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UK LEGAL COMMENT


A busy month


The UK Gambling Commission has been baring its teeth in recent weeks. Northridge Law’s Melanie Ellis looks at the latest developments


sergign/Adobe Stock I 32 NOVEMBER 2021


t has been another busy month for the UK Gambling Commission’s enforcement department. Two licensed operators (VGC Leeds Limited, which operates the Victoria Gate Casino in Leeds, and online operator BGO Entertainment) faced


licence reviews, while an unlicensed operator (Sorare. com) is being investigated to determine whether it is offering unlawful gambling facilities.


VGC Leeds


VGC Leeds Limited agreed a settlement with the Commission after a year-long investigation, paying £241,000 to represent divestment of financial gain accrued as a result of accepted failings, £209,000 in lieu of a financial penalty and Commission costs of £21,578.17. The failings identified in the running of the Victoria Gate Casino related to the identification and management of customers who posed a higher risk of money laundering and gambling related harm, so this is a familiar story about high spending customers. Two customers were highlighted by the Commission in a public statement. The first of these “Customer A” lost £275,000 over the course of 22 months before source of funds evidence was requested, when evidence was provided it consisted of a tax account


demonstrating A earned £217,391. The Commission found this wanting, both in relation to responsible gambling and anti-money laundering checks. It turned out A owned a construction company which had carried out work at the casino premises, this relationship perhaps explaining why the casino was reluctant to query their spending. Casino staff also failed to keep records of the regular interactions they had with the customer. “Customer B” lost £93,294 in the space of 16 months. A number of responsible gambling interactions were carried out with B noting that there were no concerns, but there was no record of the reasons for the interactions in contravention of the operator’s own policy. In relation to AML controls, the casino asked B to provide source of funds evidence within seven days, but nothing was forthcoming until seven weeks later. During that time B was allowed to continue playing at the casino. The bank statements that were eventually provided showed a large balance, but apparently the casino did not query the origin of those funds. This case demonstrates that it is not just online


operators in the firing line. Whilst the Commission’s affordability consultation relaters to remote operators


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