GB regulator hands Casino 36 £300,000 penalty package

11 July 2019

Land-based operator Casino 36 has agreed a £300,000 penalty package with the GB Gambling Commission for money laundering and social responsibility failures, the regulator has announced. 

The operator will divest £147,741 and make a £152,259 payment in lieu of a financial penalty, which the Commission would otherwise impose for breaches of the Licence Conditions and Codes of Practice (LCCP).

The Commission's investigation found the Wolverhampton-based venue failed to conduct adequate customer enhanced due diligence (EDD), source of funds (SOF) and source of wealth (SOW) checks for 33 customers. These individuals spent a combined £147,741 at Casino 36 between November 2017 and October 2018. According to the commission, senior management became aware of these breaches on February 12, 2018, yet they continued to occur.

The report also stated that Casino 36's controls were "inadequate, outdated and failed to take account of current Commission guidance."

Casino 36 also "failed to protect vulnerable customers," according to the report, by failing to ensure sufficient customer interaction was taking place when customers were potentially displaying signs of suffering gambling harm.

The commission did note "that there was now a willingness by the licensee to ensure appropriate and effective policies are in place and being implemented". However, it added, this "had only now been adopted after several engagements by the Commission, following a prolonged period of time".

In addition to the casino's penalty package, it will also have further conditions added to its licence. All personal management licence holders working for the operator will also have to undergo anti-money laundering training as part of the settlement, while a comprehensive training programme must be launched for staff.

Casino 36 must also maintain EDD on its top 250 customers, split into the top 125 customers in terms of spend, and the 125 customers to lose the most in the casino. This must be carried out within six months of the settlement being agreed, then every 12 months thereafter. Finally, the venue must also appoint an independent chair for its compliance committee to assess its internal controls and systems at least once a year.

Richard Watson, Commission executive director, said operators have a responsibility to ensure they are not allowing illegal funds to flow through their companies.

“As a result of Casino 36’s failings stolen money could have flowed unchecked through their casino and vulnerable customers were placed at risk of harm," Watson said. "This is simply not acceptable.

“Operators have to understand their customer base. This can only be achieved if they know their customers and ask the right questions to meet both their anti-money laundering and social responsibility obligations.”