UK Gambling Commission PUNISHES William Hill: £19.2M Fine

On March 28, 2023, The United Kingdom Gambling Commission (UKGC) announced that it had penalized three online gambling businesses £19.2 million ($23.7 million) for social responsibility and anti-money laundering failures. The £19.2 million is the largest amount to ever be paid to the UKGC as a result of social responsibility and anti-money laundering violations.

William Hill Group, also known as WHG (International) Limited, one of the largest brands in the global gambling space, owns and operates the three brands named in the UKGC documentation. WHG operates williamhill.com, Mr Green Limited, which runs mrgreen.com, and William Hill Organization Limited, a brand that operates 1,344 physical gambling shops across the United Kingdom.

Details About William Hill and Mr Green

William Hill is one of the largest and most well-known sportsbook operators around the world. William Hill operates sportsbooks across the United States, United Kingdom, and on the internet. The William Hill Group (International) Limited owns and operates all three brands mentioned in the UKGC’s complaint.

The first brand penalized is williamhill.com, an online sportsbook, racebook, poker room, and casino gaming brand serving customers in the United Kingdom and other regulated markets.

The second brand mentioned, Mr Green, operates an internet casino site that offers customers numerous online games of chance, including blackjack, roulette, slot machines, bingo, and more. It also hosts a sportsbook. Mr Green claims to be specifically focused on promoting responsible and safe gambling, but it is a bit unclear if that truly is the case based on the recent failures.

Information on the Mr Green Casino website

The third brand listed in the complaint is William Hill Organization Limited, which operates 1,344 in-person gambling parlors. These William Hill locations mostly offer sports and horse betting to customers located all over the United Kingdom.

An in-person William Hill gambling parlor (Photo courtesy of William Hill)

Record-High £19.2m Penalty Levied by the UKGC

As a result of the violations by the three operators named in the UKGC complaint, the UKGC will collect a total of £19.2 million ($23.7 million). WHG (International) Limited, which operates williamhill.com, has been ordered to forfeit £12.5 million ($12.5 million), and Mr Green Limited, which operates mrgreen.com, will forfeit £3.7 million ($4.56 million). Additionally, William Hill Organization Limited, which runs 1,344 gambling premises across the U.K., will forfeit £3 million ($3.7 million).

These fines combine to be the largest ever enforcement by the UKGC, overtaking the previous £17 million ($21 million) action against Entain last year. Since the beginning of 2022, operators have paid over £76 million ($94 million) to the UKGC for regulatory failures.

The failures detailed by the UKGC include numerous social responsibility and anti-money laundering failures. Social responsibility failures include:

• Having inadequate measures in place to protect new customers and to effectively consider rapid spending and duration of play to the point that the customer might have faced the risk of big losses in a short period:
  • A customer opened a new account and spent £23,000 ($28,357) in 20 minutes without any checks.
  • Another customer was allowed to register for a new account and spend £18,000 ($22,193) within 24 hours without any checks.
  • A third customer was allowed to register for a new account and spend £32,500 ($40,000) in less than two days without any investigation or checks.(Mr Green)
• Failing to identify specific customers at risk of experiencing gambling related harm and failing to conduct checks at an early enough stage in the customer's journey; one player lost £14,902 ($18,373) in just over an hour. (Mr Green)
• Failing to identify risk of harm or intervene with certain customers early enough; a customer lost £54,252 ($66,889) in four weeks without WHG seeking evidence of income, carrying out adequate checks, or using any other effective method(s) to identify risk of harm. (WHG Limited)
• Having insufficient controls, which exposed both returning and new customers to the risk of significant losses in a brief period of time. One customer opened an account and lost £11,400 ($14,055) over the first month without being subject to sufficient checks. Another customer did not have a phone interaction with the firm until their losses reached £45,800 ($56,468). (WHG Limited)
• Failing to observe a 24-hour delay between receiving a request for an increase in a credit limit and approving it. One customer was allowed to place a £100,000 ($123,295) wager when his credit limit had been previously set at £70,000 ($86,306). (WHG Limited)
• Ineffective controls enabled 331 users to gamble with WHG despite being self-excluded with Mr Green. (WHG Limited)
• Failing to identify changes in the customer behavior which should have led to consideration of whether the customer was experiencing harm – a safer gambling interaction with the bettor was conducted only after he had booked an £18,000 ($22,193) bet (William Hill Organisation Ltd)
• Having deficient controls in effect to protect new customers and to successfully consider high-velocity spend and duration of play until the customer may have been subject to the risk of substantial losses in a short period:
  • After a retail location re-opened following the Covid lockdown, the operator let one customer lose £10,600 ($13,069) in two days without a safer gambling interaction.
  • Staff did not identify a user as being at risk of experiencing gambling harms or pursue any interactions despite the customer being unknown and wagering £42,253 ($52,095) in 130 bets over a period of three days. (William Hill Organisation Ltd)

In addition to the extensive list of social responsibility problems listed above, the UKGC also identified many anti-money laundering issues. Anti-money laundering failures identified in the complaint against William Hill are included below:

• Permitting customers to deposit big amounts without conducting appropriate checks – one customer was able to spend and lose £70,134 ($86,471) in a month, another to lose £38,000 ($46,851) in five weeks and another to lose £36,000 ($44,386) in four days. (WHG Limited)
• Allowing customers to deposit large amounts without conducting appropriate checks – one deposited £73,535 ($90,664) and lost £14,068 ($17,345) in four months (Mr Green)
• Customers could bet large sums of money without being observed or scrutinized to a high enough standard – the operator did not request Source of Funds (SoF) evidence when one customer wagered £19,000 ($23,425) in a single bet, did not get documents from a customer who staked £39,324 ($48,484) and lost £20,360 ($25,102) in 12 days, and did not obtain Source of Funds information or documentation from a user who wagered £276,942 ($341,454) and lost £24,395 ($30,077) in two months. (William Hill Organisation Ltd)
• Policies, procedures, and controls lacked guidance on proper actions to take subsequent to the results of customer profiling and how the findings should be utilized to establish appropriate outcomes. (WHG Limited) and (Mr Green)
• Procedures and controls lacked hard stops to inhibit further spend and abate potential money laundering risks before customer risk profiling is finished. (WHG Limited) and (Mr Green)
• Anti-money laundering staff training lacked sufficient information on managing risks. (WHG Limited) and (Mr Green)

The UKGC also clarified that additional license conditions will also be added to make sure that a business board member oversees an improvement plan and that the brand undergoes a third-party audit to assess that it is effectively implementing its anti-money laundering and safer gambling policies, controls, and procedures.

Andrew Rhodes Comments on the Penalty

Andrew Rhodes is the chief executive of the United Kingdom Gambling Commission. Mr. Rhodes had plenty to say regarding William Hill and this massive penalty:

When we launched this investigation the failings we uncovered were so widespread and alarming serious consideration was given to licence suspension. However, because the operator immediately recognised their failings and worked with us to swiftly implement improvements, we instead opted for the largest enforcement payment in our history…

In the last 15 months we have taken unprecedented action against gambling operators, but we are now starting to see signs of improvement. There are indications that the industry is doing more to make gambling safer and reducing the possibility of criminal funds entering their businesses.

Operators are using algorithms to spot gambling harms or criminal risk more quickly, interacting with consumers sooner, and generally having more effective policies and procedures in place.

Andrew Rhodes, the Chief Executive of the UK Gambling Commission

As can be gathered by the seriousness of Mr. Rhodes’ comments, we can conclude that the violations are some of the most serious in the history of the United Kingdom Gambling Commission. William Hill is a massive operator in the UK, so the potential threat of losing their license could cost them their entire business or at least millions of pounds.

The UKGC Has Come Down Hard on Operators of Late

Back in August of 2022, the UKGC levied the largest fine to date when it penalized the Entain Group £17 million ($21 million). Another recent instance came only a couple of weeks ago when the UKGC fined Unibet and 32Red £7.1 million ($8.7 million).

Another example of a serious fine came when the UKGC penalised Caesars £13 million. Although there are many questions as to the success of the UKGC’s efforts, at least the larger fines may be more effective than some of the smaller fines issued by other regulatory agencies, like when the NJ Division of Gaming Enforcement fined an operator $10,000 (£8,110).

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