The UKGC last week issued a £6.2m fine to iGaming operator William Hill, citing “systemic senior management failure” in relation to both anti-money laundering and social responsibility regulations. Beyond the immediate financial penalty, a discussion has centered on the role of senior management – not just compliance professionals – in preventing such failures recurring.
Here, two iGaming compliance experts offer their take on what went wrong, and how to move forward:
MLRO – iGaming Operator
“The ‘Head in the Sand’ approach is Ultimately More Expensive, and More Destructive
It’s not clear whether in the William Hill case, infringements were perhaps being reported by the MLRO to company managers, who ignored them and failed to act. That’s not fully clear from the coverage I’ve seen.
There’s often a friction between the MRLO and a company’s commercial leaders. The MLRO’s role is usually independent, with AML legislation generally only requiring them to inform management, or provide reports. There’s often no legislatory requirement for them to get those reports approved or acted upon by management.
As an MLRO, personally, I’m passionate about the importance of knowing who your customer is. It’s not just about avoiding penalties like in the William Hill case. It’s really about good management, and forward-thinking leadership which understands that the “head in the sand” approach is ultimately likely to be more expensive, and even destructive to business.
Wendy Zitzman – iGaming Academy
“Systemic Failure Cannot be Addressed with a Legal Band-Aid”
There’s a vast number of new and updated legal requirements for iGaming operators. This month’s William Hill case is just one of many that proves not enough of this information is making its way to the top.
Senior management in many companies are often unaware of the extent of their legal and regulatory responsibilities. While it is the MLRO’s responsibility to keep them informed, there are clearly roadblocks to this communication. In many cases this comes down to due to the organizational structure or operating procedures: critical information simply isn’t making it to the top.
Operators’ typical response involves a flurry of consultation, new lawyers being hired and new contracts being drawn up. However, systemic failure cannot be addressed with a legal band-aid. Training, staff education and open knowledge sharing, allowing information flow throughout the company – and its decision-makers – is what is needed.