William Hill Group fined £19.2m by Gambling Commission

This is a record-breaking figure and follows several other large operator fines having been imposed in recent years and is the sixth operator to be fined in 2023 alone. This action was also made just one week after two operators owned by Kindred Group plc were fined a combined total of £7.2 million.

Information from the Gambling Commission states,

The Gambling Commission’s full press release is available here.

These William Hill Group fines are in respect of widespread anti-money laundering and social responsibility failures. In conjunction with the financial penalties, additional licence conditions will be imposed to ensure improvement in their processes, policies and procedures.

The Gambling Commission findings included:

WHG (International) Limited (‘WHG’)

Anti-money laundering failures:

• to ensure policies, procedures and management oversight was in place within trading rooms.
• a member of trading staff, had a customer’s username and password and placed bets, on the customer’s, instruction via their online account.
• “Certain customers were able to deposit large amounts of money without timely Enhanced Customer Due Diligence (ECDD) – a particular example included Customer A who had a net spend of £36,137 before ECDD profiling”.
• A customer was able to deposit £71,427 and lose £70,134 without the operator having knowledge as to the source of funds or occupation.
• A customer was able to deposit and lose £36,000 in just four days, having registered for an account on 12 March 2021. Significant amounts were lost within the first 24-hour period.

Social Responsibility failures:

• A customer was able to open an account on 15 February 2021, trigger the enhanced customer due diligence threshold on 19 February 2021, but due to a backlog the customer profile was not completed until 17 March 2021. Losses of £54,252 were sustained during the 4 weeks. Income evidence was not requested, and the risk of harm was not identified.
• A customer did not receive a telephone interaction until losses had reached £45,800.
• Overreliance was placed on automated email interactions when safer gambling alerts had been reached.
• A customer was able to immediately place a £100,000 bet when his credit limit had been set to £70,000.

The financial penalty of £12.5 million was to be directed towards socially responsible purposes and included a divestment of £284,361.57. Their public statement is available to view here.

Mr Green Limited

Anti-money laundering failures:

• “Certain customers were able to deposit large amounts of money without timely Enhanced Customer Due Diligence (ECDD) – a particular example included Customer A who deposited £52,985 before ECDD profiling.”
• Assumptions were made that certain customers in a winning position reduced the risk for money laundering, without gathering evidence to support the assertion.
• Undue reliance was placed on open-source information without corroborating this with the customer’s source of funds information .
• A customer was able to deposit £73,535 and lose £14,068 within 4 months as the Licensee focused on the net worth of companies, of which the customer was a director, rather than establishing personal income.

Social Responsibility failures:

• A customer was able to deposit “£23,000 in 24 hours because there was no trigger in place to capture and prevent high velocity gambling without any interaction taking place.”
• An account was opened by another customer on 16 March 2021, who then lost £14,902 in 70 minutes.
• “Inadequate record keeping hampered the operator’s ability to decide how and when to interact with customers.”
• A customer was able to open a new account and spend £32,500 in 2 days without checks in January 2021.
• A further customer was able to spend £23,000 in 20 minutes without checks.
• There was also an overreliance on email interactions when safer gambling alerts were hit by customers.

The total fine of £3,750,000 was to be directed towards socially responsible purposes and included a divestment of £218,310.20. Their public statement is available to view here.

The recent £3.7 million fine is the second fine imposed on Mr Green, following an initial fine by the Gambling Commission in February 2020 for failing to have effective procedures to prevent harm and money laundering. The details of the first fine can be viewed here.

William Hill Organisation Limited

Anti-money laundering failures:

• A customer was not asked for source of funds evidence despite gambling £34,000 and losing £16,000 and having placed a single stake of £19,000.
• A customer staked a total of £276,942 with losses of £24,395 between 17 August and 16 October 2020. Source of funds documentation was not requested until 12 October 2020 and no evidence was received.

Social Responsibility failures:

• “Customer A usually places small stakes but then placed a £19,000 bet. Although a safer gambling interaction was conducted during which he stated he was ‘fine with his spend’, the Licensee failed to proactively further consider him from a responsible gambling prospective”
• A customer was able to stake £42,253 in-store across a 3-day period, the staff did not identify the customer as being at risk of gambling harm and made no interactions.
• The Licensee did not make customer interactions with customers that may have been at risk of experiencing harm early enough.

The total payment of £2,999,850 was also directed towards socially responsible purposes and included a divestment of £244,361.57. Their public statement is available to view here.

Socially responsible purposes and divestments

Socially responsible purposes, as the destination for these financial penalty payments, include a variety of organisations and pilot schemes. They are related to a number of themes, including raising gambling awareness, supporting those harmed by gambling and the recovery process, and research into expenditure patterns, groups of people and communities. The most recent approved destination projects being ‘Aonymind and Leon House’ and ‘Addiction Recovery Agency’. The full list of approved destinations is provided here.

The public statements also detail figures for the amount of ‘divestment’ the betting operator has been requested to make. A divestment is a payment which a betting operator makes, and which must not be offset, to reduce monies accrued where customers have been placed at a disadvantage due to the operator acting contrary to published conditions. Divestments are made to appropriate third party bodies or organisations, and fines are paid to the exchequer.

Andrew Rhodes, the  chief executive of the Gambling Commission also stated:

How can Ellis Jones help you?

The Betting and Gaming Disputes Team at Ellis Jones specialises in assisting with gambling complaints and claims to help clients to either:

1. Recover significant unpaid winnings which have been held by the operator; or
2. Recover substantial funds which have been lost as a result of the failings of betting operators.

We regularly help clients to utilise complaints processes and pursue their claims via court proceedings where required, in order to recover their losses or withheld winnings. At present, we have successfully recovered over £5 million for clients.

We highly recommend that anyone suffering from gambling harm seeks independent medical assistance and there are several charities and organisations available to assist in various circumstances. Some details of these are provided here.

Please contact us if you have sustained financial losses as a result of gambling harm and would like assistance in potentially recovering those funds at bettingclaim@ellisjones.co.uk