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UK: Gambling Commission imposes conditions and penalty on owner of gambling websites.

Boylesports Enterprise has been found to have breached Gambling Commission rules aimed at preventing money laundering on its websites Boylesports.com and Boylecasino.com .

The Commission said "the operator failed to have an appropriate money laundering risk assessment in place. It was also found that its anti-money laundering policies, procedures and controls were unsuitable and therefore could not be implemented effectively."

Boylesports Enterprise was given an official warning and ordered to pay a penalty of GBP2.8 million for its breaches.

In addition, conditions have been added to its licence:

* Maintaining the appointment of an appropriately qualified Money Laundering Reporting Officer (MLRO) who holds a Personal Management Licence (PML), and, in appointing the MLRO, ensure that the individual undertakes annual refresher training in [money laundering risk and compliance] and be able to evidence this to the Commission.

* Ensuring that all PML holders, senior management and key control staff undertake outsourced anti-money laundering training. All such staff must undertake outsourced refresher training annually thereafter.

* Continuing its review of the effectiveness and implementation of its [counter-money laundering] policies, procedures and controls.

A "personal management licence" is described by the Commission as follows:

"People responsible for the following activities at licensed gambling operators require a personal management licence (PML):

overall strategy and delivery of gambling operations
financial planning, control and budgeting
marketing and commercial development
regulatory compliance
gambling related IT provision and security
management of licensed activity for a particular area in Great Britain where you have five or more sets of premises for which you hold a premises licence
management of a single set of bingo and/or casino licensed premises."

BoyleSports was penalised in respect of two websites. At those websites, it trades under the following names / subdomains: bingo.boylesports.com boylebingo.com boylecasino.com boylegames.com boylelotto.com boylepoker.com boylesports.com boylevegas.com casino.boylesports.com games.boylesports.com livecasino.boylesports.com lotto.boylesports.comm bingo.boylesports.com mcasino.boylesports.com mgames.boylesports.com mlivecasino.boylesports.com mlotto.boylesports.com mobile.boylesports.com mvegas.boylesports.com poker.boylesports.com vegas.boylesports.com

This is a regulatory matter: no criminal proceedings are involved.

The action is against "Boylesports Enterprise." The status of this business is not shown in the Commission's reports. It is not, therefore, clear if this is a company or an unincorporated business; nor is is clear if its business activities are registered in the UK.

The company's principle website says "Boylesports Enterprise is licensed and regulated in Great Britain by the Gambling Commission under account number 39469. Other customers are licensed by the Government of Gibraltar and regulated by the Gibraltar Gambling Commissioner (RGL 083 & 084). "

The company proudly sets out its Irish antecedents, saying that its headquarters are in Dundalk "in Ireland which straddles the border with Northern Ireland.

But on one page there is some small print "As a leading Irish bookmaker, BoyleSports Ltd is proud to have its headquarters in Dundalk, Co Louth, Ireland. BoyleSports is operated by BoyleSports (Gibraltar) Limited, company number 112469, of registered address Suite 2B, 143 Main Street, GX11 1AA Gibraltar. "

That's how corporate KYC becomes difficult.

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