One of the biggest fines for land-based casinos has just been ensued, with a whopping 1.8m pounds bill being the biggest operator license warning in the History of the Gambling Commission. Silverbond Limited has received penalties following an investigation from the Gambling Commission, concerning its Park Lane Club in Mayfair.

The investigation has been launched as per repeated recommendations received by the Gambling Commission. The reasons for the investigation are multiple, which include, but are not limited to failing social responsibility measures of not recognizing the indicators of a timely problem, such as a customer displaying a behavior that is violent or not in accordance with the policies and terms & conditions of the casino and structure of the online betting service in general. Damaging casino property or threatening staff were also primary concerns of the investigators, right alongside small infractions like asking repeatedly for the maximum deposit amount to be realized and others. 

Money laundering suspicions were fueled by the company’s refusal to present its anti-fraud and money-laundering procedures and safety protocols.

Also, two license holders of personal management staff at Park Lane Club received formal written warnings and were informed that they absolutely must improve the history of protecting players and preventing any form of money laundering. Operators are expected to fully consider the issues at hand and review the raised problems one by one, trying to identify the practices that need work and the ones that are in need of a complete overhaul.

Following a review of the license issued to Silverbond Enterprises Limited (Silverbond) t/a Park Lane Club (the Licensee), the Commission found the Licensee:

• Breached specific condition on the profile and depositing practices and profiling techniques.
• did not successfully comply with anti-money laundering requirements and techniques.
• did not comply with the social responsibility codes and terms of practice.

In line with the Commission’s Licensing, compliance and enforcement policy statement, the Indicative sanctions guidance and the Statement of Principles for determining financial penalties, the Commission has decided to:

• impose a financial penalty under the 121 section of the Act, with the total sum of 1.8 million
• issues a warning under section 117(1)(a) of the Gambling Act 2005 (the Act);

The Commission commenced a review of the license that was formally and officially held by Silverbond Enterprises Limited on 26^th of February 2016. Park Lane Club, being the Licensee) was also part of the license. This resulted in the decision notice that was published and the addition of further license conditions to address failings to immediately comply with the Regulations of ML (Money Laundering) Committee back in 2007.

Customers’ accounts were chosen randomly from the top 250 customers and the result was that a significant percentage of these accounts was not subjected to effective EDD checks.

 The operator was discovered by The Commission in its failure to comply with license condition 12.11. about and in direct relation to anti-money laundering (AML) and that it had completely failed to adhere to their additional license conditions within the customer profiling systems.

The Commission is aware of the Licensee’s internal compliance team had correctly identified more EDD should be obtained before allowing players to continue gambling, but casino staff allowed the players to gamble without doing so.

Also, the Commission had concerns about the manner in which the Licensee was undertaking its responsibilities regarding AML and social responsibility requirements code 3.4.1.  In addition to its failure to perform Enhanced due diligence ( EDD) on a number of its top 250 customers, Silverbond completely failed to keep detailed records of the customers.

On 3 May 2018, the Gambling Commission gave Silverbond notice it was commencing a review of its operating license.

The Commission had publicly stated,  and the Licensee fully accepted, that the operator had:

• breached the additional condition of the license in that it had not completed the full EDD on its top 250 customers in the profiling system.
• breached license condition 12, relating to AML, of the Commission’s Licence conditions and codes of practice (LCCP)
• failed to comply with social responsibility code 3.4.1. of the codes of practice.
• In relation to the additional license condition, the operator was required to complete full enhanced due diligence on its top 250 customers within its customer profiling system. It became apparent that sufficient EDD had not been completed both the initial inspections in January and March 2018 and from a subsequent review of the current top 250 customers.