That was actually why I asked. You are aware if you gather the information under an anti money laundering request you cannot use that information for ANY other purpose? Also, SOW under AML should only be requested if the customer is a high risk customer, so how can you lump them together? I actually don't agree with this, as personally, I don't see why you shouldn't be able to use the same documents for both, but the guidance is very clear.
What happens though if a customer actually refuses to supply the documents, rather than just doesn't respond within 72 hours? If you ask me for SOW I will refuse, all my income is affiliate income. All my agreements have confidentiality clauses in them, such as this one from you
16.1 all information, including but not limited to business and financial, lists of customers and buyers, as well as price and sales information and any information relating to products, records, operations, business plans, processes, product information, business know-how or logic, trade secrets, market opportunities and personal data of the Company shall be treated confidentially. Such information must not be used for own commercial or other purposes or divulged to any person or third party neither direct nor indirectly unless the prior explicit and written consent of the Company this provision shall survive the termination of this Agreement.
16.2 the Affiliate obliges himself not to use the confidential information for any purpose other than the performance of its obligations under this Agreement.
Clearly giving you a list of casinos I get paid from with amounts would be in breach of that, and I would not be comfortable giving you the information anyway.
What if a customer refuses to give you what you ask for under RG issues, will you immediately close his account and pay him any balance, and would it be treated as a self exclusion, or just an account closure?
Thanks for your time answering