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Thread: Spinsvilla: excessive demands on basic deposits

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    Spinsvilla: excessive demands on basic deposits

    A complaint came to us where Spinsvilla (spinsvilla.co.uk) was denying a player's winnings on the grounds that they had not completed their wagering requirements. The player had taken no bonus so what "wagering requirements"? Turns out the casino has it in their Terms:
    If you opt for the No Bonus option, you will receive no bonus on your deposit, however, you will be required to wager your deposit amount (5x) before any winnings from your ... deposit can be withdrawn. This is necessary to comply with Anti Money Laundering regulations.
    Ok, player should have read the Terms, no doubt about that. But what "regulations" are they referring to? Never heard of such thing. For the sake of discussion let's abbreviate "Anti Money Laundering" to "AML".

    Turns out neither my contacts at EU-facing casinos, nor the guys in Malta know of any such AML "regulations".

    Next stop: the Isle of Man where the casino is supposedly registered. Through ThePogg we were able to get this response from the Gambling Supervision Commission, Isle Of Man:
    I can advise that there is no requirement for an operator to make such statements. The requirements to comply with AML etc are detailed on our website along with some guidance notes.

    The GSC is silent on turnover requirements and so operators are free to make their own commercial decisions in this regard.
    Since the casino is not reachable -- no email address given, Chat only available to registered members, online email submission form doesn't work -- I have no choice but to warn players here:

    Warning: Spinsvilla.co.uk is imposing excessive wagering requirements on player deposits where no bonuses are taken or involved. Furthermore the casino is almost certainly making false claims regarding "Anti Money Laundering regulations" since their jurisdiction has no such regulations and they make no reference to what body might be imposing such requirements. Players are advised to look elsewhere for their gaming services until the casino justifies the offending Terms, amends them to something more in line with accepted industry practice, or removes said Terms entirely.


    For the record some wagering requirement on flat deposits is perfectly reasonable, operators have costs after all. I'm told that 1x is typical. 5x is simply designed to entrap player's deposits and profit from the excessive wagering requirements, hence this Warning.
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    FWIW
    I'm told there are Accredited casinos that are doing something similar. I'm looking into it and will decide how to proceed. But I will say this: Accredited or not, 5x on a flat deposit is punitive and
    IMO
    unjustified.

    Since it seems this is likely to become a topic of some debate I've started a publicly accessible thread for further discussion: Spinsvilla Warning ...
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    Ok, the good folks at the MGA have pointed me to the "4th AML Directive" -- formally Directive (EU) 2015/849 Of The European Parliament And Of The Council Of 20 May 2015 -- which appears to be the guiding document for matters of this nature.

    Looking through that I find the following in Chapter 1, Section 1, Article 2:
    Member States [and thereby the operators they license] shall require that the total turnover of the financial activity does not exceed a threshold which must be sufficiently low.
    The Directive also allows operators to go beyond the basic threshold and apply more stringent procedures if they see fit:
    Article 5 : Member States [and thereby the operators they license] may adopt or retain in force stricter provisions in the field covered by this Directive to prevent money laundering and terrorist financing, within the limits of Union law.
    It should also be noted that the Directive gives operators the freedom to completely waive such procedures where they deem the case to be "low risk" insofar as money laundering goes.

    In other words the operators have a lot of latitude: everything from waiving turnover requirements completely to applying requirements beyond the basic threshold.

    It's important to keep in mind that the underlying goal of all of this is the detection, assessment and prevention of criminal money laundering and the financing of terrorist activity. Your average player deposit -- especially if they later withdraw back to the same source -- hardly qualifies as either and as such it's hard to imagine how punitive procedures as a matter of course are justified. And given that the casino using such punitive practices across the board will certainly profit from said practices I'd say that any attempt to justify should be seen for what it is: self-serving BS.

    And that takes us right back to the beginning
    IMO
    : 1x turnover is totally reasonable; 5x turnover (or worse) is not at all reasonable and is certainly not a "requirement" of AML guidelines.

    Vote with your wallets folks: if a casino is cramping your style insofar as minimum turnover of no-bonus deposits goes then tell them so, pull your money and find some place that is not padding its bottom line with what are essentially Terms-enforced losses.
    Last edited by maxd; 2nd March 2017 at 12:40 PM.
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    Quote Originally Posted by maxd View Post
    ...
    It's important to keep in mind that the underlying goal of all of this is the detection, assessment and prevention of criminal money laundering and the financing of terrorist activity. Your average player deposit -- especially if they later withdraw back to the same source -- hardly qualifies as either and as such it's hard to imagine how punitive procedures as a matter of course are justified. And given that the casino using such punitive practices across the board will certainly profit from said practices I'd say that any attempt to justify should be seen for what it is: self-serving BS.
    ...
    Excellent observation - and I concur with this 100%

    This is a great mission for the Meister Minions to document this. I will see how this can be done.
    “Too much of anything is bad, but too much good whiskey is barely enough.”

    ~Mark Twain

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