The UK Gambling Commission has issued a record £13m fine against Caesars Entertainment (Caesars) for a series of money laundering and social responsibility failures. The penalty package also includes the imposition of additional licence conditions focused on strengthening anti-money laundering (AML) practices and training.

This latest fine from the Gambling Commission comes just a few weeks after it issued a record (at the time) £11.6m fine against Betway for similar money laundering failures. The Gambling Commission has been particularly active in 2020, having so far issued a total of £27m in penalties and suspended a handful of operating licences.

A key focus of the investigations against Caesars and Betway has been on so-called “VIP practices”, which incentivise high-spending customers to spend more money. In both instances there was evidence that due diligence on “VIPs” was seriously lacking.

In Caesars’ case, examples of key failures included:

• not conducting adequate source of funds checks on a customer who spent around £3.5m over a three-month period and on a politically exposed person who lost £795,000 over the course of 13 months; and
• neglecting to carry out enhanced customer due diligence checks on other customers when appropriate, including on a customer who lost £240,000 in a 13 month period.

In addition to the fine, the Gambling Commission has imposed a number of additional conditions on Caesars' licence, which include:

• ensuring all personal management licence holders, senior management and key control staff undertake outsourced AML training and annual refreshers;
• implementation of annual AML training for all staff, tailored to individual roles; and
• an annual review of the effectiveness of group AML policies and to instruct external auditors to undertake an annual audit of those reviews.

Both investigations have served as a reminder that active co-operation with the regulator is a sensible policy. The Gambling Commission recognised “openness and co-operation” as a mitigating factor in the Caesar investigation and similarly noted full co-operation in the Betway investigation. Other mitigating factors in the Caesars investigation included voluntary disclosure of the results of an internal investigation and the proposal of a regulatory settlement at an early stage in the process.

The imposition of two record fines in less than a month signals a show of intent from the Gambling Commission. With ever-greater scrutiny on the AML procedures of gambling businesses, it may only be a matter of time until this record is broken.