William Hill to Pay £3m for Social & AML Failures

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The UK Gambling Commission (UKGC) has announced that William Hill Organization Limited will pay a regulatory settlement of nearly £3 million following an investigation that uncovered significant social responsibility and anti-money laundering (AML) failures.

The failings, which occurred in the company's retail betting shops between 1 January 2020 and 18 October 2021, led to the operator agreeing to a total payment of £2,999,850. This sum will be directed towards socially responsible causes and includes a divestment of £244,026.95.

The announcement was made in a public statement on 28 March 2023, detailing breaches of the operator's licence conditions.

Social Responsibility Failings

The UKGC investigation found that William Hill failed to protect vulnerable customers, breaching Social Responsibility Code Provision (SRCP) 3.4.1. The operator did not interact with customers in a way that minimised the risk of gambling-related harm.

Specific examples highlighted by the Commission include:

• High Velocity Spend: One new customer was allowed to lose £10,600 in just two days without a safer gambling interaction after retail premises reopened following a Covid-19 lockdown.
• Lack of Identification: Another customer, who was unknown to the operator, staked £42,253 in 130 bets over a three-day period without being identified as at-risk or receiving any customer interaction.
• Delayed Interactions: A safer gambling check was only conducted with one customer after they had placed and had an £18,000 bet accepted. Another customer, who usually placed small stakes, was allowed to place a £19,000 bet with only a brief interaction where they stated they were 'fine with his spend'.

The regulator concluded that the operator had insufficient controls to protect new customers and did not conduct interactions early enough for those who may have been at risk of experiencing harm.

Anti-Money Laundering (AML) Breaches

William Hill also breached Licence Condition 12.1.1, which relates to the prevention of money laundering and terrorist financing. The UKGC found the company's AML risk assessment was inadequate and did not fully align with the Commission's own guidance.

Key failings included:

• Inadequate Policies: The operator's policies and procedures were found to have weaknesses and were not implemented effectively.
• Lack of Scrutiny: Several customers were able to stake large amounts of money without the expected level of monitoring. For example, one customer staked £276,942 and lost over £24,000, and despite a Source of Funds (SoF) request being made, no evidence was ever provided to the operator.
• Failure to Track: The Commission found instances where William Hill could have more effectively tracked customers gambling across its multiple Licensed Betting Offices (LBOs).

While the review of specific customer accounts found no direct evidence of criminal spend, the failings represented a significant breach of the rules designed to keep crime out of gambling.

Regulatory Settlement and Implications

As part of the regulatory settlement, William Hill has agreed to vary its licence to include additional conditions. These include appointing a Board-level sponsor to oversee a 12-month action plan and undertaking a follow-up independent audit of its AML and safer gambling policies by February 2024.

The UKGC noted that while William Hill had taken steps to remedy the breaches, the case involved serious failings and repeated issues similar to previous enforcement cases in the industry.

This action serves as a reminder to all operators of their legal duty to uphold the licensing objectives, which include protecting vulnerable people from harm and preventing gambling from being a source of crime.