The Gambling Commission has hit Silverbond Enterprises, which owns London-based private members' club and casino The Park Lane Club, with a £1.8m fine for failings in its social responsibilty and anti-money laundering processes.
Silverbond’s troubles with the Commission date back to 2016, when the regulator initiated a review of Silverbond’s licence, which resulted in the imposition of additional licence conditions to address money laundering failures.
Following the review, the Commission conducted further inspections in 2018, in which it was discovered that many of Park Lane Casino’s top 250 customers did not receive enhanced due diligence checks.
According to the Commission, Silverbond’s internal compliance team had correctly identified advanced due diligence checks were needed, but casino staff allowed the players to continue to play. It was also found that Silverbond did not provide details of how money laundering checks were to be carried out, and that the company had failed to retain accurate records of activities from the Money Laundering Reporting Officer.
In total, 491 customers activated financial triggers requiring enhanced due diligence to be completed, yet for 61 of these customers, these checks were not completed.
Further failures were noted in customer interaction. The Commission uncovered cases including a customer displaying violent behaviour – including threatening staff – a customer asking for his winnings to be transferred to his personal bank account to prevent him playing further and a customer asking to increase the maximum amount that could be deposited by cheque.
The regulator noted that there was “insufficient recorded detail or rationale of whether the customer was suffering gambling related harm” in each case.
In May 2018, the Commission informed Silverbond that it was commencing a review of its operating licence, and having considered the information gathered during the review, has opted to impose a £1.8m fine, a warning and further licence conditions.
The conditions include a regular training needs analysis of all staff, to ensure that all staff undertake outsourced anti money laundering training and to ensure that an independent audit of the current top 250 customers is carried out by external auditors within the next six months.