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[Halvor]

You really don't see the ethical side to this at all do you?

I do see the side of companies following the rules... But damned if you do damned if you dont.

And forgive me if I'm wrong now, but you used to moderate streamers?

 

[Mr_Slot5]

I do see the side of companies following the rules... But damned if you do damned if you dont.

And forgive me if I'm wrong now, but you used to moderate streamers?

I did but what has me moderating streamers got to do with anything?

 

[Halvor]

I did but what has me moderating streamers got to do with anything?

To bad playfords gone

 

[Slottery]

I'm sorry but you're trying to defend the indefensible.

People's withdrawals should not be held to ransom. Checks should be done on deposit and deposit only- otherwise the whole situation is 100% in favour of the casino.

If the casino is willing to accept the deposit in the first place, they should damn well be prepared to take the risk of paying out on it.

It's as black and white as that.

Don't wanna start to defence or accuse any parties about anything, but paying withdrawal or balance only after the verification is completed is not really falling to "ransom" category, even it can feel about it and it's cool statement to for defending player rights.

Wrote quite a lot about AML regulations, believe or not, it can be counted as tipping off if you refuse to accept suspicious (or customer you want to complete SOW) players deposit and trigger SOW request at same time.

Then most probably that you never hear from that person anymore, authorities can claim that by refusing to continue business with customer in request, it was too clear tipping off as AML request was sent right after. Would that feel any better to accept your deposit but not let to play with it at all to be automated action when people need to be verified?

Casinos risk that player happen to win, don't really have anything to do with AML regulations. If you play at casino who just for fun stop paying your withdrawals, i would recommend to change one which does. If not willing to comply with any AML regulations, then only can recommend not to play online at all as it's not guaranteed that you don't get that request sooner or later.

 

[Mr_Slot5]

Don't wanna start to defence or accuse any parties about anything, but paying withdrawal or balance only after the verification is completed is not really falling to "ransom" category, even it can feel about it and it's cool statement to for defending player rights.

All well and good but this isn't just about AML, it's happening for RG reasons too.

The two are being too readily conflated.

Whilst there are grounds for casinos to adhere to AML guidelines as you suggest, this should be case specific and discretionary (and there is discretion within the guidance as seen with different implementations at different casinos). AML checks should be really quite thin on the ground as I doubt too many players exhibit signs of fraud.

As for RG. if the checks are for RG issues the checks should have been done pre-deposit. There is NO reasonable excuse for a casino to hold a withdrawal in this scenario.

 

[CasinoNinja]

Yeah, you would just love to provide a SOW on registration right? What exactly do you think this would lead to except most players going to offshore/unlicensed casinos? Think before you post.

I wouldn't mind to be 100% that would be no problems when withdrawing.
I could easily send a payslip or similar on registration if I knew I would be spending money on the casino and wanted to make sure I would get paid with no problems.

 

[Slottery]

I know, it can happen and don't really say that there are no casinos who can use it in ways they souldn't, just making that automated block for deposit and AML SOW request after that, most probably wouldn't get green light from authorities.

I think i mentioned in some earlier post, that some operator(s) do pay out withdrawal and send request right after, WHEN player is low aml risk in their opinion. I think that's quite fair to do, but always also can't be done if you have some big amounts, anyting suspicious etc... so there always will be some cases, no matter what, where player get that request at withdrawal stage.

That's just something you can't fully eliminate. SOW also once it's requested, you are expected to apply also AML risk to player if your monitoring is risk based approach, even you would be worried that player only spending all his savings from own bank account, so you can't let it be only RG request even that would be your reason for it in a first place.

You just are obligated to complete your ongoing monitoring, if you fail some part of it, then you fail, so you can't just leave some part out from your risk assessment once completing it to player. For some RG failures you don't get much punished but when there's criminal activities like stolen money from employer etc... your sitting on much bigger pile of shite.

These all are individual like our bank accounts and finances are, so making one size fit all model is not that simple like in KYC. Implementing such a process to player monitoring which also fills all demands from all regulations would be worth of big bug, it really is not casinos interest to spend hours and hours to get some player verified, for sure paying withdrawals and have these things not existing would be easier for both.

I really still miss point in what is casinos benefit to have ongoing SOW for week or two and pay player only then... These times you don't even get a cent interest from two weeks doesn't matter how much money you have. If one gambling addict reverse withdrawal there and then (not happening for UK anymore so that thought that casinos only love stall withdrawal because of that is not applicable anymore), but they 99% sure lose player who is pissed off after lost back pending withdrawal during verification because had gambling problem and was stupid and reversed it (don't really have sympathy for people who reverse some really big withdrawals, lose them back and blame anyone else but only themselves), and maybe few other players who read persons sob story how casino forced him/her to losee £50k or what ever remarkable amount person in question decided to play with.

 

[Slottery]

I'm sure these are posted somewhere many times earlier, but if somebody have too much freetime in lockdown, i know that many casinos would be interested to specific plan for their ongoing monitoring which would be fast and efficient as possible, wouldn't take much man/woman power to do daily and wouldn't upset players that they leave because of their SOW is hard or next to impossible to complete (partly of stated fact that you are not really allowed to say much to player about process long as you have open questions).

UKGC:

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MGA:

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MGA one provider more hints and tips where to pay attention. If not getting great idea how to specs great monitoring process to some casino which covers all the aspects (and take an account things like RG as well), when something is triggered and why etc... Going these through even quickly (they are still very vague but you get some ideas which things at least casinos have to pay attention), could possibly clarify something from that area which could help once you get these letters everyone love to your email, SOW!

 

[brianmon]

Yeah, you would just love to provide a SOW on registration right? What exactly do you think this would lead to except most players going to offshore/unlicensed casinos? Think before you post.

Why would anyone need to go to an offshore/unlicensed casinos??
There are about 400 UKGC licensed casinos.
But that's not the point anyway. No one's suggested asking for a SOW on registration.
MrSlots said the SOW should be requested at the deposit stage, and not at withdrawal

 

[Guntis]

Yeah, SOW as part of the registration process would be a perfect option from a regulators point of view. But the casino's main goal is to make the registration as straightforward as possible; name, surname, email, confirm the email.
Casinos will avoid this as hard as they can or otherwise potential customers will simply leave and never come back.
That's the fact!

 

[Slottery]

Yeah, SOW as part of the registration process would be a perfect option from a regulators point of view. But the casino's main goal is to make the registration as straightforward as possible; name, surname, email, confirm the email.
Casinos will avoid this as hard as they can or otherwise customers will simply leave and never come back.
That's the fact!

But as SOW is not like KYC as you might end up requesting one again after little while, for one reason that your behavior don't fit to your profile and even it would fully fit, you can't really know that same person is in same job after few years, these days many things change quite often.

Requesting that in sign off, would let you play in peace probably as long you are allowed to play now before you get SOW request. And like stated in few posts, if SOW is something you can be prepared, it's not really doing it's purpose, but would make setting triggers for that particular player easy, just would need to demand some months bank statements and be more specific than one payslip as only based on that you don't know much of players finances.

Like these examples were in that UKGC vague guideline what around you are expected to know from your customer (recommend again to read at least that, it's really short and only take some minutes to read with thoughts), one highlighted as bolded to refer SOW in registration don't solve all problems.

• Are you confident you can evidence all of the information you rely on when assessing a customer’s risk?
• Is there over-reliance on checks made by third parties?
• Is your enhanced due diligence applied to customers on a risk-sensitive basis?
• Are customers’ source of funds and source of wealth adequately investigated?
• Do you know where customer money is coming from?
• How frequently are you asking questions about established customers?

 

[Sasukdcf]

Again I understand that it's frustrating. But please also understand that putting their accreditation into question and to use of the forum as a battering ram towards them seems a bit nasty.

I've not been a casino representative here for years, but the pressure really do not help or speed anything up.

It's just a few hours since you voiced your intentions to be patient.

Again I understand that it's frustrating. But please also understand that putting their accreditation into question and to use of the forum as a battering ram towards them seems a bit nasty.

I've not been a casino representative here for years, but the pressure really do not help or speed anything up.

To be fair I asked the question about accreditation and was given answers by
Members... I wasn’t demanding they be removed
I don’t think it’s right ( and still don’t ) that they can hold my money for the best part of a week so far having let me deposit 2k without any questions etc etc however that said It would appear that the GC incompetent as they are allow this and I have to wait the time, it doesn’t mean I have to be particularly happy about it....

So out of interest then... when does the point come that I would be entitled to become impatient

A week

2

A month

And also just to point out that my initial thread was not negative as I have pointed out it was fairly neutral... the system and process that’s been VERY protracted has caused the issues....

Being told I have to screen shot x

And then being told a screenshot is not acceptable for Y

Being told my accountants are wrong when they were not...

These are the parts that have caused the additional frustrations

 

[Sasukdcf]

But as SOW is not like KYC as you might end up requesting one again after little while, for one reason that your behavior don't fit to your profile and even it would fully fit, you can't really know that same person is in same job after few years, these days many things change quite often.

Requesting that in sign off, would let you play in peace probably as long you are allowed to play now before you get SOW request. And like stated in few posts, if SOW is something you can be prepared, it's not really doing it's purpose, but would make setting triggers for that particular player easy, just would need to demand some months bank statements and be more specific than one payslip as only based on that you don't know much of players finances.

Like these examples were in that UKGC vague guideline what around you are expected to know from your customer (recommend again to read at least that, it's really short and only take some minutes to read with thoughts), one highlighted as bolded to refer SOW in registration don't solve all problems.

What does it mean when it refers to customers risk!?

Risk of what ? Any ideas

 

[Halvor]

May I ask why you have gone from "I will wait for a few days" to the battering ram approach again within the same day?

 

[Slottery]

What does it mean when it refers to customers risk!?

Risk of what ? Any ideas

In that MGA doc posted earlier, is their quite simple guidelines in high level like:

The following is a list of possible red flags which licensees may wish to consider:
Customer does not cooperate in the carrying of CDD.
• Customer attempts to register more than one account with the same licensee.
• Customer deposits considerable amounts during a single session by means of multiple prepaid cards.
• Customer deposit funds well in excess of what is required to sustain his usual betting patterns.
• Customer makes small wagers even though he has significant amounts deposited, followed by a request to withdraw well in excess of any winnings.
• Customer makes frequent deposits and withdrawal requests without any reasonable explanation.
• Noticeable changes in the gaming patters of a customer, such as when the customer carries out transactions that are significantly larger in volume when compared to the transactions he normally carries out.
• Customer enquires about the possibility of moving funds between accounts belonging to the same gaming group. Page 31 of 37
• Customer carries out transactions which seem to be disproportionate to his wealth, known income or financial situation.
• Customer seeks to transfer funds to the account of another customer or to a bank account held in the name of a third party.
• Customer displays suspicious behaviour in playing games that are considered as high risk.

Divided to 4 main categories:

The risk areas that the business risk assessment as well as the customer-specific risk assessment are to look at can be divided into four:
• Customer risk;
• Product/service/transaction risk;
• Interface risk; and
• Geographical risk.

Then there page 21 is really basic chart how you should carry your risk assessment when player reach 2000€ threshold where already medium or high risk players SOW information should be requested.

In page 25 there are some guidelines for players inability to provide information, mentioning for example that funds should be paid to player unless there are some real legal grounds not to:

Where there are no grounds to suspect ML/FT or the transaction has not been suspended by the FIAU or by operation of the law, nor is there an attachment or freezing order, the licensee would have no reason rooted in the AML/CFT regime justifying the retention of any such funds. Thus, where funds are to be remitted back, the licensee should: a. Consider whether there is any other legal impediment to the remittance of the funds; and b. Remit the funds to the same source through the same channels used to receive the funds.

Even that doc is from MGA, it's explaining quite well many basics about monitoring and risk assessments. It's bit boring but going it through quickly and check only interesting parts probably could open process better than i. That basic guidance is 37 pages, there are so many different factors which could affect to risk assessment, including for example what you can find from person when you search all sources you have, just internet to be one and there are loads of different services in different countries who collect information about people to one place.

Don't really know how would explain my understanding very clear, you just use all possible information you are able to get and then try to think what possibly could be risks with this particular player.

 

[Sasukdcf]

Awesome ty...

There are a lot of factors there....

Only one I can see that I may flag is playing high risk games with more money than it would appear I could sustain...

That is, unless the fact I won £7k the other day was not taken into account !!!

You see if they directly asked the question I could send them the video of the win ! Maybe that would help?

 

[Sasukdcf]

May I ask why you have gone from "I will wait for a few days" to the battering ram approach again within the same day?

Battering ram?? Hardly

I’m not..: for one talking about it helps me stay calm and 2 I suppose being told I am going to receive an email requesting one more document and then not actually receiving said email indicating that it’s going to now be at least another 24 hours is a tad frustrating...

I have not contacted them on chat once today

Which is an improvement on the 10 times the previous day...

Spending time replying here is better than playing on my account while I have over £1000 sitting there which while I am still in n tilt range is not ideal... but other than locking my account which will mean i can’t access it to speak to them, I can’t withdraw or protect..

 

[Sasukdcf]

I have been reading this thread with interest, and felt obliged to register to query certain aspects of the regulations.

I understand the need for the gambling commission to be a little vague with the guidelines. It is case by case. They can't say "Any total deposits exceeding £4k must be subject to enhanced due diligence" Otherwise criminals, and even genuine players would go up to the limit and then stop or play elsewhere.

What I don't understand and don't think is fair is the whole thing seems to be a win-win for the casino:

1) Player is allowed to deposit say £3k, loses, maybe or maybe not receives an email asking for source of funds. Either way, the money has been lost and the casino probably doesn't really care where the money came from, and there is no chance they would ever refund the deposits.

2) Player is allowed to deposit say £3k, builds a balance of £10k, withdraws. Suddenly the money is held hostage due to these enhanced checks, despite the deposit being the same, and, more importantly, the deposit and gameplay having been already accepted.

To me there is a fair and simple solution - regulate at the point of deposit. If L+L think OP deposited too much then either:
1) The deposit(s) themselves should have been blocked
2) If 1) Is not possible due to what I have previously stated about avoiding specific AML deposit limits, gameplay should be immediately blocked until the player has proved the source of the money. If the player either fails this process or chooses not to do it, the casino can simply refund the deposit and everyone walks away happy-ish.

Any casino who accepts deposits and gameplay and only creates hurdles after a win in fact seems to me to be in breach of the Gambling Commission rules stated here:

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" A request made by a customer to withdraw funds from their account must not result in a requirement for additional information to be supplied as a condition of withdrawal if the licensee could have reasonably requested that information earlier. "

I am curious what the protocol here is - if OP decides enough is enough and doesn't send any more documents, and L+L do not accept the existing documents, do they keep all funds, refund the deposits, or refund the whole balance (and close the account whichever scenario I assume)? Is there any precedent on this?

There is a similar comment in the self-exclusion guidelines here:

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Once you have made a self-exclusion agreement, the gambling company must close your account and return any money in your account to you. It must also remove your name and details from any marketing databases it uses.

I wonder if OP can simply request a self exclusion in this case?

I would be interested to hear Jan's or any other rep's thoughts on some of these points. I have tried to raise what I feel are fair points and am not looking to bash on any casinos or reps.

Very good point that !!

But would anyone risk trying it to then find that you have then blocked yourself from communicating with them after this point...

I would assume that AML would trump self exclusion rule tho !! Interesting that it’s black and white written down tho that they mustn’t hold up a withdrawal... however it says “ if information could have been asked for earlier...

To be fair on that ( see I can be pragmatic ) this all happened quite fast as in I joined played and won in the same session so they didn’t really have chance to ask for much in that timeframe ( however they had enough to let me deposit loads !!?? )

 

[Mr_Slot5]

I have been reading this thread with interest, and felt obliged to register to query certain aspects of the regulations.

I understand the need for the gambling commission to be a little vague with the guidelines. It is case by case. They can't say "Any total deposits exceeding £4k must be subject to enhanced due diligence" Otherwise criminals, and even genuine players would go up to the limit and then stop or play elsewhere.

What I don't understand and don't think is fair is the whole thing seems to be a win-win for the casino:

1) Player is allowed to deposit say £3k, loses, maybe or maybe not receives an email asking for source of funds. Either way, the money has been lost and the casino probably doesn't really care where the money came from, and there is no chance they would ever refund the deposits.

2) Player is allowed to deposit say £3k, builds a balance of £10k, withdraws. Suddenly the money is held hostage due to these enhanced checks, despite the deposit being the same, and, more importantly, the deposit and gameplay having been already accepted.

To me there is a fair and simple solution - regulate at the point of deposit. If L+L think OP deposited too much then either:
1) The deposit(s) themselves should have been blocked
2) If 1) Is not possible due to what I have previously stated about avoiding specific AML deposit limits, gameplay should be immediately blocked until the player has proved the source of the money. If the player either fails this process or chooses not to do it, the casino can simply refund the deposit and everyone walks away happy-ish.

Any casino who accepts deposits and gameplay and only creates hurdles after a win in fact seems to me to be in breach of the Gambling Commission rules stated here:

You do not have permission to view link Log in or register now.

" A request made by a customer to withdraw funds from their account must not result in a requirement for additional information to be supplied as a condition of withdrawal if the licensee could have reasonably requested that information earlier. "

I am curious what the protocol here is - if OP decides enough is enough and doesn't send any more documents, and L+L do not accept the existing documents, do they keep all funds, refund the deposits, or refund the whole balance (and close the account whichever scenario I assume)? Is there any precedent on this?

There is a similar comment in the self-exclusion guidelines here:

You do not have permission to view link Log in or register now.

Once you have made a self-exclusion agreement, the gambling company must close your account and return any money in your account to you. It must also remove your name and details from any marketing databases it uses.

I wonder if OP can simply request a self exclusion in this case?

I would be interested to hear Jan's or any other rep's thoughts on some of these points. I have tried to raise what I feel are fair points and am not looking to bash on any casinos or reps.

Missed this post earlier. Excellently written.

This is exactly the way I see things. As you say, even if the casino accept the deposit, they can block gameplay. Much better (and fairer to the customer) than holding a withdraw to ransom.

As you say, the only winner on all fronts is the casino, if it's done any other way.

The parts you've put in italics are fundamental points too.

 

[colinsunderland]

Missed this thread growing last night, but can I just point out, sometimes doing these on withdrawal is justified, as the casino wouldn't see the suspicious gameplay until the request was made.

For example, someone deposits £1000 using paysafe. Puts 5 bets on roulette. Each one being £98 red. £98 black, £4 zero. Withdraws after the 5 bets. Withdraws to bank. That would be classic money laundering behavior and no way could it be picked up until the withdrawal was made.

I know that isn't the case here, nor in most cases, but there seems to be a myth that it should never be done on withdrawal.

I still don't care what casinos say. If the funds come from bank account A and return to bank account A, the the likely hood of money laundering is practically non existent. Banks have obligations under the same act as the casinos, and really the onus should be on them to do SOW requests on the original funds. It certainly isn't clean funds if it comes from A and is returned to A.

Casinos who allow withdrawals to different sources than deposits, Videoslots, Coral, Sky as a few examples, are making it easier for money laundering to take place, and are the ones who should be doing more in depth checks on customers.

 

[Sasukdcf]

Missed this thread growing last night, but can I just point out, sometimes doing these on withdrawal is justified, as the casino wouldn't see the suspicious gameplay until the request was made.

For example, someone deposits £1000 using paysafe. Puts 5 bets on roulette. Each one being £98 red. £98 black, £4 zero. Withdraws after the 5 bets. Withdraws to bank. That would be classic money laundering behavior and no way could it be picked up until the withdrawal was made.

I know that isn't the case here, nor in most cases, but there seems to be a myth that it should never be done on withdrawal.

I still don't care what casinos say. If the funds come from bank account A and return to bank account A, the the likely hood of money laundering is practically non existent. Banks have obligations under the same act as the casinos, and really the onus should be on them to do SOW requests on the original funds. It certainly isn't clean funds if it comes from A and is returned to A.

Casinos who allow withdrawals to different sources than deposits, Videoslots, Coral, Sky as a few examples, are making it easier for money laundering to take place, and are the ones who should be doing more in depth checks on customers.

Maybe that’s why this is flagged as I always use PayPal ...: now on PayPal you CAN ( I haven’t ) but can set up multiple banks and funding sources... so via PayPal going on what you have said you could “ clean money” and make it look like casino winnings using black and red as you have said..:

I however did my nuts on bonanza and got lucky on action bank of all games !!

 

[PMKFRUITPRO]

Sky won’t allow you to deposit on one source and withdraw to another unless the original deposit amount at least is then returned to the original source.

However in some circumstances support will remove a deposit method in order to allow this if they are happy you’re not a criminal!!

I got caught out on this a few times which did rather irritate me at the time but it’s understandable.

 

[pinnit2014]

Sky won’t allow you to deposit on one source and withdraw to another unless the original deposit amount at least is then returned to the original source.

However in some circumstances support will remove a deposit method in order to allow this if they are happy you’re not a criminal!!

I got caught out on this a few times which did rather irritate me at the time but it’s understandable.

I have two accounts on there; RBS that has Apple Pay enabled and Barclays. If I depo from RBS normally I can’t withdraw to Barclays but if I depo using Apple Pay (in this case funded by RBS), you can take back to whatever card you want etc

 

[colinsunderland]

That must have changed then since I was playing there as I could always choose my withdrawal method.

 

[Sasukdcf]

ok so latest update, i know you are all on the edge of your seats......

Jan messaged to say they would be requiring proof of how i funded my paypal

which they already had on 3 statements (2 from business accounts and the personal account showing that funds were recieved but hey ho.....

so i waited to recieve this request.... and didnt

so went on chat and they confirmed that this was required (again) although I hadnt been asked for it other than unnoffically via Jan....

now on barclays my statements run from the 11th of the month so it currently only shows transactions from april 12 to may 11 and they wanted to see where my deposits i made to them were shown ....

so i downloaded a PDF of transactions which went back to 5th May wierdly but showed all the deposits to L and L and the payment in from my business account...... sorted.......


nope they need the transactions to show back to the 01/05/2020.... a whole month before i even joined their bloody casino??????

so i then had to send them a statement from 12th april to 11th may to cover the first 5 days of May....

really cant see that they are entitled to request that.... but hey, they have it and have been told they will now require yet another 24 hours obviously, even though if they had sifted through the reams of information i have been asked to send them they already had all this amongst it!

this is whats so hard to accept and why i get arsey..... fair enough they want to see proof of where transactions came from and how funded but why do they have the right to demand to see stuff from a fulll month before i even joined them ???