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Share Tweet Browser does not support script. The Licensee accepted that at the time of the corporate evaluation, it had not been compliant with the Regulations and was not compliant with the Regulations. Officials accepted that this was a technical issue and not a deliberate breach. Our what we do page also provides an overview of the types of queries we are able to help consumers with in the first instance. This licence condition has been in force since October An appropriate risk assessment allows operators to identify risks relevant to their business, including the risks associated with the customers they transact with, and conduct effective customer due diligence on the basis of this assessment, among other things. Indicated that it had put in place a series of enhanced social responsibility alerts and these had been applied across both of its platforms. The Licensee stated that at the time of the corporate evaluation it had recognised the need for a training program which it had put in place and that by September appropriate additional training was in place. In addition the Licensee accepted that whilst it was subject to the Regulations, improvements could have been made to the training provided to staff in how to recognise and deal with transactions and other activities which may relate to money laundering or terrorist financing. Our phonelines are open on Monday, Wednesday and Friday between 10 am and 4 pm. The contact us service is also available for answers to common questions and we will aim to respond to these enquiries as quickly as possible. The Commission made the Licensee aware of the requirement at the time and in a letter of 5 October In its responses, the Licensee accepted that it had breached this licence condition and subsequently provided a risk assessment approved by its Board on 23 February Licence condition attached to the licence on 1 November and Licence Condition The Licensee was required to put in place and implement the measures described in Parts 2 and 3 of the Money Laundering Regulations superseded by the Regulations insofar as they relate to casinos. Regulation 28 11 of the Regulations requires the Licensee to conduct ongoing monitoring which includes scrutiny of the transactions undertaken by the customer throughout the course of the business relationship, including the source of funds , and Regulation 33 of the Regulations includes the requirement to apply enhanced customer due diligence measures and enhanced ongoing monitoring in situations where there is a high risk of money laundering or terrorist financing. Officials saw evidence of customers being offered free spins or Amazon vouchers to retain their business, but it was not clear that this was appropriate. Experts by Experience interim group created The Gambling Commission has today announced tha….{/INSERTKEYS}{/PARAGRAPH} Officials noted that the Licensee has now refunded this money to the customers. This manifested itself in terms of resource, systems, and controls for example: the Social Responsibility policy and procedure was not sufficient - it only gave examples to staff of potential issues as opposed to outlining detailed action to be taken to mitigate risk, and there were no specific policies for VIP customers; there had been insufficient resources for identifying and mitigating SR risk. In its response, the Licensee acknowledged that, at the time of the corporate evaluation policies and procedures for customer interaction were not sufficient to identify problem gambling and could have been improved. In its response the Licensee provided the Commission with a written complaints resolution policy. This manifested itself in terms of resource, systems, and controls for example:. In its response the Licensee accepted that at the time of the corporate evaluation its written policies and procedures needed improvement. The Commission requires the outcome of the review and subsequent action plan to implement any recommendations to be reported to the Commission by the person who assumes responsibility for this action, and that the Commission will have access to all the documents relating to the work. The Licensee:. In relation to the Regulations, Commission officials had set out examples where they considered that the Licensee had failed to consistently apply enhanced customer due diligence and enhanced ongoing monitoring on a risk-sensitive basis, contrary to regulations 28 and 33 of the Regulations. If you are a gambling operator please read our Frequently Asked Questions for gambling businesses. Code of practice issued under Section 24 Gambling Act Social responsibility code 6. Read Daub Alderney Summary of Decision notice below. The Licensee indicated that it was working with external advisors to make improvements to its responsibility policies and procedures. The Licensee indicated it had now addressed the backlog completely and had successfully filtered its entire database against its revised alerts. The Licensee highlighted the following action that it had taken: it had reviewed the customers identified by the Commission during the corporate evaluation and referred to in our letter of 5 October The Licensee accepted it had made insufficient enhanced due diligence EDD and source of funds SOF enquiries in respect of those customers but did indicate that it had made some enquiries. It is there to support those suffering from gambling problems or those concerned about the affect gambling is having on people close to them. The Licensee was in addition recruiting a new MLRO; with the assistance of external support, the Licensee had improved its written policies and procedures to ensure full compliance with the Regulations. This alert had identified customers who had not provided sufficient and acceptable SOF. The Licensee asserted that since the Commission's corporate evaluation in June and July , it had made significant improvements in its anti-money laundering and counter-terrorist financing policies and procedures. The following facts were stated in the Case Summary. It accepted that it required additional resource within its compliance team, but it said it had provided some mitigation to the risk by providing resource from other business areas. Commission Officials found that the Licensee did not: conduct appropriate ongoing monitoring of a business relationship Regulation 14 of the Regulations. We commenced a review under section 2 of the Gambling Act the Act because:. Such policies, procedures and controls are implemented effectively, kept under review and revised appropriately. The Panel found: that the Licensee did not have an appropriate risk assessment in place until February Its failure constituted a breach of licence condition In doing so, the Panel found that the Licensee had breached conditions All such staff must undertake outsourced refresher training annually thereafter the Licensee continues to segregate funds as per Licence condition 4. In using this alert across its customer based it identified 63 from whom satisfactory SOF information had not been received. Regulatory returns - further temporary extension to submission dates Regulatory returns are a basic condition of hol…. At the time of the corporate evaluation, the Licensee had not put into effect a written procedure for handling customer complaints and disputes. In reaching this decision the Panel had regard to the Statement of principles for determining financial penalties June Due to the impact Covid is having on operations across the UK we have had to reduce our phoneline opening hours. On 12 January the Gambling Commission the Commission gave Daub Alderney Limited the Licensee notice that we were commencing a review of its operating licence. Our approach to enforcement. {PARAGRAPH}{INSERTKEYS}Daub Alderney will also have extra conditions placed on its licence to provide gambling to consumers in Britain. You can call them free on , or visit gamcare. Between 14 July and 1 September , 98 self-exclusion emails and 30 problem gambling emails were not directed to customer service. Code provision 3. Approaching the decision as to what sanction s , if any, should be imposed under section of the Act the Panel referred to the Indicative sanctions guide June and the Statement of principles for licensing and regulation June The Panel also agreed that it was appropriate to impose a financial penalty under section of the Act. It agreed that it had failed to document in adequate detail its risk-sensitive policies and procedures relating to anti-money laundering AML and terrorist financing. Posted on 13 November Show all parts of this guide Other news Stephen Cohen reappointed as Commissioner Regulatory returns - further temporary extension to submission dates Experts by Experience interim group created. The Regulatory Panel has found that the Licensee: breached conditions of its licence relating to anti-money laundering measures AML failed to comply with social responsibility codes of practice. Licence condition Such risk assessments must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic, or any other material changes, and in any event reviewed at least annually. It indicated improvements included the lowering of financial alerts, a consistency of alerts across platforms and the ability to review customer activity across its platforms. If you have a question about your gambling, or the gambling of someone close to you, our FAQs from gambling consumers during lockdown may provide valuable information. Officials nevertheless noted that this failure occurred for such a period of time and is likely to have had a significant impact on the self-excluded customers as they were able to continue to deposit funds into, and play on, their accounts. This summary of the Regulatory Panel decision sets out the relevant facts of the case, licence condition and social responsibility code of practice provisions, the findings and the outcome of the review.