business days after receiving the ant i-money laundering and terrorist funding.
 
 Our survey revealed that the system on customer management methods aimed at AML and social responsibility had a serious weakness, and Vibaro accepted it.
 
 In determining the appropriate results, we take into account the following factors:
 
 Publication closed
 BV Gaming Limited Public Statement
 
 VIVARO actively and timely to deal with all specified issues.
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Vibaro's business content (including funding power).
 
 Before automatic restrictions were applied to the customer account, some customers could bet at a high rate.
 
 Do you have a formal procedure to measure gambling policies and procedures and to properly record safer and reliable results?
 
 Is it possible to effectively record all decisions on compliance and show evidence of continuous evaluation, evaluation, and improvement in response to the request of the committee?
 
 Do you reflect the lessons learned from the published items in your policy and procedure?
 
 Is the customer risk profile updated or linked to the risk evaluation of money loaning and terrorism?
 
 Introduction
 
 Blue Star Planet Limited accepted it at the time of the assessment:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 Published: August 25, 2022
 
 Our publication referring to violations of license conditions and implementation (LCCP) requirements that were valid at the time of violation. In some cases, the requirements have been updated.
 
 License Conditions 12. 1. 1 Overwhelmin g-Prevention of money laundering and terrorism funding
 
 When the normal normary clause (OCP) 2. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1-
 
 Social liability code clause 3. 4. 1 and 2-- When not in accordance with customers.
 
 Operators are expected to review the following issues, identify and implement improvements from the perspective of customer account management, to review their own practices.
 
 A licensed gaming providers have a legal obligation to guarantee that the gaming facilities will be provided according to the following licensing purposes according to the 2005 gaming method (open on a new tab) and license conditions.
 
 Prevents gambling from being caused by crime, disorder, being associated with crime, or being used to support crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Protects children and socially vulnerable from gambling damage and exploitation.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 The regulatory officials revealed that there was a defect in the SPReadex procedure to prevent money laundering (ML) and protect the vulnerable.
 
 From January 2020 to May 2021, Spread Exit violated the license conditions and business norms (LCCP):
 
 There were weaknesses and deficiencies in relation to the adequacy and maintenance of policies and procedures, and their implementation.
 
 In paragraphs 1 and 2 of Social Responsible Standards (SRCP) 3. 4. 1, in order to minimize the risk of gambling harm to Licensei, in contact with customers and with customers. We are calling for the guidance of the European Commission on how to treat.
 
 1. Breach of paragraph 1 of licence condition 7.1.1
 
 In consideration of SPREADEX's corrective measures, SPREADEX will pay a total of £ 1. 363. 786 in response to the committee's statement on license and regulation.
 
 The following was found by our survey and subsequent regulatory authorities:
 
 deficiencies in Spreadex's implementation of anti-money laundering (AML) policies, procedures and controls.
 
 deficiencies in policies, procedures, controls and practices for responsible gambling, including weak implementation.
 
 License condition 12: "Licensees must carry out a risk assessment of the risk of their business being used for money laundering and terrorist financing. This risk assessment must be appropriate and must be reviewed as necessary in the light of changing circumstances, such as the introduction of new products or new technology, new ways of paying by customers, changes in customer demographics or other significant changes." Any matter must be reviewed at least annually.
 
 2. Breach of paragraph 1 of licence condition 12.1.1
 
 There were repeated breaches or defaults by the business.
 
 Failed to annually carry out the required review and update and did not take into account and properly consider information on ML and TF risks available in Commission publications.
 
 Failed to identify and assess all relevant customer, product and geographic risk factors.
 
 Licence condition 12. 1. 1(2) states that "Once the risk assessment and review have been completed and taken into account, the licensee shall ensure that it has adequate policies, procedures and controls to prevent money laundering and terrorist financing."
 
 The Commission found, and Spreadex acknowledged, that Spreadex did not fully comply with licence condition 12. 1. 1(2). That is, there were weaknesses and deficiencies with respect to the adequacy and maintenance of policies, procedures and controls to address:
 
 Some customers were able to deposit large amounts of money without triggering sufficient interactions such as source of funds (SOF) checks.
 
 3. Breach of paragraph 2 of licence condition 12.1.1
 
 By way of example, the Commission's concerns were:
 
 Enhanced customer due diligence detection (ECDD) triggers were ineffective, allowing customers to deposit large amounts of money before the first AML review.
 
 The level of information received and verified by the licensee did not increase in line with the ML risk level of the customers. In one case, a customer received a financial deposit note for £25, 000, but increased the note to £100, 000, requesting further verification based on a profit and loss statement and an open-code cheque.
 
 Excessive reliance on electronic verification checks without obtaining additional independent data from reliable sources.
 
 License Status 12: "Licensees must ensure that such policies, procedures and controls are effectively implemented, constantly reviewed and appropriately revised to remain effective and take into account any applicable learning or guidelines issued by the Gambling Commission from time to time.".
 
 4. Breach of paragraph 3 of licence condition 12.1.1
 
 Do you record the type of behaviour that triggered your interaction with a customer and maintain an appropriate record of the interaction along with the decision not to interact, particularly at the level of detail provided?
 
 failed to critically review its SOF documentation and placed excessive reliance on electronic controls.
 
 Failed to allow for sufficient staff to respond to economic factors in a timely manner and mitigate risks appropriately.
 
 By way of example, the Commission's concerns were:
 
 A customer who was unable to continue depositing after providing issued bank statements in response to a request for SOF receipts
 
 A customer who was able to deposit £365. 000 and lost £284. 000 over a three-month period
 
 A customer who was able to deposit £3. 000 and lost £2. 000 over a three-month period months of losses without being sufficiently substantiated.
 
 The Commission's review of certain customers identified during the compliance assessment found no evidence of criminal charges against the licensee.
 
 The findings assessed as 1 through 3 arose, in part, because SpreadX did not fully consider the Commission's guidance on money laundering. OCP 2. 1. 1 states: "To help prevent activities related to money laundering and terrorist financing, licensees shall act in accordance with the European Commission's Anti-Money Laundering: Preventing Money Laundering and Combating Terrorist Financing Guidance for remote and non-remote casino transponders.
 
 5. Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering Measures for operators based in foreign jurisdictions)
 
 In accordance with the rules 17 (9), the information provided by the director authorities (Gambling Committee) was not fully considered.
 
 SRCP (1) and (2) are described as follows:
 
 b. Dealing with customers who are at risk or who may be experiencing gambling-related harm.
 
 c. Understand the impact of interactions on customers and the effectiveness of the licensee's actions and approach.
 
 2 Franchisees should take into account the European Commission's guidance on customer interactions.
 
 6. Failure to comply with Paragraph 1 and 2 of social responsibility code provision (SRCP) 3.4.1 (Customer Interaction)
 
 Are all important incidents a proper procedure so that the European Commission is reported in a timely manner?
 
 The company's financial alerts were ineffective and allowed customers to lose a lot of money in a short period of time.
 
 He was excessively dependent on financial alerts to identify customers with potential loss risks.
 
 He did not properly record or evaluate the exchange with customers.
 
 For example, concerns from the European Commission include customers who deposited £ 1. 7 million a month and lost £ 500, 000. Although the interaction with the customer was performed, it was not properly evaluated and did not consider the effectiveness of account restrictions.
 
 Licence condition 15. 2. 1(4) - requires franchisees to notify the Commission of certain significant events, such as the appointment or loss of key personnel.
 
 b. engaging with customers who have suffered or are likely to suffer gambling-related harm.
 
 c. understanding the impact of interactions on customers and the effectiveness of the licensee's actions and approach."
 
 Expenses for the European Commission to investigate this matter 7. 831. 00 pounds
 
 In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
 
 Seriousness of the discovered violation
 
 Impact on license purposes
 
 A violation occurred in a situation similar to the case that the European Commission was handled in the past in the past, and as a result, the lessons to be learned in a wider industry were published.
 
 7. Failure to comply with paragraph 2 of SRCP 5.19 (Other marketing requirements)
 
 Requires to encourage other businesses' compliance
 
 Due to the nature of the violation, it may have been affected by other customers who have not investigated by the European Commission.
 
 SPREADEX insighted the seriousness of the violation and stopped the casino for five months to reduce the risk.
 
 The regulatory arrangements were as follows:
 
 SPReadex and their senior managers cooperated with the European Commission in a timely and transparent way.
 
 SPREADEX proposed a reconciliation to the regulatory authorities early.
 
 Gambling operators should learn by the industry, taking into account the weaknesses revealed in this survey. The operator should consider the following questions:
 
 Do you introduce a formal process to measure the AML and more secure gambling policies and the effectiveness of the procedure, and record the results properly? Committee has SPREADEX's policy and procedure. SRCP 3. The company is SRCP 3:
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors:
 
 He was excessively dependent on financial alerts to identify customers with potential loss risks.
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Agree to publish facts regarding this matter
 
 Expenses for the European Commission to investigate this matter 7. 831. 00 pounds
 
 Mitigating factors:
 
 In considering the appropriate solution to this survey, the European Commission took into account the following additional factors and the easing factors:
 
 Seriousness of the discovered violation
 
 Impact on license purposes
 
 A violation occurred in a situation similar to the case that the European Commission was handled in the past in the past, and as a result, the lessons to be learned in a wider industry were published.
 
 Good practice:
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Additional inherent risks
 
 Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
 
 SPREADEX has submitted an action plan shortly after the compliance evaluation, taking effective measures to expand and improve compliance.
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
 
 When a customer is a national of a third country and has applied for residence or citizenship in that country in exchange for a transfer of capital, purchase of real estate, purchase of government bonds or investment in a legal entity in that country (AML Guidance para. 6. 33).
 
 The AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Publication closed
 Annexio (Jersey) Limited trading as Affiliate Empire Public Statement
 
 He was excessively dependent on financial alerts to identify customers with potential loss risks.
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 For example, concerns from the European Commission include customers who deposited £ 1. 7 million a month and lost £ 500, 000. Although the interaction with the customer was performed, it was not properly evaluated and did not consider the effectiveness of account restrictions.
 
 Key failings
 
 Before automatic restrictions were applied to the customer account, some customers could bet at a high rate.
 
 Pay £ 1. 363. 786 instead of fines, and use it for socially responsible activities.
 
 Agree to publish facts regarding this matter
 
 The limit of financial deposits was too high, so it had no effect on suppressing hig h-speed expenditures and allowed some customers to exceed the limit of AML risk. License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensee has been confirmed that it is properly carried out, procedures, and management to prevent money laundering and terrorism funding. I have to do it.
 
 Introduction
 
 Blue Star Planet Limited accepted it at the time of the assessment:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 Requires to encourage other businesses' compliance
 
 Due to the nature of the violation, it may have been affected by other customers who have not investigated by the European Commission.
 
 SPREADEX insighted the seriousness of the violation and stopped the casino for five months to reduce the risk.
 
 SPREADEX has submitted an action plan shortly after the compliance evaluation, taking effective measures to expand and improve compliance skills.
 
 SPReadex and their senior managers cooperated with the European Commission in a timely and transparent way.
 
 SPREADEX proposed a reconciliation to the regulatory authorities early.
 
 Gambling operators should learn by the industry, taking into account the weaknesses revealed in this survey. The operator should consider the following questions:
 
 Do you introduce a formal process to measure the AML and more secure gambling policies and the effectiveness of the procedure, and record the results appropriately?
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
 
 A licensed gaming carrier has a legal obligation to guarantee that the gaming facility will be provided according to the 2005 gaming method (open on a new tab) (ACT), the conditions of the license, and the following license purposes.
 
 Breach of Paragraph 1 of Licence Condition 12.1.1 (Anti-Money Laundering) between October 2019 and November 2021
 
 Do you have a formal process to analyze the effectiveness of dialogue with customers and confirm that the type of dialogue is effective?
 
 Do you record the kind of behavior that triggered the dialogue with customers, and keep the appropriate record of the dialogue, especially at the detailed levels provided?
 
 1 OCP does not have a status of license conditions, but has excellent cases. The deviation from the OCP regulations by the business may be considered by the European Commission as part of the license review.
 
 2. Compliance with SRCP shall be a license condition according to Article 82, Paragraph 1 of the Act.
 
 Public statement ends
 
 Published: August 17, 2022
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Breach of Paragraph 2 of Licence Condition 12.1.1 between October 2019 and December 2020
 
 License Status 12: "Upon completion of a risk assessment and taking into account any review of the assessment, the licensee must ensure that it has adequate policies, procedures and controls to prevent money laundering and terrorist financing.
 
 Operators are hoped that they will address the following issues and review their own practices to identify and implement the improvement of customer account management.
 
 A licensed gaming operator has a legal obligation to provide gaming facilities in accordance with the 2005 gambling method (open on a new tab) (ACT), the conditions of the license, and the following license purposes.
 
 Prevents gambling from being caused by crime, disorder, being associated with crime, or being used to support crime.
 
 Gamble is performed in a fair and open way.
 
 Protects children and other vulnerable from gambling damage and exploitation.
 
 Following the compliance evaluation, this survey led to the launch of the composite non-regulated business license number: 001611-102408-022 Ladbrokes Betting & Amp; Gaming Limited (LBG) section 116 regulation review 1. The regulatory review revealed that the LBG process designed to prevent money laundering (ML) and more secure gambling was inadequate.
 
 Breach of paragraph 3 of Licence Condition 12.1.1 between October 2019 and December 2020
 
 From December 2019 to October 2020, LBG did not comply with specific license conditions and implementation norms (LCCP):
 
 Paragraph 2 and Paragraph 3 approval 12. 1. 1, Section 3-Money Laundering and Terrorism Procurement
 
 Social liability norms (SRCP), paragraphs 1 and 2-2 -Dialogue with customers.
 
 Based on the statement of the LBG corrections and the license and regulations on the authority, LBG voluntarily abandons £ 212. 849. 86, pays £ 2. 787. 150. 14 instead of a fine, and pays a total of £ 3. 000. 000.
 
 What was revealed in our surveys and the underlying regulatory authorities.
 
 LBG Money Laundering Prevention (AML) policy, procedure, and management system inadequate.
 
 Responsible policies, procedures, management and implementation.
 
 Insufficient in the report of the report
 
 We discovered that LBG violated the following license conditions and social liability norms from December 2019 to October 2020:
 
 License status 12: "If the risk assessment is completed and assessment is considered, Licensee must secure a proper policy, procedure and management system to prevent money laundering and terrorism."
 
 Licensing conditions 12. 1. 1 (3) said, "Licensei has been r e-implemented, and it has been reviewed, and it is always reviewed, and it will continue to be effective, and the Gambling Committee has been announced at any time. We must guarantee that we are taking the applicable learning and guidance. "
 
 Policy and procedure's appropriateness and maintenance, and weaknesses and incomplete implementation
 
 Failure to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction) between October 2019 and December 2020
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 Customer Gaster G was a hig h-priced cash customer who regularly puts more than 500 pounds of cash into the store terminal. The customer gave his first bet on January 10, 2020, bet about £ 168. 000 in eight months, and lost a total of about £ 28. 000. The customer was not subject to AML checks by License, but the main reasons were that it was not reported for reviews by store staff and did not apply to AML reference triggers in Licensee. Licensee acknowledged that the customer had not begun to check the customer until the governance process was reviewed in September 2020.
 
 SRCP 5. 1. 6 - Licence requirements comply with the Advertising Code.
 
 When a committee confirmed a specific customer specified in the compliance evaluation, there was no evidence that Licensei was criminal charges.
 
 SRCP compliance is a condition for obtaining a license according to Article 82, Paragraph 1 of the Act. SRCP 3. 4. 1 (revised on October 31, 2019) is described as follows:
 
 "1 Licensei must be in contact with customers in a way to minimize the risk of gambling har m-related harm. This includes the following:
 
 a. identifying customers who may experience harm related to gambling.
 
 b. To contact customers who may experience harm related to gambling.
 
 c. Understand the effects of interactions on customers, and the effectiveness of licensing and approach.
 
 Breach of Licence condition 15.2.1 (Reporting key events) in August 2020
 
 2. Franchisie should consider the European Commission's guidance on dialogue with customers.
 
 LBG acknowledged that it was not completely compliant with SRCP3. 4. 1:
 
 The regulatory arrangements were as follows:
 
 In July 2020, the customer introduced £ 29. 372 and lost £ 11. 345 (on e-third of 12 months of loss). This has been the highest monthly betting for customers since becoming a tracked shop customer, which was significantly exceeded the monthly loss recorded in the past. The customer was not escalated by both office team or desk team for a safer gambling review.
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present higher ML and TF risks, having taken all other relevant factors into account (para. 2. of the AML Guidance).
 
 The customer K, known as a delivery driver, was £ 17 between October 2019 and October 2020.
 
 Aggravating factors
 
 Licensei acknowledged that the failure of the customer L, which lost £ 218. 765 and lost £ 44. 000, had a major failure. I lost 597 pounds.
 
 The content of this regulation settlement is as follows:
 
 Do you have a formal process to analyze the effectiveness of the interaction with customers, the reviews are properly documented, and that it was consistent approach?
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Licence condition 12: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee must ensure that it has in place appropriate policies, procedures and controls to prevent money laundering and terrorist financing.
 
 Mitigating factors
 
 Appoint a board-level sponsor, reporting directly to the Chairman, to be responsible for implementing the action plan.
 
 Conduct an independent audit of the gaming insurer's relevant policies and procedures within 12 months to ensure that the gaming insurer's policies, procedures and controls are effectively implemented, and subsequently implement the independent audit's safer recommendations.
 
 In considering an appropriate resolution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 The serious nature of the violations identified
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Additional inherent risks
 
 Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 In so far as it relates to the Money Laundering Regulations (MLR), the requirements of any UK statutory instrument which it amends or replaces must be complied with, whether or not the MLR applies to its business.
 
 Licensei
 
 Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
 
 The AML training provided to staff provided insufficient information about the risks and how to manage them.
 
 Footnotes
 
 Gaming operators should take into account the failures uncovered in this investigation to ensure industry learning. Operators should consider the following questions:
 Publication closed
 Rank Digital Gaming (Alderney) Limited Public statement
 
 He was excessively dependent on financial alerts to identify customers with potential loss risks.
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Do you have a formal process for analysing the effectiveness of customer interactions to ensure reviews are properly documented and the approach is consistent?
 
 Key failings
 
 LBG agreed to add the following condition to its license:
 
 Appoint a board-level sponsor, reporting directly to the chairman, to be accountable for the implementation of the action plan.
 
 Conduct an independent audit of the gaming insurer's relevant policies and procedures within 12 months to ensure that the gaming insurer's policies, procedures and controls are effectively implemented, and subsequently implement any safer recommendations of the independent audit.
 
 In considering an appropriate resolution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Introduction
 
 Blue Star Planet Limited accepted it at the time of the assessment:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 The need to encourage compliance by other operators
 
 Due to the nature of the violations, other customers not investigated by the Commission may have been affected.
 
 LBG's senior management should be aware of the governance issues that led to the violations, given the seriousness of the violations.
 
 The extent of steps taken to remedy the violations - The franchisee implemented an early action plan to remedy the violations.
 
 The licensee procedurally complied with the Commission's schedule for providing materials and requested extensions when such materials could not be provided within the expected time frame.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 Failure to comply with Paragraph 1 and 2 of social responsibility code provision (SRCP) 3.4.1 (Customer Interaction) between October 2019 and February 2021
 
 Do you have a formal process in place to measure the effectiveness of your gambling policies and procedures and how they make gambling safer and more secure?
 
 Are all compliance decisions effectively recorded and can you show evidence of ongoing assessment, evaluation and improvement as required by the Commission?
 
 Are lessons learned from public statements reflected in your policies and procedures?
 
 Do you have a formal process for analysing the effectiveness of customer interactions to ensure reviews are appropriately documented and the approach is consistent?
 
 LBG agreed to add the following conditions to its licence:
 
 SRCP 5. 1. 6 - Licence requirements comply with the Advertising Code.
 
 Conduct an independent audit of the gaming insurer's relevant policies and procedures within 12 months to ensure that its policies, procedures and controls are effectively implemented and subsequently implement the independent audit's safer recommendations.
 
 Taking into account the corrective actions taken by Lindar Media Limited before and immediately after the compliance assessment and in accordance with the Commission's Statement of Authority for Licensing and Regulation, Lindar Media Limited will pay a total of £690. 947.
 
 The serious nature of the violations identified
 
 The impact on licensing purposes
 
 There were repeated violations or defaults by the operator or other pool companies
 
 Failure to comply with Social Responsibility Code Provision 3.9.1 Paragraph 2 (b) - Identification of individual customers - remote, between June 2020 and February 2021
 
 The violations occurred in circumstances similar to cases the Commission has encountered in the past, resulting in the publication of lessons to be learned for the wider industry.
 
 The need to encourage compliance by other operators
 
 Due to the nature of the violations, other customers not investigated by the Commission may have been affected.
 
 LBG's senior management should be aware of the governance issues that led to the violations, given the seriousness of the violations.
 
 Failure to comply with Social Responsibility Code Provision 3.5.3 Paragraph 6 – Self-exclusion between November 2020 and February 2021
 
 The extent of steps taken to remedy the violations - the franchisee implemented an early action plan to remedy the violations.
 
 The licensee procedurally complied with the Commission's timeline for providing materials and requested extensions when such materials could not be provided within the expected time frame.
 
 Gaming operators should take into account the failures identified in this investigation to ensure industry learning. Operators should consider the following questions:
 
 Do they have a formal process in place to measure the effectiveness of their gambling policies and procedures? Are your gambling policies and procedures safer and more secure and are their outcomes properly recorded?
 
 The regulatory arrangements were as follows:
 
 Have lessons learned from public statements been reflected in your policies and procedures?
 
 Consent to publish a statement of facts in the matter.
 
 Do you record the kind of behavior that triggered the interaction with your customers? Also, do you maintain the appropriate record of the interaction, especially the detailed levels provided, with the decision not to interact?
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors:
 
 1. The committee began reviewing regulations on January 18, 2021.
 
 Mitigating factors:
 
 Appoint a board-level sponsor, reporting directly to the Chairman, to be responsible for implementing the action plan.
 
 Publish: August 17, 2022
 
 The public statement of the committee is a focus on violations of license usage conditions and LCCP requirements (LCCP), which were valid at the time of violation. In some cases, the requirements have been updated.
 
 This Licensee is a member of the Entene Group (ENTAIN) (formerly GVC Group).
 
 Good practice:
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Do you effectively record all compliance-related decisions and provide evidence of ongoing evaluation, assessment and improvement to the European Commission upon request?
 
 Customers who are associated with higher risk countries as a result of their nationality, country of operation or country of residence may present a higher ML and TF risk, taking into account all other relevant factors (AML Guidance para. 2.)
 
 Do you have a formal process for analysing the effectiveness of client interactions to ensure that reviews are properly documented and a consistent approach?
 
 Do you record the types of actions that triggered a client interaction and maintain an appropriate record of the interaction along with the decision not to interact, particularly in terms of the level of detail provided?
 
 This survey led to the start of the compliance evaluation, which led to the launch of the composite remote license number: 000-054743-R-330863-0072 2 LC International Limited (LCI) section 116 regulation examination 1. The regulation screening discovered a defect in the LCI process for the purpose of preventing money laundering (ML) and more secure gambling.
 
 From December 2019 to October 2020, LCI did not comply with specific license conditions and implementation norms (LCCP):
 
 1, 2, and 3 of the license conditions 12. 1. 1 that require money launding and terrorism (ML and TF)
 
 Footnotes
 
 Licensing conditions 12. 1. 2 obliged operators based in foreign jurisdictions to comply with money laundering, terrorist funding, and fund transfer regulations 2017 (payer information).
 Publication closed
 International Multi-Media Entertainments Limited (IMME)
 
 Paragraphs 1 and 2 of SRCP 3. 9. 1 require licensees to implement policies and procedures to identify separate accounts held by the same person and, where a customer holds multiple accounts, licensees must have and implement procedures that enable them to link each of a customer's accounts with each other.
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Our investigation and subsequent regulatory review found:
 
 Lack of LCI implementation of anti-money laundering (AML) policies, procedures and controls
 
 Failures in responsible policies, procedures, controls and practices, including implementation weaknesses
 
 Some customers who were subject to AML restrictions were unable to open accounts under different brands.
 
 Between December 2019 and October 2020, LCI was found to have breached the following provisions of its license conditions and social responsibility code:
 
 License condition 12: "Licensees must carry out an assessment of the risks that their business will be used for money laundering and terrorist financing. The risk assessment must be appropriate and must be reviewed as necessary in light of changing circumstances, including the introduction of new products or new technologies, new ways of paying by customers, changes in customer demographics, or other significant changes."
 
 LCI admitted that it breached this license condition because its ML and TF risk assessments did not adequately reflect the European Commission's expectations and did not take sufficient account of the European Commission's ML and TF risk assessments of the UK gambling industry.
 
 The failures were that LCI's risk assessment did not:
 
 mention terrorist financing
 
 specifically mention customer nationality or business risk in section 3 of geographic risk.
 
 License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensee has been confirmed that it is properly carried out, procedures, and management to prevent money laundering and terrorism funding. I have to do it.
 
 Licensing conditions 12: "Licensei has such policies, procedures, and controls effectively, have been r e-reviewed, and are appropriately reviewed, and the gambling committee is relevant learning and guidelines at any time. We must guarantee that we are taking into account. "
 
 LCI acknowledged that this license was violated:
 
 There were weaknesses and defects in the appropriateness and maintenance of the policy and procedure, and its implementation.
 
 The committee has confirmed that some customers can deposit large amounts of money without causing interaction (specifically checking funds (SOF)):
 
 Customer A had a £ 742. £ 742. Licensee has confirmed that the customer is a new company director through open source. Licensei did not know the customer salary because open source personal financial information was not obtained. At the time of the assessment, the customer had lost £ 59 in the past six months. I lost £ £ £ down.
 
 Customer B, which was registered in February 2020, had a total of £ 186. £ 186. £ 31. 000 pounds for six months, 31. 000 pounds, and almost 25. 000 pounds for three months. Licensee acknowledged that it should have been responded earlier after confirming that the customer's home address was a social housing property.
 
 Customer C deposited £ 157. 698 in two months. However, Licensee first demanded the details of SOF on August 9, 2020, but the customer was allowed to continue gambling on August 27, 2020 until his account was restricted. Later, Licensee was concerned about the legitimacy of the provided evidence, and closed his account when he received the customer evidence.
 
 Customer D deposited a total of £ 524. 501 during the failure of the failure, causing a loss of £ 75. 600. The customer was not required to submit evidence until April 2020, but he refused to submit, and his account was later closed. License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensei has an appropriate policy, procedure, and management to prevent money laundering and terrorism funding. You have to confirm that.
 
 Licensing conditions 12: "Licensei has such policies, procedures, and controls effectively, have been r e-reviewed, and are appropriately reviewed, and the gambling committee is relevant learning and guidelines at any time. We must guarantee that we are taking into account. "
 
 LCI acknowledged that this license was violated:
 
 There were weaknesses and defects in the appropriateness and maintenance of the policy and procedure, and its implementation.
 
 The committee has confirmed that some customers can deposit large amounts of money without causing interaction (specifically checking funds (SOF)):
 
 Customer A had a £ 742. £ 742. Licensee has confirmed that the customer is a new company director through open source. Licensei did not know the customer salary because open source personal financial information was not obtained. At the time of the assessment, the customer had lost £ 59 in the past six months. I lost £ £ £ down.
 
 Customer B, which was registered in February 2020, had a total of £ 186. £ 186. £ 31. 000 pounds for six months, 31. 000 pounds, and almost 25. 000 pounds for three months. Licensee acknowledged that it should have been responded earlier after confirming that the customer's home address was a social housing property.
 
 Customer C deposited £ 157. 698 in two months. However, Licensee first demanded the details of SOF on August 9, 2020, but the customer was allowed to continue gambling on August 27, 2020 until his account was restricted. Later, Licensee was concerned about the legitimacy of the provided evidence, and closed his account when he received the customer evidence.
 
 Customer D deposited a total of £ 524. 501 during the failure of the failure, causing a loss of £ 75. 600. The customer was not required to submit evidence until April 2020, but he refused to submit, and his account was later closed. License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensee has been confirmed that it is properly carried out, procedures, and management to prevent money laundering and terrorism funding. I have to do it.
 
 Licensing conditions 12: "Licensei has such policies, procedures, and controls effectively, have been r e-reviewed, and are appropriately reviewed, and the gambling committee is relevant learning and guidelines at any time. We must guarantee that we are taking into account. "
 
 LCI acknowledged that this license was violated:
 
 There were weaknesses and defects in the appropriateness and maintenance of the policy and procedure, and its implementation.
 
 The committee has confirmed that some customers can deposit large amounts of money without causing interaction (specifically checking funds (SOF)):
 
 Customer A had a £ 742. £ 742. Licensee has confirmed that the customer is a new company director through open source. Licensei did not know the customer salary because open source personal financial information was not obtained. At the time of the assessment, the customer had lost £ 59 in the past six months. I lost £ £ £ down.
 
 Customer B, which was registered in February 2020, had a total of £ 186. £ 186. £ 31. 000 pounds for six months, 31. 000 pounds, and almost 25. 000 pounds for three months. Licensee acknowledged that it should have been responded earlier after confirming that the customer's home address was a social housing property.
 
 Customer C deposited £ 157. 698 in two months. However, Licensee first demanded the details of SOF on August 9, 2020, but the customer was allowed to continue gambling on August 27, 2020 until his account was restricted. Later, Licensee was concerned about the legitimacy of the provided evidence, and closed his account when he received the customer evidence.
 
 Customer D deposited a total of £ 524. 501 during the failure of the failure, causing a loss of £ 75. 600. The customer was not required to submit evidence until April 2020, but he refused to submit, and his account was later closed.
 
 In June 2020, the customer deposited £ 10. 000 a day and hit the AML trigger. For the first time, Licensee confirmed his account (with open source check), but did not find any disadvantageous information. The customer was allowed to continue playing until he pulled another AML trigger, which deposits £ 60. 000 in seven days, which caused a License SOF check.
 
 Licensei thought that the customer was a wealthy individual based on the assumptions during the open source check. However, before the request for funding in August 2020, there was no evidence of the alleged wealth being used as an account funding source. Customers deposited £ 140. 700 during the disability period, and net income was £ 60. 300.
 
 Paragraph 1 of this statement has been enforced since October 2016 and is required:
 
 "Licensei is amended or replaced, regardless of whether the MLR is applied to that business, as far as the Money Laundering Rules (Revised) Rules 2007 (MLR) are related to the 2007 (MLR). Requirements for British legal documents.
 
 AML policies, procedures and controls
 
 Licensee accepts that the abov e-mentioned AML default has violated this license condition to configure the money laundering regulations 2017, that is, a violation of money laundering regulations:
 
 Rules 19 (1) (a) effectively reduces and manages the risks of "related people" identified by the risk assessments implemented by relevant people. We are seeking that management and procedures must be maintained.
 
 Rules 28 (11) (a) requires continuous monitoring in trading, so to make sure that transactions match customer profile, customer profile, and risks as needed. Includes the funding of the funding source.
 
 Rules 33 imposes an obligation to implement ECDD measures and enhance continuous monitoring in a situation that is identified as high risk of money launding and terrorism funding.
 
 The European Commission considered a specific customer specified during compliance evaluation, and it was not found that they had not made a criminal charges against Licensei.
 
 Social responsibility failings
 
 Compliance with SRCP shall be a license condition according to Article 82, Paragraph 1 of the Act. SRCP 3. 4. 1 (revised on October 31, 2019) is described as follows:
 
 "1 Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related damage. This includes the following:
 
 a. identifying customers who may suffer or suffer gambling.
 
 b. To contact customers who may suffer or suffer gambling.
 
 c. Understand the effects of exchanges on customers, and the effectiveness of licensing and approach.
 
 2. Licensee must consider the European Commission's guidance on dialogue with customers.
 
 LCI acknowledged that SRCP3. 4. 1 was not completely compliant:
 
 In a way to minimize the risk of harm associated with gambling, it was delayed or could not be interacted with a specific customer specified by the committee.
 
 Suitability concerns
 
 Customer F performed a large amount of deposits and withdrawals and lon g-time play from night to early morning in Licensee's habits. The chat was exchanged only once. Licensee accepted that the dialogue with this customer was lacking, and in November 2018, the customer's account was opened, contrary to the previous decision to be closed forever due to an analyst mistake. Accept
 
 Regarding Customer A, who deposited £ 742. 000, Licensei deposited £ 742. 000 in 14 months. Regarding the customer A, who deposited £ 1 in 14 months, Licensei acknowledged that the customer action had not reached the level expected by the European Commission or Licensei himself. He acknowledges that he should have been involved with the customer earlier, and that he had to ask more questions about the margin and income when he was involved. Since then, Licensee has revised procedures related to the reference value so that such oversight does not recur.
 
 SRCP 3. 9. 1, paragraphs 1 and 2 are specified as follows:
 
 "1. Licensee must set a policy and procedure to identify the separate accounts held by the same person.
 
 2 If Licensee keeps many accounts to customers, Licensei has a procedure to associate the customer's account with other accounts, and to do this, and implement it:
 
 a. if a customer chooses to exclude themselves from self-representation, the customer is effectively excluded from all gambling with the licensee, unless the customer makes clear that their request relates only to a specific form of gambling or gambling using only some of the accounts they hold with the licensee;
 
 b. all of a customer's accounts are monitored and decisions to trigger interactions with the customer are made based on behavior and transactions observed across all accounts;
 
 c. when credit is provided or granted, credit limit caps apply in the aggregate to all accounts; and
 
 d. individual credit limits apply to all of a customer's accounts.
 
 LCI acknowledged that it did not fully comply with SRCP3. 9. 1AS.:
 
 AS: Customers subject to AML checks and restrictions had the opportunity to open multiple accounts with the franchisee's other brands.
 
 In one case, a client whose account was blocked at Coral for spending £60. 000 in 12 months and not providing a source of funds was able to immediately open an account at Ladbrokes and deposit £30. 000 in one day.
 
 The regulatory action consisted of:
 
 (i) the divestment of £544. 03. 048. 03, and (ii) a payment in lieu of £13. 455. 952, consisting of a payment in lieu of financial penalties totalling £14. 000. 000, which will be directed towards socially responsible causes.
 
 Consent to public disclosure of the facts in this matter
 
 LCI agrees to amend its license to add the following condition:
 
 Appoint a board-level sponsor reporting directly to the Chairman and responsible for the implementation of the action plan.
 
 Conduct an independent audit of the gaming insurer's relevant policies and procedures within 12 months to ensure that its policies, procedures and controls are effectively implemented and subsequently implement any safeguard recommendations of the independent audit.
 
 In considering an appropriate resolution to this investigation, the Commission took into account the following aggravating and mitigating factors:
 
 The serious nature of the breaches identified
 
 The impact on licensing purposes
 
 There have been repeated breaches or defaults by the operator or other pool companies
 
 The breaches occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the wider industry.
 
 Need to encourage compliance among other operators
 
 Due to the nature of the breach, other customers not investigated by the Commission may have been affected.
 
 LCI senior management should be aware of the governance issues that led to the breach, given the severity of the breach.
 
 The extent of steps taken to remedy the breach – the franchisee implemented an early action plan to remedy the breach.
 
 The licensee procedurally complied with the Commission’s timetable for providing materials and requested extensions when such materials could not be provided within the expected time frame.
 
 Gaming operators should take into account the failures uncovered in this investigation to ensure industry learning. Operators should consider the following questions:
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Do you effectively record all compliance decisions, and can you show evidence of ongoing evaluation, assessment and improvement, as requested by the Commission?
 
 Are lessons learned from public statements reflected in your policies and procedures? Are customer risk profiles developed or linked to money laundering and terrorist financing risk assessments?
 
 Do you have a formal process for analysing the effectiveness of customer interactions to ensure that reviews are properly documented and the approach is consistent?
 
 Do you record the types of actions that triggered customer interactions and maintain appropriate records of the interactions, particularly the level of detail provided, along with any decisions not to interact?
 
 Do your employees receive appropriate AML and SR training?
 
 1 The European Commission launched a regulatory review on 11 November 2020.
 
 2 Transactions under the LCI: Cheeky Bingo? Coral; Foxy Bingo; Foxy Games; Foxy Bingo; Foxy Games? Cheeky; Gala bingo; Gala Casino; Gala Coral; Gala bingo; Gala Casino; Gala Coral. Gala Spins; Gala Casino; Gala Casino; Gala Spins; Gala Casino; Galas; Gala Spins; Gala Casino; Galas Casino; Gala Spins. Party Casino? Poker Party; Poker parties; Poker Party; Sports Betting? Bwin
 
 3 The AML Guidance and the European Commission's MLTF risk assessment provide a number of factors that can and must be taken into account when conducting your own MLTF risk assessment. Furthermore, Article 18. 2(a) of the Regulation requires licensees to take these documents into account when conducting their own MLTF risk assessment.
 
 Publication closed
 Greentube Alderney Limited Public statement
 
 Published: May 17, 2022
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Key failings
 
 Before automatic restrictions were applied to the customer account, some customers could bet at a high rate.
 
 Breaches of Licence Condition 12. 1. 2 (Anti-Money Laundering Measures for Entities Based in Foreign Jurisdictions) Clause 1
 
 Social Responsibility Code 3. 4. 1(1) and (2) - Failure to comply with the provisions of customer interaction.
 
 Due to the ML/TF risk, some of the interaction customers should have restricted more play.
 
 The limit of financial deposits was too high, so it had no effect on suppressing hig h-speed expenditures and allowed some customers to exceed the limit of AML risk. License status 12: "If the risk assessment is completed and the assessment is reviewed, Licensee has been confirmed that it is properly carried out, procedures, and management to prevent money laundering and terrorism funding. I have to do it.
 
 Introduction
 
 Blue Star Planet Limited accepted it at the time of the assessment:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Gamble will be performed in a fair, safe and open way.
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 The regulatory review found deficiencies in Jumpman Gaming's processes designed to prevent money laundering (ML) and promote safer gaming by protecting vulnerable individuals.
 
 Evidence collected during the compliance assessment and subsequent licence review found that Jumpman Gaming did not comply with its Licence Conditions and Code of Practice (LCCP):
 
 Licence Condition (LC) 12. 1. 1 clauses 1, 2 and 3 require Jumpman Gaming to comply with the prevention of money laundering and terrorist financing.
 
 Licence condition 12. 1. 2 requires operators based in foreign jurisdictions to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Payer Information) Regulations 2017 (the "2017 Regulations").
 
 Due to the ML/TF risk, some of the interaction customers should have restricted more play.
 
 Furthermore, the following deficiencies were pointed out:
 
 Section 1 and 2 of SRCP3. 9. 1. This is a requirement for a policy and procedure to identify a separate account held by the same person, and is a requirement for residents to hold multiple accounts on customers.
 
 Jumpman Gaming will pay a total of £ 500 instead of financial penalties, based on our JUMPMAN GAMING's improvement measures and based on our license and regulations.
 
 The customer is a national of a third country and is applying for residency or citizenship in that country in exchange for transferring capital, purchasing real estate, purchasing government bonds or investing in a legal entity in that country (AML Guidance section 6. 33).
 
 Insufficient in Jumpman Gaming ant i-money laundering (AML) policy, procedure, and management.
 
 Operators are hoped that they will reconsider their own practices to address the questions described below, identify and implement improvements in customer account management.
 
 A licensed gaming carrier has a legal obligation to guarantee that the gaming facility will be provided according to the 2005 gaming method (open on a new tab) (ACT), the conditions of the license, and the following license purposes.
 
 In the licensed status of 12. 1. 1 (1), "Licensei must carry out the risks used by businesses for money laundering and terrorism funding. The risk evaluation must be appropriate. We must review new products and new technologies, new payment methods, changes in customers, and changes in situations in other significant changes.
 
 Breach of paragraph 1 of license condition 12.1.1
 
 There were repeated breaches or defaults by the business.
 
 The committee determined that the relevant risk assessment was rejected:
 
 Considering information on the risks of ML and TF provided by the European Commission, examining them appropriately.
 
 Properly evaluating the risks of customers who meet certain standards.
 
 The reliable sources to fully evaluate the risks of trading relationships and transactions involved in countries that have been identified as no effective systems to deal with ML and TF.
 
 Breach of paragraph 2 of license condition 12.1.1
 
 The following paragraph 1 of the Ordinance Rules (OCP) 2. 1. 1 states: "Licensei prevents money laundering from the European Commission to prevent activities related to money laundering and terrorism funding. It must act according to the guidelines and the guidance for resolved and no n-casinos.
 
 JUMPMAN GAMING accepting the issues pointed out by the European Commission in compliance evaluation, indicating deficiencies in policies and procedures, and acknowledged that they violated the license conditions of 12. 1. 1 (2).
 
 Committee concerns are as follows:
 
 The policy, procedure, and management seemed to combine the source of wealth (SOW) and the source of funds (SOF). SOF refers to the source of funds involved in specific transactions. SOW refers to the source of all customers' property.
 
 Breach of paragraph 3 of licence condition 12.1.1
 
 Agree to publish facts regarding this matter
 
 The policy document did not cover the guidance requirements for employees on customered duddyjames (CDD), reinforced CDDs, continuous monitoring, and enhanced continuous monitoring.
 
 Not all hig h-risk factors were considered in enhanced CDD and enhanced continuous monitoring.
 
 Breach of Paragraph 1 of Licence Condition 12.1.2 (Anti-money laundering Measures for operators based in foreign jurisdictions)
 
 License conditions 12. 1. 1 (3) said, "Licensei is effectively understood, and the management of these policies, procedures, and management is always reviewed, and the Gambling Committee at any time. You must make sure that you take into account the applicable knowledge or guidance to be announced. "
 
 JUMPMAN GAMING acknowledged that the policy and procedure were not completely compliant with the license 12. 1. 1 (3).
 
 Committee concerns are as follows:
 
 Before the significant revision was made, the customer could deposit far exceeding the average of British income and lost.
 
 When a customer encountered an AML warning sign, Licensei did not follow his policy. Later, the customer was able to continue additional payments before the measures were taken.
 
 Despite the large amount of expenditure, customers were able to continue playing at high speed.
 
 Paragraph 1 of this condition has been enforced since October 2016, and it is urging License to comply with the rules 2017 (2017 Regulations) 2017 (2017 Regulations).
 
 Jumpman Gaming acknowledged that the policy and procedure were not completely complied with and had a violation of the license agreement 12. 1. 2.
 
 Breach of Paragraph 15 of Licence Condition 15.2.1 (Reporting key events)
 
 2. Franchisie should consider the European Commission's guidance on dialogue with customers.
 
 The franchisee did not take appropriate measures to identify and assess ML and TF risks.
 
 The franchisee failed to establish and maintain effective policies, controls and procedures.
 
 Failure to comply with Paragraph 1 and 2 of social responsibility code provision (SRCP) 3.4.1 (Customer Interaction)
 
 "1. Licensei must be in contact with customers in a way to minimize the risk of gamblin g-related harm. The following includes:
 
 "1. Licensees must engage with customers in a way that minimises the risk that they will suffer gambling-related harm. This includes:
 
 SRCP 5. 1. 6 - Licence requirements comply with the Advertising Code.
 
 SRCP 3. 4. 1(1) and (2) state: "1. Licensees must interact with customers in a way that minimises the risk that customers will experience gambling-related harm. This includes:
 
 a. Identifying customers who are at risk or who may be experiencing gambling-related harm.
 
 b. Engaging with customers who are at risk or who may be experiencing gambling-related harm.
 
 c. Understanding the impact of interactions on customers and the effectiveness of the licensee's actions and approach. ".
 
 Licensees must take into account the Commission's guidance on customer interactions."
 
 There were repeated violations or defaults by the operator or other pool companies
 
 The regulatory arrangements were as follows:
 
 One customer lost more than £15, 000 in less than a month without gathering sufficient evidence to establish whether he could afford it. This customer lost over £11, 000 in two days at the peak of the Covid-19 lockout.
 
 Consent to publish a statement of facts in the matter.
 
 One customer lost around £19, 000 in around four months without gathering sufficient evidence to establish whether they could afford it.
 
 The Commission also related to the franchisee's failure to take into account the Commission's guidance on customer interactions in accordance with SRCP 3. 4. 1 (2).
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 The business relationship is conducted in unusual circumstances (AML Guidance section 6. 33).
 
 The customer is the beneficiary of a life insurance policy (AML Guidance section 6. 33).
 
 The violations occurred in circumstances similar to cases the Commission has faced in the past, resulting in the publication of lessons to be learned for the industry as a whole.
 
 Rule 18 required that a "relevant person" take appropriate measures to identify and access the ML and TF risks to which its activities are subject.
 
 Do you record the types of behavior that triggered the dialogue with customers, and maintain the appropriate record of the dialogue, especially from the detailed level of detailed levels provided?
 
 a. If the customer chooses sel f-exclusion, the customer is not clear that the request is related to gambling that uses only specific accounts in a specific form of gambling or licensed. Is effectively closed out of all gambling in License.
 
 Mitigating factors
 
 The extent of the measures taken to remedy the violations
 
 c. If credit is provided or permitted, the credit limit is applied to all accounts.
 
 d. Each financial limit can be applied to all customers' accounts.
 
 Good practice
 
 Gambling operators should take into account the weaknesses identified in this investigation so that the industry can learn from them. Operators should consider the following questions:
 
 Do you effectively record all compliance decisions, and can you show evidence of ongoing evaluation, assessment and improvement, as requested by the Commission?
 
 Are lessons learned from public statements reflected in your policies and procedures? Are customer risk profiles developed or linked to money laundering and terrorist financing risk assessments?
 
 Do you have a formal process for analysing the effectiveness of customer interactions to ensure that reviews are properly documented and the approach is consistent?
 
 Do you record the types of actions that triggered customer interactions and maintain appropriate records of the interactions, particularly the level of detail provided, along with any decisions not to interact?
 
 Do your employees receive appropriate AML and SR training?
 
 1 The European Commission launched a regulatory review on 11 November 2020.
 
 2 Transactions under the LCI: Cheeky Bingo? Coral; Foxy Bingo; Foxy Games; Foxy Bingo; Foxy Games? Cheeky; Gala bingo; Gala Casino; Gala Coral; Gala bingo; Gala Casino; Gala Coral. Gala Spins; Gala Casino; Gala Casino; Gala Spins; Gala Casino; Galas; Gala Spins; Gala Casino; Galas Casino; Gala Spins. Party Casino? Poker Party; Poker parties; Poker Party; Sports Betting? Bwin
 
 3 The AML Guidance and the European Commission's MLTF risk assessment provide a number of factors that can and must be taken into account when conducting your own MLTF risk assessment. Furthermore, Article 18. 2(a) of the Regulation requires licensees to take these documents into account when conducting their own MLTF risk assessment.
 
 Publication closed
 VGC Leeds Limited Public statement
 
 Action plan and important measures taken by Licensee to correct violations and prevent recurrence
 
 Our publication describes the violation of the license conditions and the LCCP requirements (LCCP) that were valid at the time of violation. In some cases, requirements have been updated since then.
 
 Key failings
 
 Safer Gambling:
 
 License and their senior executives cooperated with the European Commission in a timely and transparent way.
 
 Anti-Money Laundering:
 
 Gaming operators should pay attention to the failures revealed in this survey to ensure industry learning. The operator should consider the following questions:
 
 Is an official process for measuring AML and safer gambling policies, and the results are appropriately recorded?
 
 Introduction
 
 The lessons learned from public statements are reflected in your policy and procedure?
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Is it possible to effectively record all decisions related to compliance and provide evidence of continuous evaluation, evaluation, and improvement according to the request of the committee?
 
 Make sure that children and other vulnerable are not damaged or exploited by gambling.
 
 Do you record the type of behavior that triggered your customers, especially at the detailed levels provided, and maintain the appropriate recording of interaction?
 
 Are you taking a strong means to identify a separate account held by the same person? Also, is it possible to associate with each customer account and other accounts?
 
 End of public report
 
 Released: May 17, 2022
 
 Our publication reports violations of license conditions and business code (LCCP) requirements that were valid in the event of violation. In some cases, the requirements have been updated.
 
 License Conditions 12. 1. 1 Overwhelmin g-Prevention of money laundering and terrorism funding
 
 Failure to identify customers at risk of gambling related harm
 
 Social responsibility code provision (SRCP) 3.4.1
 
 License conditions 12. 1. 2 violation s-Money laundering measures for operators based in foreign jurisdictions.
 
 Do not follow the norms of social liability 3. 4. 1 (1) and No. 2 (dialogue with customers).
 
 Operators are expected to review their own practices to examine the overview of the issues, identify and implement customer management.
 
 A licensed gaming operator has a legal obligation to guarantee that the gaming facility will be provided according to the 2005 gaming method (law), license conditions, and the following license purposes:
 
 Preventing gambling from being caused by crime, disorder, being associated with crime, or being used to promote crime.
 
 Examples of social responsibility failings include:
 
 Gamble is performed in a fair and open way.
 
 Protect children and other vulnerable so that they are not damaged or exploited by gambling.
 
 Failure to implement effective AML controls
 
 Licence condition 12.1.1 relates to the Prevention of Money Laundering and Terrorist Financing
 
 As a result of this survey, the regulation review of the Progress Play Limited (Progress Play) composite remote casinos 116 and the betting license number: 000-039335-R-319313-017. The European Commission started a regulation screening on August 14, 2020.
 
 The regulation screening revealed that the Progress Play procedure, designed to prevent money laundering and protect vulnerable individuals, was inadequate. Progress play did not comply with license conditions and implementation norms (LCCP):
 
 License conditions 12. 1. 1 are obliged to prevent money laundering and terrorist funding in paragraphs 2 and 3.
 
 License conditions 12. 1. 2 require operators based in foreign jurisdictions to comply with money laundering, terrorist funding, and fund transfer (payer information) rules 2017.
 
 Examples of AML failings include:
 
 Social liability Rules (SRCP) 3. 4. 1 (A), (B), (C), and Paragraph 2. Licensei needs to treat customers with customers in a way to minimize the risk of gamblin g-related damage, and consider the European Commission's guidance on how to interact with customers.
 
 PROGRESS PLAY has fully cooperated in our surveys and acknowledged that the security policy and procedure of more secure gambling and the safer gambling were not appropriate. He also acknowledged that he had not acted according to the license clause. Progress Play submitted an action plan during the investigation and took action to expand and improve compliance.
 
 In consideration of the improvement of progress by progressive play, and in accordance with the license and regulatory principles statements, Progress Play pays £ 175. 718. 00 instead of fines and disposal. Also pay £ 12. 466, 35.
 
 Licence Status 12. 1. 1 (2) states: "Once a risk assessment has been completed and a review of the assessment has been conducted, the licensee shall satisfy itself that it has in place appropriate policies, procedures and controls to prevent money laundering and terrorist financing." .
 
 The Commission officials consider that Progress Gaming has failed to establish and maintain appropriate policies, procedures and controls to prevent money laundering and terrorist financing.
 
 Progress Gaming accepted:
 
 Customers were given 14 days to provide supporting source of funds (SOF) information, during which they could continue to place bets. This approach did not adequately address the risk of money laundering.
 
 License Condition 12. 1. 1 (3) states: "Licensees must ensure that such policies, procedures and controls are effectively implemented, kept under review and appropriately revised to ensure they remain effective, taking into account any applicable learning or guidelines published by the Gambling Commission from time to time.".
 
 Commissioners consider that Game Progress has failed to ensure that its policies, procedures and controls are effectively implemented, kept under review and appropriately revised to ensure they remain effective, taking into account any applicable learning or guidelines published by the Gambling Commission from time to time.
 
 Game Progress report accepted:
 
 The regulatory arrangements were as follows:
 
 There was some evidence of SOF information being recorded in the customer profiles reviewed, but there was a lack of clear logic around decision making.
 
 Failure to effectively review SOF information provided, which resulted in customers being able to spend more than their known earnings.
 
 Do you have a formal procedure to measure gambling policies and procedures and to properly record safer and reliable results?
 
 The first of these conditions The section requires that: "Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (Law Society Act 2157 of 2007), as amended by the Money Laundering (Amendment) Regulations 2007 (Law Society Act 3299 of 2007), or any equivalent requirement of English law which amends or replaces those regulations (MLR) in so far as they relate to casinos."
 
 In considering an appropriate solution to this investigation, the Commission considered the following aggravating and mitigating factors:
 
 Aggravating factors
 
 Do you have a formal process to analyze the effectiveness of the interaction with customers, the reviews are properly documented, and that it was consistent approach?
 
 Establish and maintain appropriate policies and procedures commensurate with the risk
 
 Appropriately manage all customer business relationships and obtain SOF evidence aligned with the customer's risk profile
 
 Discontinuation
 
 Mitigating factors
 
 Compliance with the SRCP is a condition of authorisation under section 82(1) of the Act. SRCP 3. 4. 1 (amended 31 October 2019) states:
 
 Licensees must engage with customers in a manner that minimises the risk that customers will experience gambling-related harm. This includes:
 
 a. Identify customers who are at risk of, or may be experiencing, gambling-related harm.
 
 Elim Poon - Journalist, Creative Writer
 Last modified: 27.08.2024
 
 Guiding Principles for Public Statements These guiding principles help NACAC leaders determine when it is appropriate to make a public. Statements should contain a clear, concise, and balanced presentation of significant facts and valid inferences, including relevant benefits and. We enforce federal competition and consumer protection laws that prevent anticompetitive, deceptive, and unfair business practices.

Play

accepted

Public statements

Public Statements

Introduction

Breached paragraph 2 of licence condition 12.1.1 (Prevention of money laundering and terrorist financing) between May 2021 and July 2022

Breached licence condition 12.1.2 (Anti-Money Laundering - Measures for operators based in foreign jurisdictions) between May 2021 and July 2022

Failed to comply with paragraphs 1b and 1c of SRCP 3.4.1 (Customer Interaction) between October 2021 to September 2022

Aggravating factors

Mitigating factors

Good practice

Hillside (UK Sports) ENC Public Statement

Introduction

Breached paragraph 2 of licence condition 12.1.1 between May 2021 and July 2022

Failed to comply with paragraphs 1b and 1c of Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction) between October 2021 to September 2022

Aggravating factors

Mitigating factors

Good practice

Lindar Media Limited Public Statement

Introduction

Breach of paragraph 1 of licence condition 12.1.1

Breach of paragraph 2 of licence condition 12.1.1

Breach of paragraph 3 of licence condition 12.1.1

Failure to take into account Ordinary Code Provision 2.1.1

Breach of licence condition 15.2.1 (4) - Reporting key events

Breach of licence condition 1.2.1(3) - Specified management offices – personal management licences

Failure to comply with paragraph 1b, 1c and 2 of SRCP 3.4.1 (Customer Interaction)

Identify

Interact

Failure to comply with SRCP 5.1.6 - the advertising codes

Failure to comply with SRCP 3.1.1(2) – Combating problem gambling

Aggravating factors

Mitigating factors

Good practice

Notes

Done Bros (Cash Betting) Limited Public Statement

Introduction

Breached licence condition 12.1 Prevention of money laundering and terrorist financing

Breach of paragraph 1 of licence condition 12.1.1

Breach of paragraph 2 and 3 of licence condition 12.1.1

Failed to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)

Aggravating factors

Mitigating factors

Good practice

Notes

Videoslots Limited Public Statement

Introduction

Breach of licence condition 12.1.1(3)

Failure to comply with SRCP 3.4.1 Customer interaction

Conclusion

Aggravating factors:

Mitigating factors:

Good practice

Notes

Skill On Net Limited Public Statement

Introduction

Breach of paragraph 1 of licence condition 12.1.1

Breach of paragraph 2 of licence condition 12.1.1

Breach of paragraph 3 of licence condition 12.1.1

Breach of paragraph 1 of licence condition 12.1.2 (Anti-money laundering - measures for operators based in foreign jurisdictions)

Failure to comply with SRCP 3.4.1 paragraphs 1 and 2

Aggravating factors:

Mitigating factors:

Good practice

Notes

William Hill Organization Limited Public Statement

Introduction

Breach of paragraph 1 of licence condition 12.1.1

Breach of paragraphs 2 and 3 of licence condition 12.1.1

Failure to comply with Paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)

Aggravating factors

Mitigating factors

Good Practice

Notes

WHG (International) Limited Public Statement

Introduction

Breach of paragraph 1 of licence condition 2.3.1

Breach of paragraph 1 of licence condition 12.1.1

Breach of paragraphs 2 and 3 of licence condition 12.1.1

Breach of paragraph 1 of licence condition 12.1.2 (Anti-money laundering measures for operators based in foreign jurisdictions)

Failure to comply with paragraph 1 and 2 of SRCP 3.4.1 (Customer Interaction)

Failure to comply with paragraphs 1a, 1c and 1d of SRCP 3.7.1 (Provision of Credit)