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Guidance

LCCP Information requirements

Guidance for licence holders on the information requirements in the LCCP

  1. Contents
  2. 5 - Key events (relevant persons and positions)

5 - Key events (relevant persons and positions)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to relevant persons and positions within, or connected to, a gambling business.

It includes how to tell us:

  • if any person holds 3% or more of the company or holding company’s shares,

  • if your company takes out a loan from any person who is not authorised by the Financial Conduct Authority (opens in a new tab) (or a company in your group of companies takes out such a loan and then makes an equivalent loan to your company), and

  • if your company appoints a person to a ‘key position’, or a person leaves a key position, or a person leaves a key position to take up another.

Key Event 2: Shareholders or members holding issued share capital

Licence condition 15.2.1 (2)

Reporting key events - Relevant persons and positions

All operating licences

In the case of licensees who are companies or other bodies corporate having a share capital, the name and address of any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 3% or more of the issued share capital of the licensee or its holding company.

Your company must submit a key event report to us if any person holds 3% or more of the company or holding company’s shares, whether or not that person is already a shareholder or member.

You must do this within five working days of you finding out about the event.

For a detailed explanation of the meaning of ‘holding company’ refer to the Companies Act 2006 (Section 1159) (opens in a new tab). For ‘bodies corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab). This requirement includes companies which are incorporated outside of the United Kingdom.

When reporting this key event, you must include the following information:

  • The name of the shareholder.

  • The address of the shareholder.

  • The date of birth of the shareholder (if the shareholder is a person).

  • The company registration number of the shareholder (if it is a registered company in the United Kingdom).

  • The total amount and percentage of issued share capital the shareholder holds.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Notification of shareholders

This reporting requirement applies to holders of all operating licences.

Note, your company must either surrender its licence or apply for a new licence within five weeks of the change occurring if there is a change of corporate control (opens in a new tab) in your company. This is when any person (or other legal entity), directly or indirectly:

  • has acquired 10% or more of the issued share capital of the company,

  • is entitled to 10% or more of the rights to profits or dividends in the company,

  • has 10% or more of the voting power in the company, or

  • is able to exercise significant influence over the management of the company or holding company.

Key Event 3: Taking out loans from persons not authorised by the Financial Conduct Authority

Licence condition 15.2.1 (3)

Reporting key events - Relevant persons and positions

All operating licences

The taking of any loan by the licensee, or by a group company who then makes an equivalent loan to the licensee, from any person not authorised by the Financial Conduct Authority: a copy of the loan agreement must be supplied.

Your company must submit a key event report to us if it takes out a loan from any person who is not authorised by the Financial Conduct Authority (opens in a new tab), or a company in your group of companies takes out such a loan and then makes an equivalent loan to your company.

You must do this within five working days of you finding out about the event.

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. For a detailed explanation of these terms, refer to the Companies Act 2006 (Section 1159) (opens in a new tab).

Companies whose financial services activities are authorised by the Financial Conduct Authority are listed on the Financial Services Register (opens in a new tab).

When reporting this key event, you should include the following information:

  • The name of the lender.

  • Total amount of total loan.

  • The reason(s) for the loan.

  • The lender’s source of funds for the loan.

  • What due diligence checks your company has carried out on the lender.

  • If the loan involves crypto assets.

You must upload a signed copy of the loan agreement when reporting this event.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Loans non FCA

This reporting requirement applies to holders of all operating licences.

Key Event 4: Appointment of persons in key positions

Licence condition 15.2.1 (4)

Reporting key events - Relevant persons and positions

All operating licences

The appointment of a person to, or a person ceasing to occupy, a ‘key position’ (including leaving one position to take up another). A ‘key position’ in relation to a licensee is:

  • in the case of a small-scale operator, a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006.

  • in the case of an operator which is not a small-scale operator, a ‘specified management office’ as set out in (current) LCCP Licence condition 1.2.

  • a position where the holder of which has overall responsibility for the licensee’s anti-money laundering and / or counter terrorist financing compliance and / or the reporting of known or suspected money laundering or terrorist financing activity.

  • any other position for the time being designated by the Commission as a ‘key position’.

General

Your company must submit a key event report to us if it appoints a person to a ‘key position’, or a person leaves a key position, or a person leaves a key position to take up another.

For small-scale operators (opens in a new tab), a key position is a person occupying a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 (opens in a new tab).

For other gambling operators, a key position is any of the following:

  • A ‘specified management office’, as described in LCCP Licence condition 1.2 (opens in a new tab).

  • A position held by a person who has primary responsibility for making sure you meet requirements relating to preventing money laundering and the funding of terrorism, and for reporting known or suspected money laundering or funding of terrorism.

  • Any other position we designate as a ‘key position’ at any time. We will normally do this by attaching an extra condition to a company’s operating licence.

You must do this within five working days of you finding out about the event.

Reporting a person who has taken up a key position

If you are reporting a person who has taken up a key position, you should include the following information:

  • The person’s name, address and date of birth.

  • The role the person is appointed to and the date of their appointment.

  • A summary of their role and primary responsibilities.

  • If the key position requires a personal management licence.

  • If the person holds a personal management licence, or has previously sent us an Annex A personal declaration (opens in a new tab).

  • If the person does not hold a personal management licence, or has not previously sent us an Annex A personal declaration (opens in a new tab), but requires one for their new position. In which case, tell us when they intend to apply for a licence or submit an Annex A. Include details of who is covering the position until we have processed the application.

  • If your company will be applying for an amendment to its licence (see note below if you are a small-scale operator).

Reporting a person who has left a key position

If you are reporting a person who has left a key position, you should include the following information:

  • The person’s name, address and date of birth.

  • The role the person has stopped occupying and the date they left it.

  • If the company intends to replace that person and when. If a replacement is not being made, tell us who will cover that person’s responsibilities.

  • The arrangements the company has made to cover that person’s position until a replacement is recruited.

  • If your company needs to apply for an amendment to your licence (see note below if you are a small-scale operator).

  • If the person has taken up a new key position (and the name of the new position).

Changes to persons in key anti-money laundering and counter-terrorist financing positions

For changes of persons in key positions relating to anti-money laundering and / or counter terrorist financing, in non-remote casinos, you must also upload documentary evidence of compliance with our guidance on The prevention of money laundering and combating the financing of terrorism (opens in a new tab) (Paragraphs 5.2 and 5.12). For other licensees, evidence of compliance with our advice on Duties and responsibilities under the Proceeds of Crime Act 2002 (opens in a new tab) (Paragraphs 20.7 and 20.15) must be provided.

Changes to persons in other designation key positions

We may have designated any other position as key for a licensee either through a condition attached to the operating licence or by letter to the licensee. If a person is appointed to this position or ceases to occupy this position, provide the same information as set out in the above section on reporting changes to persons in key positions.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select one of the following types when entering this key event on eServices:

Key Event: Key position – AML/TF__ (for changes to persons with primary responsibility for anti-money laundering and preventing terrorist financing)

Key Event: Key position – manage't office__ (for changes to persons in a specified management office)

Key Event: Key position – GC designated__ (for change to persons in any key position we designate as a ‘key position)

Key Event: Key position – SSO__ (for changes to a person occupying a qualifying position in a Small-Scale Operator)

This reporting requirement applies to holders of all operating licences.

Note, if you are a small-scale operator reporting any of these events, you must also submit an application to vary your company’s existing operating licence, to update Schedule X (opens in a new tab) of the licence.

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Key events (operator status)
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Key events (financial events)
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