Okay, since basically I'm had a lot of headache dealing with new MGA directives and understanding them, and since I was the one who implemented internal procedures for it, I think I will try to clarify some things for my meister friends, and maybe someone will find it useful. Please note, post is based on MGA documents and instructions/ recommendations / suggestions together with my own thoughts based on a hell lot of experience dealing with AML / Antifraud / customer verifications.
Also, please note, I can speak only in regards to Curacao / MGA authorities. I never worked with UK market and UKGC (and I'm personally OK and happy with that

).
So, when we speak about EDD and the things which in the most case customers hate, we should take into consideration two different but most important documents we must request from customers:
SOF (source of funds) /
SOW (source of wealth).
To clarify:
SOF - we want to see it when we are speaking about money laundering / fraud / etc - and want to see how funds deposited in casino appeared on your bank account / skrill / credit card/ etc.
SOW - It's a little bit different. It is also can be related to money laundering and fraud, but basically it is more about player protection and responsible gaming (like if you earn 2k / month, and gamble 2k / month - you obviously have a gambling problem and we must make some actions to help you).
So, EDD is required to help operator to:
- Prevent possible money laundering , terrorist financing , fraud.
- To protect customers from gambling problems, spending too much, losing the money he can not afford himself to lose.
And here we see already one huge problem - I'm pretty much sure in like 90% of cases when you get
SOW request - it will be more than enough to request SOF. It's much more easy for customer to make screenshot like 'I've topped up my skrill via my credit card, here is photo my this credit card, all good, it's me, I'm playing. This is about when we speak about ML/Fraud.
So what about player protection? Basically, with all my heart - I can't get how requesting SOW should protect customer...I request SOW from dunover for example, he thinking 'FU' and going in another casino. And another one. And another one. And another. And losing funds. Did I as responsible operator protected him from gaming problems? Well - no.
And here comes the MGA directives and rules, let's see from which customers we must request SOW / SOF.
Basically, MGA says that each operator must use scoring based risk system, which divide customers in different risk groups; for instance (low, medium, high). So customers who comes in High risk group - must pass via EDD including SOW / SOF.
How MGA thinks we must divide customers in groups. Well, it is based on:
- Customer country
- Customer used payment options
- Customer betting patterns
- Customer depositing patterns
I'm not really want to continue with it because basically each casino use their own system and divide customers as they think, but I believe it will give you some insights. Once you in high risk group - you have zero chances, you will be requested EDD.
As a final word, I can only repeat - IMO, SOW/SOF requests is good and gives operators guidelines how to prevent ML/Fraud/ etc. But when it is come to player protection from responsible gaming - I have serious doubts that SOW really help somehow. Much more better, imo, to contact such customers, remind them about your responsible gaming page, tell him that he can set deposit/wager/loss/session limits, he can contact special websites to get help. If operator really thinks that player is already have gambling problems - GO AHEAD AND SET HIS LIMITS YOURSELF. But do not make request of docs saying like 'okie, I did everything I could, hehe'.
So, to sum up, we see more and more SOW requests because:
- Some casino teams are simply follow what they was suggested by compliance team, without trying to think how is better to act with your customers.
- Some casino teams are really do not care - we have instruction - we request. Customers not happy - ah, it's not my problem, I get paid not for this.
- And most casinos I believe just covering themselves from any potential fines from MGA if they will have lack of player protection / AML.
Hope it helps someone, if you have any questions I'm happy to answer.