The UKGC’s latest regulatory action related to Lindar Media (trading as MrQ), shows the importance of ensuring procedures are in place for routine tasks such as ensuring RET contributions, as well as updating the UKGC in regards to notifying the Commission of key events, such as changes to management positions!
In the statement on the Gambling Commission website, the Commission outline the good practice operators should carry out to avoid the noted failings, and encourages operators to consider the following questions;
> do you have formal processes in place to measure the effectiveness of your AML and safer gambling policies and are findings adequately recorded?
> do you have sufficient processes in place to ensure that all key events are notified to the Commission in a timely manner
> is your marketing of gambling products and services undertaken in a socially responsible manner. Do they comply with the advertising codes of practice issued by the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP)? Have you familiarised yourself with the latest Advice from CAP on ‘Gambling, betting and gaming: Appeal to children’ (May 2023). SEE LINK
> do you efficiently record all compliance-related decisions and are you able to demonstrate to the Commission, on request, evidence of ongoing assessment, evaluation and improvement?
> do lessons learned from public statements flow into your policy and processes?
> are your customer risk profiles informed by or linked to your money laundering and terrorist financing risk assessment?
> do you have a formalised process for analysing the effectiveness of customer interactions to ensure that reviews were adequately documented and consistent in their approach?
> do you log the types of behaviour which have triggered a customer interaction and keep sufficient records of interactions, along with decisions not to interact especially in terms of the level of detail provided?
> do you have out of hours arrangements in place?
> have your staff received sufficient AML and social responsibility training?
All of the issues noted by the Commission in this release, are covered by the ‘Luke – Audit, Risk and Compliance‘ independent audit and assurance offerings!
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