The UK Gambling Commission has sanctioned several dozen Personal Management Licence (PML) holders connected with Caesars Entertainment UK Limited for potential breaches of their licence conditions. Caesars operates 11 casinos in the UK. The responsibilities of PMLs are enumerated in section 1.2.1. of the Licence Conditions and Codes of Practice, which applies to most casino, gaming machine, gambling software and lottery managers’ licenses, and requires licensees to ensure that PMLs in their establishment hold a personal licence and be responsible for the overall management and direction of the business, the finance, regulatory compliance, marketing, information technology, and day to day site management. Seven of the investigated PML holders received license warnings, two received advice to conduct letters, and three PML holders surrendered their licences An additional 21 PML holders were affected by the investigation and sanctions.
The PML investigation followed an April 2020 decision by the Gambling Commission to impose a £13m fine on Caesars because of system failures in the organization’s decision making processes regarding VIP customers from 2016 to 2018. The Gambling Commission conducted an investigation in which it found money laundering failings such as inadequate source of funds checks for high stakes gamblers, politically exposed persons, and ostensibly low wage earners, and failure to conduct enhanced due diligence on customers whose activity warranted such scrutiny.
Caesars was also found to have failed to satisfy the social responsibility requirements of its license – in particular, by inadequate interaction with customers who were known to be problem gamblers or to be of insufficient means to support their gambling activities.
The April 2020 fine was accompanied by the dismissal of three senior managers. Caesars was also required to implement improvements in its anti-money laundering and social responsibility compliance. At that time, the Gambling Commission indicated that it would continue to investigate individual licence holders connected with the Caesars case.