Scottish land-based casino sanctioned for AML and customer interaction failings

The Gambling Commission has today (1 September 2021) announced the imposition on 16 August 2021 of (a) a £68,517 financial penalty and (b) a warning under section 117(1)(a) of the Gambling Act 2005 on Corinthian Clubs Limited, the operator of the Casino at the Corinthian Club in Glasgow.

A summary of the AML and customer interaction failings identified by the Commission in this case are set out in the regulator’s Regulatory Action register which states as follows:

Following a review of the operating licence undertaken against Corinthian Clubs Limited t/a Casino At The Corinthian (the Licensee), the Commission found that the Licensee: 

  • breached paragraphs 2 and 3 of licence condition 12.1.1 (Anti money laundering – Prevention of money laundering and terrorist financing) 
  • failed to comply with code of practice issued under section 24 Gambling Act 2005, so as to be treated as a licence condition – Social Responsibility Code Provision (SRCP) 3.4.1 (Customer Interaction).

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: 

  • give the Licensee a warning under section 117(1)(a) of the Gambling Act 2005 (the Act) Act). 
  • impose a financial penalty of £68,517.

The reason for this decision was because the Licensee failed to: 

  • establish and maintain appropriate risk-sensitive policies, procedures and controls to prevent money laundering and terrorist financing 
  • ensure such policies, procedures and controls were implemented effectively, kept under review, revised appropriately to ensure they remain effective and take into account any applicable learning or guidelines published by the Gambling Commission from time to time 
  • promptly interact with customers who may have experience significant harm and losses on the Licensee’s casino products 
  • record sufficient information on customer interactions to demonstrate whether the customer should be identified as high risk for the potential of problem gambling. 

The Licensee co-operated with the investigation and acknowledged the failings. 

The above announcement has been made on the same day as the Commission’s announcement of  a £5.85million fine imposed on Rank Group PLC subsidiary, Daub Alderney Limited, for social responsibility and AML failings, about which we have written more here.