The land based casino Park Lane Club, which is operated by Silverbond Enterprises Limited, has been handed a £1.8 million fine by the United Kingdom Gambling Commission over money laundering and social responsibility failings. The company has also been given an operator licence warning, as well as been on the receiving end of additional conditions to its licence.
When it comes to social responsibilities, the Gambling Commission takes the matter extremely serious. That’s because they can include the need for a company or casino to look out for indicators of problem gambling, which it appears that staff in the Park Lane Club failed to do. That coupled with failures around money laundering paints a picture and in this instance is one that the UKGC felt that it had to act on.
The Gambling Commission released a statement on its website on Wednesday stating that the company Silverbond Enterprises Limited has been given an operator licence warning as well as penalties and ‘additional conditions’ for ‘social responsibility and money laundering failings’.
The UKGC then went on to explain exactly what those social responsibility failings were, as well as why it’s been found guilty of money laundering failings.
Social Responsibility Failings
The UKGC said that companies are expected to look out for the indicators of potential problem gambling, which in this case included:
- A customer displaying ‘violent behaviour’ such as damaging property and threatening staff
- A customer asking the casino to increase the maximum amount of money that it would accept by cheque
- A customer requesting that his winnings be sent to his personal bank account in order to stop him from gambling any further
Whilst it’s not explicitly said in the Gambling Commission’s statement, it is reasonable to infer that Park Lane Club didn’t respond to these various circumstances in a manner that pleased the UKGC.
Money Laundering Failings
Perhaps somewhat more problematic for the company that runs Park Lane Club, Silverbond Enterprises Limited, is the suggestion that they failed to correctly deal with money laundering issues.
The specific examples cited by the Gambling Commission included failing to correctly detail how anti-money laundering policies were carried out with regards to 61 customers, where enhanced due diligence wasn’t done.
The Gambling Commission also issued formal warnings to two of the personal management licence holders at Park Lane Club. This was due to their failure to sufficiently protect players and a failure to prevent potential money laundering, both of which are major issues.
The UKGC used the opportunity to encourage other operators to ‘review their own practices’ after considering the issues brought up in the report. They hope that companies will then implement the necessary improvements.
The Specific Failings
In the report the Gambling Commission drew attention to specific failings of the licensee, Silverbond Enterprises Limited, with regards to their licence for Park Lane Club. They were:
- The Breaching of specific conditions of its licence with regards to the Enhanced Due Diligence it should have carried out on the top 250 depositing customers
- A failure to comply with the Anti-Money Laundering requirements of their licence
- A failure to comply when it came to the codes of practice in place for Social Responsibility
As a result of that the UKGC decided to look at its own Licensing, Compliance and Enforcement policy statement, which outlines a Statement of Principles. The decision was to do the following:
- Fine Silverbond Enterprise £1.8 million, in accordance with section 121 of the Gambling Act of 2005
- Issue the company with a warning section under 117(1)(a) of the Act
- Use section 117(1)(b) to impose additional conditions onto Silverbond Enterprises Limited’s licence
How It All Came About
The Gambling Commission’s investigation has been a long time coming, with a review of the licence held by Silverbond Enterprises Limited actually carried out in February of 2016. The result that review was to use a decision notice to the company regarding an initial failure of Money Laundering Regulations.
After that review the Gambling Commission revised to conduct further inspections of the Park Lane Club, attending the premises on the 16th and 17th of January and then again on the 28th of March. Whilst there, representatives of the Commission looked at random customers accounts, focussing on the top 250 customers in terms of money deposited into accounts.
It was discovered during that research that a large number of the casino’s customers had not been subjected to Enhanced Due Diligence, which they should have been. That meant that the company had failed to meet both the initial licence conditions, 12.1.1, and the additional licence condition imposed in 2017. That additional condition said that the company needed to “complete full enhanced due diligence on its top 250 customers within its customer profiling system”.
The Commission did admit that the licensee’s internal compliance team had drawn attention to the fact that more EDD needed to be carried out prior to players being allowed to continue gambling, but that the casino’s staff allowed them to keep gambling without these additional checks being carried out. It led the Commission to develop ‘serious concerns’ about the way the licensee was carrying out its Anti Money Laundering responsibilities.
As a result, the Commission issued notice to Silverbond Enterprises Limited in May of 2018 that it would carry out a review of its operating licence. All of the things mentioned by the Commission, including the failure to complete sufficient EDD on its clients and that it had breached its licence regarding money laundering, where accepted by Silverbond.
The licensee was then required to carry out Enhanced Due Diligence on its top 250 customers, but the inspections in 2018 revealed that they had failed to do so. When the company’s top 25 customers were reviewed it became apparent that at least half of them had not had EDD checks carried out on them.
Silverbond Have Complied Throughout
There is no suggestion from the Gambling Commission that Silverbond Enterprises Limited have been anything other than compliant with their investigation from the get-go. Indeed, the Gambling Commission drew special attention to the fact that the licensee had co-operated throughout and accepted their failings at every point. They did offer a financial settlement over the matter, but the UKGC decided that the breaches were too serious to accept it.
Some of the aggravating factors from the Commission’s point of view included the fact that the breach lasted for as long as 17 months, as well as Silverbond failing to take note of the Commission’s initial statement on the matter. That previous breaches had been repeated even after the Commission drew attention to them didn’t help the company’s cause. The Commission was also unimpressed that customers who were at risk of problem gambling weren’t more readily identified.