Enhanced due diligence at All British Casino

[johnnymcc1966]

I don't really give a fuck.

Dunover? More like bendover. Fuck off niggerlover.

I was going to agree with your tone over casinos but anybody who resorts to racism when confronted over an argument which has absolutely nothing to do with that topic anyway is an absolute moron.

 

[pinnit2014]

A sensible casino wouldn’t. You shouldn’t rely on someone else having done the work for you. It’s still your responsibility if you rely on it, and the original checks turn out to have been insufficient, wrong or otherwise negligent.

Not entirely true in all contexts where you can essentially 'contract out' certain duties - true, you would still retain the legal duty and should things go wrong still be held accountable but, if you have formal agreements etc in place, you would have legal remedies available to you.

AML wise there are quite a few companies who specialise in such but some bodies, naturally, may not wish to go down that route.

IIRC correctly you can't blindly, with having specific arrangements in place which you monitor, just go ' the bank must have checked etc'

 

[shadow123]

Think it is high time UKGC published firm requirements of what casinos need to do instead of leaving them to interprate
the guidlines however they wish, usually to the detriment of players,
I would suggest

Fixed trigger points for SOW requests
List of all documents to be submitted
Actions to be taken if requested documents are not submitted.
Time limit for SOW investigations to be completed if all the specified documents have been submitted and are correct.
Ban holding withdrawals to ransom and allowing those funds to be further gambled.
Not allow deposits to be made during the SOW investigating period (may sound harsh but cant think of a better way of speeding things up)
All this is information to be incorporated into the Casino terms and conditions.

Might help but can never see it happening

 

[thr0b]

Not entirely true in all contexts where you can essentially 'contract out' certain duties - true, you would still retain the legal duty and should things go wrong still be held accountable but, if you have formal agreements etc in place, you would have legal remedies available to you.

AML wise there are quite a few companies who specialise in such but some bodies, naturally, may not wish to go down that route.

IIRC correctly you can't blindly, with having specific arrangements in place which you monitor, just go ' the bank must have checked etc'

Oh, yes, this is what I mean - you can’t assume the bank has done it, or that it was done in the way appropriate to your business, unless you contracted them to do it. (And even then, it’s still your fault if you contract it out, you rely on it and they mess up.)

If you really on the back having done it without any contract between you and the bank, you’ve not even attempted to do it.

 

[toms596]

Let’s play a quick game.

Customer from the UK registers via a Google paid for advert and loses £100. How much does the casino make?

I’m not going to break it down, but I’ll start you off with…

£21 goes to UK HMRC as tax.

£79 left.

Is this a reason why offers are so poor nowadays?

Apart from the 100% or 50% reload offers at Lottomart the free spins offered are usually quite bad. 10 spins at 10p or deposit £30 wager £100 and get £3 worth of spins

I remember being VIP at Casino Heroes years ago before they left the UK and being able to purchase 50 spins at £1 with the rubies they used to throw at me every Sunday

 

[pinnit2014]

Think it is high time UKGC published firm requirements of what casinos need to do instead of leaving them to interprate
the guidlines however they wish, usually to the detriment of players,
I would suggest

Fixed trigger points for SOW requests
List of all documents to be submitted
Actions to be taken if requested documents are not submitted.
Time limit for SOW investigations to be completed if all the specified documents have been submitted and are correct.
Ban holding withdrawals to ransom and allowing those funds to be further gambled.
Not allow deposits to be made during the SOW investigating period (may sound harsh but cant think of a better way of speeding things up)
All this is information to be incorporated into the Casino terms and conditions.

Might help but can never see it happening

There are quite a few supervisory bodies, for monitoring/enforcing compliance with AML of which UKGC is one (FCA, law Society, ACCA and many more) - wonder of those accountable to them have as many problems with their 'base' - i don't know the specific guidances they hand down or if better/worse than UKGC ones.

Someone with more knowledge than me will know but very surprised if they introduced SOW trigger points as, bar some areas in the EU Regulations, they make no mention of it. They also, whilst they may introduce clarity for players, have their own issues: possible if you did introduce them casino's, anti the legislation, wouldn't treat it as risk based etc.

Risk based monitoring has it's benefits - it allows flexibility but comes with the disadvantage of you open yourself to criticism if those above you don't like it and many businesses will not like the sometimes subjective nature of it. And it takes a lot of work in the background to maintain a real time view.

 

[pinnit2014]

Oh, yes, this is what I mean - you can’t assume the bank has done it, or that it was done in the way appropriate to your business, unless you contracted them to do it. (And even then, it’s still your fault if you contract it out, you rely on it and they mess up.)

If you really on the back having done it without any contract between you and the bank, you’ve not even attempted to do it.

Yeah, you can outsource the processes etc but the risk will stay with the business

Even then you'd need to show that you were effectively monitoring that relationship as well to make sure x,y,x were doing what they should be doing - i imagine that to being a complete ballache for a company and why some want it still kept in-house.

 

[shadow123]

Fine keeping it in house if they all sing from the same book, but no 2 casinos use the same procedures,and its
being totally misused in many cases.Surely it better to have standard statuory requirements applying to all casinos
which would protect them against fines and sanctions if they complied with them.The player would also know what to
expect when signing up to any casino.

 

[justdoit]

Fine keeping it in house if they all sing from the same book, but no 2 casinos use the same procedures,and its
being totally misused in many cases.Surely it better to have standard statuory requirements applying to all casinos
which would protect them against fines and sanctions if they complied with them.The player would also know what to
expect when signing up to any casino.

every casino they hold withdraw and let you deposit and play they know they braking UKGC rules, by waiting for sow 90% players they will get feed up go back play lose all balance and happy ending for casinos

 

[snorky510238]

The easiest way, would be to do SOW before you can play at a given Casino, wouldn’t it? We all know why that doesn’t happen though. Talk about making rules to suit the agenda.

 

[L&L-Jan]

not worth give any money to UKGC casinos any more is not only ALL British casino all same ? yesterday open new account first deposit £50, cashout £30 and they send me email with sow bs, Pokerstars I spend like £100 all month they send me email from safer gambling bs, WHG 4 years with them 21 casino, I deposit £200 last 2 weeks did 3 spins £10 in Big Bass Splash won £9k when bonus finish I was lock out and ban from casino for doing £10 a spin, my 90% playing in 21 casino was under £1 for 4 years and I was up all time WTF is wrong UKGC Casinos, looks like they pushing us to black market casinos

Although I play under MGA license, I had to do SOW at both Entain (party) and Flutter (PokerStars). It is not limited to UKGC. We do the same for Sweden (SGA) and same for Malta (MGA). As its an European law, it is not limited to the UKGC.

 

[justdoit]

Although I play under MGA license, I had to do SOW at both Entain (party) and Flutter (PokerStars). It is not limited to UKGC. We do the same for Sweden (SGA) and same for Malta (MGA). As its an European law, it is not limited to the UKGC.

can casinos do something about it, or just let UKGC kill all online casinos?
how long did you SOW take ?

 

[L&L-Jan]

The easiest way, would be to do SOW before you can play at a given Casino, wouldn’t it? We all know why that doesn’t happen though. Talk about making rules to suit the agenda.

I actually replied to such a comment today:

As for doing all the check upfront, this doesn't make sense. We do electronic verification during the onboarding, this will remove the requirement to KYC the account up to £1400 in deposits/withdrawals. When that treshold is reached, we require to do KYC. As we all know KYC is a simple process.

From there we have various financial tresholds in place, that when reached, SOW is required. This will never occur for the majority of the players. And with majority I really mean like 90%+ of the players.

That would mean we would have to increase our payments team like 10x in order to be able to verify those SOW documents. This while 90%+ of the players will never be subject to such verifications? Hence, casinos do it based on set financial tresholds and unfortunately for players, this differs per company.

I do understand your point, but just giving feedback from the casinos perspective.

 

[snorky510238]

That system is massively flawed though isn’t it? A player is then allowed to deposit until they hit the SOW trigger. Could be a couple of years for example.

When they send in the documents/bank statements, you find that they have funded their playing by either getting into debt or that they haven’t been gambling responsibly.

At that point, you close their account and wave goodbye but are not held responsible in any form. Has a Casino really done it’s due diligence in that scenario?

 

[Mr_Slot5]

From there we have various financial tresholds in place, that when reached, SOW is required. This will never occur for the majority of the players. And with majority I really mean like 90%+ of the players.

Pretty much what I’d expect…but why then do we see horror stories on here of low rollers depositing £20, hitting massive then getting a SOW from some casinos. That to me just smacks of the casino using delaying tactics. It can’t be affordability related as everyone can afford a withdrawal and it can’t be AML related as even the most hapless of criminals aren’t going to launder £20.

Or is it simply a case of a threshold being hit and the MLRO should step in to manually review the account, rather than being draconian and using a blanket approach?

 

[pinnit2014]

Is the SOW different from the EDD forms sent out? - I certainly wasn't in the top 10% of players at L and L and got asked for financial information (SOF/SOW declarations and associated evidence to support the amounts put down on the declaration - payslips/bank/property sale)

 

[L&L-Jan]

Pretty much what I’d expect…but why then do we see horror stories on here of low rollers depositing £20, hitting massive then getting a SOW from some casinos. That to me just smacks of the casino using delaying tactics. It can’t be affordability related as everyone can afford a withdrawal and it can’t be AML related as even the most hapless of criminals aren’t going to launder £20.

Or is it simply a case of a threshold being hit and the MLRO should step in to manually review the account, rather than being draconian and using a blanket approach?

I cant answer on those cases mate, because I dont run those operations.
On our end, that £20 deposit could have resulted in customer hitting thresholds for lifetime deposit sum.
Otherwise a £20 in deposit and £5k in withdrawal should not be subject to EDD imo, but more to just KYC.

 

[Vegasbum]

That system is massively flawed though isn’t it? A player is then allowed to deposit until they hit the SOW trigger. Could be a couple of years for example.

When they send in the documents/bank statements, you find that they have funded their playing by either getting into debt or that they haven’t been gambling responsibly.

At that point, you close their account and wave goodbye but are not held responsible in any form. Has a Casino really done it’s due diligence in that scenario?

Excellent post

 

[snorky510238]

Excellent post

Or of course, they may have been laundering money (appreciate the cases are probably minimal and they’re not likely to produce documents) but even so it still seems the wrong way to eliminate the possibility.