William Hill to pay “Penalty Package” exceeding £6 million.

Summary

A Gambling Commission investigation has revealed that between November 2014 and August 2016 William Hill (WH) breached anti-money laundering and social responsibility regulations. Ten customers were allowed to deposit large sums of money, but WH failed adequately to seek information about the source of their funds or to establish whether the customers were problem gamblers.  In the event, the money turned out to be linked to criminal offences. The gambling transactions resulted in gains for WH of around £1.2m. WH have been ordered to pay more than £5m for breaching regulations and to divest themselves of the £1.2m they earned from gambling transactions with the ten customers.

Failure to check source of funds

One gambler was allowed to deposit (and gamble with) some £654,000 over nine months, without any check being made as to the source of his funds. He lived in rented accommodation and earned around £30,000 p.a.

Another was allowed to deposit £541,000 over 14 months on the back of a conversation in which he claimed to be earning up to £365,000, with no check or follow-up of his claim. The truth was that he earned around £30,000 a year and funded his gambling habit by stealing from his employer.

Social Responsibility: Problem Gamblers

In addition to its findings relating to money laundering, the Commission found that WH had “breached social responsibility code provision 3.4.1 (customer interaction) in its dealings with the customers who exhibited behaviours indicative of problem gambling”

Systemic Failings

A number of incidents of a like kind brought the total monies deposited without proper money laundering checks being carried out to £3.4 million. The Gambling Commission found that WH had been guilty of “systemic failings” in its anti-money laundering and social responsibility procedures, breaches of the Money Laundering Regulations 2007, and breaches of the Licence Conditions and Codes of Practice to which WH’s gambling licence is subject.

In determining the level of financial penalty the Commission put particular weight on “the likelihood that the issues are not unique to the ten cases and are believed to be systemic in this area of business – we base this on the licensee’s assertions that at the relevant time there was insufficient staff available to manage the pool of at-risk customers”.

See Gambling Commission Statement February 2018

See also: Casinos: Money Laundering

Gerald Gouriet QC