Betat SoW Request - 1 casino less on my to play list

brianmon

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just a couple of cases of a UK bookie asking for SOW documentation before the recent changes :)
A student with 50k losses and a 40k balance in their account, and someone else with a 20k balance.
It isn't quite the same as the Malta based casinos, chasing players who deposit £20 a week
 

Harry_BKK

Dormant account
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Dec 18, 2014
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Balcony
How about we players lobby authorities to introduce mandatory SOWs for casinos, that any player can ask at any time? I am saying this in view of this case: Run of a lifetime , where the casino is clearly not capable of paying out a large win within an appropriate period of time. We are supposed to trust you guys that all is fine and dandy at your end, which in many cases it clearly isn't.

And the MGA and UKGC seals are supposed to give us peace of mind where this clearly shows that they don't mean a thing.

Who is checking the financial health of a casino operator? Most are a mesh of subsidiaries that makes it hard just to find out who is actually in charge let alone how well-funded a casino is. As mac72 indicated in the other thread, land based casino have to cover all their chips with cash, so we know exactly that they have the cash to pay out any possible win. We know nothing about the financial capabilities of online casinos.

@L&L-Jan I was hoping to get your view on my post.
 

homerbert

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Jun 21, 2012
Location
NoWhere
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 :D).

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.
 

homerbert

Dormant account
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Jun 21, 2012
Location
NoWhere
@Harry_BKK Hey mate.

Basically, any MGA casino should have like a 'starting capital' - not sure how it will be on english, lol. It means like you should have bankroll, but I can't comment on amount.

And more than this, at any given time, operator must have on their bank accounts which MGA have access to monitor or funds in transit (like on skrill / neteller accounts for example) amount of money, to cover ALL player balances.

And I guess the problem is that like today my player balances for example 100k EUR. I had 300k EUR at my accounts. All good, I'm okayish operator. But tomorrow one player won 1kk EUR. And suddenly I need 800k EUR more to be okay with MGA.

It's all I know, maybe Jan knows this field better.
 

Playford7

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just a couple of cases of a UK bookie asking for SOW documentation before the recent changes :)
For at least the past 10 years online I’ve had some very largeable deposits, also 4 plus figure withdrawal at WH, laddys also coral.
I’ve never once encountered any issue.
Granted my big wins are sports related, can see how that would matter though...
Started to edge away from Maltese companies of late. (No disrespect to the decent ones)
 

Mr Wild

Senior Member
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Mar 10, 2015
Location
Malta
The bigger a brand is, the higher risk appetite it can have due to average loss will probably be higher compared to a smaller brand and the normal player will has less friction on SOW checks.
One should point out that WH got a 7M fine for not checking SOW and several other brands has got a fine as well for not checking this.
 

colinsunderland

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A student with 50k losses and a 40k balance in their account, and someone else with a 20k balance.
It isn't quite the same as the Malta based casinos, chasing players who deposit £20 a week

No of course not and I wasn't suggesting that :) It was just to show that UK based bookies have been doing it longer than the Malta casinos have, as people seem to be under the impression they don't ever do it. It has been law in the UK for a lot longer than the last 12 months.

They do, however, seem to do it properly, ie when a customer is actually a high risk, rather than blanket emailing customers, or when they hit a deposit limit.
 

Playford7

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No of course not and I wasn't suggesting that :) It was just to show that UK based bookies have been doing it longer than the Malta casinos have, as people seem to be under the impression they don't ever do it. It has been law in the UK for a lot longer than the last 12 months.

They do, however, seem to do it properly, ie when a customer is actually a high risk, rather than blanket emailing customers, or when they hit a deposit limit.
Sensible approach and totally concur
 

colinsunderland

Experienced Member
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The bigger a brand is, the higher risk appetite it can have due to average loss will probably be higher compared to a smaller brand and the normal player will has less friction on SOW checks.
One should point out that WH got a 7M fine for not checking SOW and several other brands has got a fine as well for not checking this.

I would also point out that all of those fines were for cases where they should have been checked, unlike some casinos that blanket email customers, and do it on withdrawal etc. Someone depositing £20 a week, is NOT money laundering. They should maybe clamp down on casinos that 'could' facilitate money laundering by not processing withdrawals back to the source of funds.
 
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