William Hill Record Fine

William Hill Record £19.2 Million Fine For Widespread Failures

Apparently they knew it was coming, but even so, opening the post to see a fine for £19.2 million staring back at you has got take the wind out of your sails.

That’s what happened to William Hill this morning, who have now taken the crown from Entain as the bookie with the highest ever fine from the UK Gambling Commission.

It’s all thanks to license conditions failings between May of 2020 and October of 2021, and it could have been a lot worse too.

The UKGC were this close (i’m doing that thing with my thumb and index finger) to having their license suspended, and were only saved by the fact they acted quickly and are under new ownership.

There’s quite a lot to unpack here given Hill’s recent sale and re-sale, so let’s get into it.

What Have William Hill Been Fined For?

Long List

Social responsibility and anti money laundering failings are the problem, but the reason the fine is so big, is due to how widespread the problem was.

The list is incredibly long, and since the William Hill business is made up of several technically different businesses, it’s slightly complicated too.

The three elements of the overall William Hill business involved here, are WHG (International) Limited, which runs the William Hill website, Mr Green Limited which runs the Mr Green website that is owned by William Hill, and William Hill Organisation Limited which operates their high street premises.

The £19.2 million fine has been divided as follows:

Company Fine
WHG (International) Limited £12.5 Million
Mr Green Limited £3.7 Million
William Hill Organisation Limited £3 Million

We can see then that the worst of the failings fall at the door of WHG (International) Limited, or the William Hill online business in other words.

They have taken just over 65% of the fine, while Mr Green have to stump up a little over 19% and William Hill Organisation Ltd are responsible for the remaining 15.5% or so.

Getting more specific about what actually went wrong here, it may be easier to break it down by category.

Social Responsibility Failings

Social ResponsibilityThis concerns occasions when William Hill should have spotted potentially harmful gambling behaviour, such as sudden big spends or unusual betting behaviour, and stepped in to check the customer was able to afford it.

As you can see from the very long list below, that wasn’t happening:

  • Having insufficient controls in place to protect new customers, and to effectively consider high velocity spend and duration of play until the customer may have been exposed to the risk of substantial losses in a short period:
      1. One customer was allowed to open a new account and spend £23,000 in 20 minutes without any checks.
      2. Another customer was allowed to open an account and spend £18,000 in 24 hours without any checks.
      3. And a third customer was allowed to open a new account and spend £32,500 over two days without any checks. (Mr Green)
  • Failing to identify certain customers at risk of experiencing gambling related harm and failing to carry out checks at an early stage in the customer’s journey – one customer lost £14,902 in 70 minutes. (Mr Green)
  • Failing to identify risk of harm or intervene with certain customers earlier enough – one customer lost £54,252 in four weeks without the operator seeking income evidence, carrying out adequate checks, or using any other effective method to identify risk of harm. (WHG (International) Limited)
  • Having insufficient controls which exposed new or returning customers to the risk of substantial losses in a short period of time – one customer opened his account and lost £11,400 over the first 30 days without being subject to sufficient checks and another customer did not have a telephone interaction until losses reached £45,800. (WHG (International) Limited)
  • Failing to apply a 24-hour delay between receiving a request for an increase in a credit limit and granting it – one customer was allowed to immediately place a £100,000 bet when his credit limit had been set at £70,000. (WHG (International) Limited)
  • Ineffective controls allowed 331 customers to gamble with WHG (International) Limited despite having self-excluded with Mr Green. (WHG (International) Limited)
  • Failing to identify changes in the customer behaviour which should have provoked consideration of whether the customer was experiencing harm – a safer gambling interaction was conducted only after he had placed and had accepted an £18,000 bet (William Hill Organisation Ltd (WH Retail))
  • Having insufficient controls in place to protect new customers, and to effectively consider high velocity spend and duration of play until the customer may have been exposed to the risk of substantial losses in a short period:
      1. After its retail premise re-opened following the Covid pandemic lockdown, the operator allowed one customer to lose £10,600 in two days without a safer gambling interaction.
      2. Despite being unknown and staking £42,253 in 130 bets over a three-day period, staff did not identify one customer as being at risk of experiencing harms associated with gambling or undertake any customer interactions. (William Hill Organisation Ltd (WH Retail)

Soooooo yeah. Hard to defend yourself from that little lot I would imagine.

Anti Money Laundering Failings

Anti Money LaunderingThis is more to do with knowing who your customers are and ensuring that their money hasn’t come from the proceeds of crime.

  • Allowing customers to deposit large amounts without conducting appropriate checks – one customer was able to spend and lose £70,134 in a month, another to lose £38,000 in five weeks and another to lose £36,000 in four days. (WHG (International) Limited)
  • Allowing customers to deposit large amounts without conducting appropriate checks – one customer deposited £73,535 and lost £14,068 in four months (Mr Green)
  • Customers were able to stake large amounts of money without being monitored or scrutinised to a high enough standard – the operator failed to request Source of Funds (SoF) evidence when one customer staked £19,000 in a single bet, did not obtain documentation from a customer who staked £39,324 and lost £20,360 in 12 days, and did not obtain SoF evidence from a customer who staked £276,942 and lost £24,395 over two months. (William Hill Organisation Ltd (WH Retail))
  • Policies, procedures and controls lacked guidance on appropriate action to take following the results of customer profiling and how its findings should be used to establish the appropriate outcome. (WHG (International) Limited) and (Mr Green)
  • Procedures and controls lacked hard stops to prevent further spend and mitigate against money laundering risks before customer risk profiling is completed. (WHG (International) Limited) and (Mr Green)
  • AML staff training provided insufficient information on risks and how to manage them (WHG (International) Limited) and (Mr Green)

Again, quite the rap sheet.

Loss of License and Impact on 888

888 and William Hill Brands

If you don’t already know, online gambling company 888 bought William Hill’s European assets from Caesars in 2022, who had themselves bought the company a year earlier.

This means that poor old 888 are footing the bill for something they weren’t even responsible for, as they did not own William Hill at the time the offences took place.

A spokesperson for 888 has said:

“The settlement relates to the period when William Hill was under the previous ownership and management.”

“After William Hill was acquired, the company quickly addressed the identified issues with the implementation of a rigorous action plan.”

“The entire group shares the [Gambling Commission’s] commitment to improve compliance standards across the industry and we will continue to work collaboratively with the regulator and other stakeholders to achieve this.”

This may be true, but it wasn’t all that long ago that 888 got a fine of their own, and it was no small change.

This latest financial wallop will take their fine tally to £28.6 million in a 12 month period, which is a huge proportion of their annual profits, and it comes at a time when the company are heavily in debt and the outlook for the industry is uncertain.

888’s share price has plummeted in recent months, and it dropped another 11% or so after the news was announced.

However, it would have been much worse if Hill’s license had been suspended, because then they wouldn’t have been able to trade at all, and given that they have 1,344 shops to pay for on top of all the costs of their online business, that would have been devastating.

Ironically, it is their sale to 888 and the latter’s deft response to the issues that saved Hill’s from this fate.

Chief Executive of the Gambling Commission, Andrew Rhodes, said:

“When we launched this investigation the failings we uncovered were so widespread and alarming serious consideration was given to licence suspension,”

“However, because the operator immediately recognised their failings and worked with us to swiftly implement improvements, we instead opted for the largest enforcement payment in our history.”

Have 888 taken on too much for them to chew with William Hill, or will they steer the ship back to to land of good favour and reap the rewards in years to come?

Only time will tell.