Rizk Source of Wealth Bullshit!

[goatwack]

Yea sure the UKGC require casino's to carry out this proceedure...but let's not let that get the Casino's who ask for SoW off the hook.

The whole point of SoW is to prevent money laundering & criminal proceeds being funnelled and should only be carried out when and only when ML is suspected. Casino's are carrying out this SoW on a whim.

If this SoW was asked of me I would be completely insulted and close my account as it insinuates by default that the casino do not trust where my money came from and think it may be from illegal activities on my part.

The casino are not obligated to ask for SoW documents unless ML is suspected and that's what is pissing players off.

I am certain Rizk know fine well...they don't need any finer instructions. Just another method for them to delay pay and inconvenience the player. Been there with Documents at nearly all the MT sites; they do love a good old wind up that lot.

Is it AML or Responsible Gambling? The fusion is there for all to see.....

 

[Chipkin9]

Is it AML or Responsible Gambling? The fusion is there for all to see.....

It's AML...that was the whole purpose of SoW in the first place. Absolutely nothing to do with RG.

 

[goatwack]

It's AML...that was the whole purpose of SoW in the first place. Absolutely nothing to do with RG.

So why the fines dished out everywhere by the UKGC? Casinos are reacting by wanting to avoid 'problem gamblers' frequenting their site. And save themselves millions in the process

AML is a piss- poor excuse to instigate these procedures. Along with funding terrorism

 

[Chipkin9]

So why the fines dished out everywhere by the UKGC? Casinos are reacting by wanting to avoid 'problem gamblers' frequenting their site. And save themselves millions in the process

AML is a piss- poor excuse to instigate these procedures. Along with funding terrorism

I dunno mate

I'm not going to pretend to be clued up on the whole thing, but perhaps the fines are for not complying with carrying out SoW as part of AML? And casino's are probably using "Problem Gamblers" as cover. This way people won't be offended by being accused of having dirty money.

At the end of the day the hands may be different but the game is the same; the UK government want to know absolutely everything about you and your online activites and this is just another measure and another industry to track what you do online and where your money comes from. That in itself tells you it is in fact to do with AML and not RG.

We all know British politicians do not like British citizens having offshore accounts, unless it's thier own

 

[mack341]

I didn't know much about the UKGC other than hearing their name in passing, but i found it a bit odd that the commission's chair[man] bill moyes, no relation to david i guess, is also chaiman of the general dental council. He seems to really want to get his and the ukgc's teeth into these issues.

 

[Deeplay]

Right now its getting messy just heard back from Rizk

Thank you for your documents.


Unfortunately the documents provided are not sufficient to show your source of wealth as it doesn’t show how the funds are generated or where it comes from, we can also not see how much you actually earn from these images.


When filling out the source of wealth questionnaire on site you stated that your annual income is £xx / £xxx and your screenshot showing transactions in 2017 is stating £xxxK.


We kindly ask that you supply additional documents which can support what was stated by you in the questionnaire, how your income is generated and where it comes from.


They are really messing up they state my income i showed them was higher than I said on the form!!

I imput income in GBP not USD which is what my income comes from as all my transactions are in USD

Im not prepared to offer any further information and they could not even differentiate between $ and £

so im stuck they are holding my money, refusing to pay

so be warned if you get this from Rizk be prepared for a very messy situation.


Im not sure what my next step is but right im 100s out of pocket.

Captain Rizk any answers to this ?

 

[Deeplay]

Note where they say ::: and your screenshot showing transactions in 2017 is stating £xxxK.

Below is a copy of one screen shot i provided I blanked out the figures and notice it clearly shows my income is in USD DOLLARS NOT gpb

so they are not even reading the document correctly! the conversion from USD into British Pounds will always mean you end up with less POUNDS than Dollars
simply fact

so if i say I earn £100 pounds per year through USD purchases it would mean right now I would have earned approv $135

it is a real worry they did not even take the time to read the document properly

IM not giving any further infromation and will be taking this further if there is no resolution.

see screen shot of one I sent them

Old Attachment (Invalid)

Right now its getting messy just heard back from Rizk

Thank you for your documents.


Unfortunately the documents provided are not sufficient to show your source of wealth as it doesn’t show how the funds are generated or where it comes from, we can also not see how much you actually earn from these images.


When filling out the source of wealth questionnaire on site you stated that your annual income is £xx / £xxx and your screenshot showing transactions in 2017 is stating £xxxK.


We kindly ask that you supply additional documents which can support what was stated by you in the questionnaire, how your income is generated and where it comes from.


They are really messing up they state my income i showed them was higher than I said on the form!!

I imput income in GBP not USD which is what my income comes from as all my transactions are in USD

Im not prepared to offer any further information and they could not even differentiate between $ and £

so im stuck they are holding my money, refusing to pay

so be warned if you get this from Rizk be prepared for a very messy situation.


Im not sure what my next step is but right im 100s out of pocket.

Captain Rizk any answers to this ?

 

[Deeplay]

sorry here is the screen shot that they did not even read properly

 

[Deeplay]

and this point they ask

" We kindly ask that you supply additional documents which can support what was stated by you in the questionnaire, how your income is generated and where it comes from. "

well sorry where i earn my money is none of your business at all. And im not giving my client information out which I would need to do if I was to comply with this ridiculous request!

 

[amourgirl]

It does raise eyebrows that these checks are being only done on withdrawal rather than deposit.

Quite! although casinos tend to do the same with the ID request. They allow you to deposit several times, but suddenly freeze your withdrawal until you verify your ID. Always seemed a bit of a daft way round to me. Personally, I now have made it part of my signing up procedure. I send in all my ID docs when I make my first deposit. I get peace of mind knowing it is done and there will be no delays.

 

[Deeplay]

Im starting to feel like they view as me as some kind of criminal and i dont like it one bit. Soon as this shite situation is sorted they can close my account. I dont need this bullshit.

Be warned dont deposit too much or win too much at Rizk right now as they will be straight onto your back.

 

[amourgirl]

and this point they ask

" We kindly ask that you supply additional documents which can support what was stated by you in the questionnaire, how your income is generated and where it comes from. "

well sorry where i earn my money is none of your business at all. And im not giving my client information out which I would need to do if I was to comply with this ridiculous request!

I think what they mean is if you are a seller on ebay for example, then evidence of this?

 

[bigbear]

Well Captain Rizk said here

Your Input Please - Rizk Casino answers submitted players' questions here!!

Yes after 72 hours all funds will be returned to their originator unless there is suspicious activity on the account in which case they are reported to the relevant authorities as they are now.

which was a response to

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?

Are you saying they allowed you deposit AFTER you refused to supply any more documents?

Have they said if it's RG or AML they are asking for?

The issue here is that there is no standard,across the board procedure.If the UKGC require source of wealth documentation then every casino licensed by therm should all be asking for the relevant documentation.I have made withdrawals at three UKGC licensed casinos over the past few weeks and they have all been paid promptly without any requests for SoW documents.So why are some casinos acting differently to others?

 

[Deeplay]

I think what they mean is if you are a seller on ebay for example, then evidence of this?

im not a seller on ebay but what i do is no ones business!

And the major failing here is they could not even read the document correctly which clearly states my income is genreated in USD not pounds - at source then it gets converted into GBP

and that is a grave error on there part that they could not even read the information given which leads one to ask where else are they making errors on such a serious issue.

I pay my taxes, I pay my bills and yes i make my own own money and use paypal as my billing agent who already have done a stack of checks to verify my business account, as they do with all ppal business accounts.

standard stuff. But thats not the point ...

5 more days from now they will shut of my account.

 

[aceking123]

i feel for you deeplay , im in same boat being self employed, bottom line is even if i wanted too , i cannot supply some clients things ^ where it has come from , so i just left the accounts closed & they shall remain closed , although im not gambling online any longer due to this kind of thing & a few other things.

 

[amourgirl]

5 more days from now they will shut of my account.

I know it's hard, but just be patient and try not to get annoyed (Yet anyway)
The Captain has said that he would read through this thread later on today and he will get in touch with you for more information.
Just have a chat with the him & hopefully between the two of you, you can come to some sort of resolution.

Hey guys, i will go through the whole thread in detail later today as I am travelling. I am getting more detail from Deeplay and will look into it

 

[Chipkin9]

I know it's hard, but just be patient and try not to get annoyed (Yet anyway)
The Captain has said that he would read through this thread later on today and he will get in touch with you for more information.
Just have a chat with the him & hopefully between the two of you, you can come to some sort of resolution.

But it shouldn't have come to the point where he had to contact a rep on an internet forum. What if he was someone who didn't even think to search for a forum like this? He'd be up shit creek! And I guarantee you there are people on the same boat with nowhere to turn and being refused winnings indefinitely.

Having a rep here doesn't get Rizk off. And they can spin it as the UKGC's fault all they like or misinterpretation. But that's not true (Misinterpretation part).

They know SoW should only be carried out if they suspect money laundering in accordance with AML.

 

[Deeplay]

Heard from Rizks rep he needs more to go on to try help but im not divulging my clients private information and they are many clients so its a stale mate

they want all information that i can not and am not allowed to divulge as per the contract that i have with the network I operate on. a totally mad situation

Im starting to think i will loose my withdraw and they will withhold deposits.

this is not a bash at the Rizk rep he is trying to help but i wont supply further private information and certainly not through email!

 

[Deeplay]

And now Rizk have suspended my account and are withholding all my funds they are in effect holding me to ransom



"Please be advised that your account has been temporarily suspended as you have stated that you will not provide any further information. We will require that sufficient supporting documents are provided in order to reopen your account.


You can read more about our regulatory requirements in the link below"

 

[Borgie]

Head from Rizks rep he needs more to go on to try help but im not divulging my clients private information and they are many clients so its a stale mate

they want all information that i can not and am not allowed to divulge as per the contract that i have with the network I operate on. a totally mad situation

Im starting to think i will loose my withdraw and they will withhold deposits.

this is not a bash at the Rizk rep he is trying to help but i wont supply further private information and certainly not through email!

I can't believe that they can keep your deposits as well as winnings ?

 

[Deeplay]

Fact if I divulge my income source which is the public then I breach the terms and conditions of the network I am contracted to online I wont do that and risk loosing my job

so rizk casino now are holding both all my deposits and my withdraws. they have me by the bollocks on this one. But i wont put my income at risk for this and im furious they are doing this and in such an unproffesional manner all through email!

 

[colinsunderland]

And now Rizk have suspended my account and are withholding all my funds they are in effect holding me to ransom



"Please be advised that your account has been temporarily suspended as you have stated that you will not provide any further information. We will require that sufficient supporting documents are provided in order to reopen your account.


You can read more about our regulatory requirements in the link below"

They can't just not pay you. Ask them if they have sent the details to any law enforcement agency, if not, why not, and you require your withdrawal to be processed immediately or you will start legal action, alongside complaints to the UKGC. You would also be within your rights to do a chargeback as part of what you paid for is the ability to withdraw any winnings .
If they have sent the details elsewhere, then you will have to wait until they get a response . I will be extremely surprised if they have though.

 

[Slottery]

For sure this case sucks and it should be (Captain said something in this chain that they will have new SOW process which prevent you all transactions once it's triggered, which sounds much more fair)... UKGC should really support more casinos in these regulations, instead of just throwing new ruling in place without proper instructions how to proceed with these and that casinos could have all same process in place (i remember when KYC process came and it was bit similar shite but this is ofc bit more sensitive area of personal information.

Fully understand OP and other affected fellow members frustration, but also that when you read these UKGC news, like that WHG, LeoVegas etc... they are much better in giving sanctions than cooperate with operators about how to do these in practice, therefore understand that no operator don't want even 500k fine for failing SOW/RG checks. If you have private business and state that it's not their business to know where you earn your money, it's pretty wrong view based on UKGC penalty policy, that is exactly what they need to know, how otherwise they could guess if there is something dodgy or gambling addictions behind of player.

Also, it's not only AML but RG as well, as you have seen UKGC penalties, many of them have social responsibility as one failure, so if somebody start to deposit and play with level which is alarming and triggering some limit (guess different operators have different once as no clear ruling from UKGC which would help operators a lot), they also need to know that you can afford it, in that WHG example was 2(?) players who were let to deposit large amounts where incomes didn't cover even near, so it's not fully true that SOW will be requested only for AML purposes and can't be used for RG purposes, but operator taking care of their social responsibilities.

You could see from Captains post that operator is not still fully aware about whole process and they are looking to put proper process in place, Captain usually explain things quite clear and honestly (like now admitted that he really don't know that part between affiliate TCs and SOW), i can imagine that most of operators are struggling with these rulings atm and GIG as not really small operator might have bit bigger resources to compete with these than some smaller ones. Pretty sure that everybody will see their money, or if not, there is really strong evidence about ML, they are just left in dark by UKGC who demand a lot and give very little assist but afterwards when you can read another story about hugely fined operator. This is just something we can't get away and for sure will be implemented by MGA as well at some point.

 

[Deeplay]

I can't believe that they can keep your deposits as well as winnings ?

Well sadly thats how it is now looking. They are basically telling me if I do not divulge all my private information they keep the lot. and im locked out now of my account. I have no idea who has seen the documents i have sent so far which do show private information and they are basically telling me to TTTH .

This is not aimed at Captain Rizk nice chap who I met the other year person at the CM meet.

Anyway I really hope no one else faces this as you will not get your withdraws it seems unless you provide very sensitive personal and private information. And remember they request this to be sent via email , which is not secure in any way.

 

[ternur]

They know SoW should only be carried out if they suspect money laundering in accordance with AML.

^^ That's actually incorrect. The UKGC expects licensees to know where their clients' funds originate. So the SOW request can be used for both AML and RG purposes. In fact, me thinks it's probably used mainly for RG purposes atm. It's part of the licensing conditions and one that the UKGC seems to keep an eye on.

 

[Deeplay]

They can't just not pay you. Ask them if they have sent the details to any law enforcement agency, if not, why not, and you require your withdrawal to be processed immediately or you will start legal action, alongside complaints to the UKGC. You would also be within your rights to do a chargeback as part of what you paid for is the ability to withdraw any winnings .
If they have sent the details elsewhere, then you will have to wait until they get a response . I will be extremely surprised if they have though.

Well I know i am 100% legit! even though they are making me feel like some kind of criminal now. Let them escalate it i will even give them the tel number of the Police station in my city lol ...

I dont want to do any of the above i just want it sorted and if not then I suppose I would have no choice but to take further action.

 

[colinsunderland]

For sure this case sucks and it should be (Captain said something in this chain that they will have new SOW process which prevent you all transactions once it's triggered, which sounds much more fair)... UKGC should really support more casinos in these regulations, instead of just throwing new ruling in place without proper instructions how to proceed with these and that casinos could have all same process in place (i remember when KYC process came and it was bit similar shite but this is ofc bit more sensitive area of personal information.

Fully understand OP and other affected fellow members frustration, but also that when you read these UKGC news, like that WHG, LeoVegas etc... they are much better in giving sanctions than cooperate with operators about how to do these in practice, therefore understand that no operator don't want even 500k fine for failing SOW/RG checks. If you have private business and state that it's not their business to know where you earn your money, it's pretty wrong view based on UKGC penalty policy, that is exactly what they need to know, how otherwise they could guess if there is something dodgy or gambling addictions behind of player.

Also, it's not only AML but RG as well, as you have seen UKGC penalties, many of them have social responsibility as one failure, so if somebody start to deposit and play with level which is alarming and triggering some limit (guess different operators have different once as no clear ruling from UKGC which would help operators a lot), they also need to know that you can afford it, in that WHG example was 2(?) players who were let to deposit large amounts where incomes didn't cover even near, so it's not fully true that SOW will be requested only for AML purposes and can't be used for RG purposes, but operator taking care of their social responsibilities.

You could see from Captains post that operator is not still fully aware about whole process and they are looking to put proper process in place, Captain usually explain things quite clear and honestly (like now admitted that he really don't know that part between affiliate TCs and SOW), i can imagine that most of operators are struggling with these rulings atm and GIG as not really small operator might have bit bigger resources to compete with these than some smaller ones. Pretty sure that everybody will see their money, or if not, there is really strong evidence about ML, they are just left in dark by UKGC who demand a lot and give very little assist but afterwards when you can read another story about hugely fined operator. This is just something we can't get away and for sure will be implemented by MGA as well at some point.

If the details are requested under the AML regulations, it's very clear from the UKGC guidelines they cannot use it for RG, or any other purpose.

 

[colinsunderland]

Well I know i am 100% legit! even though they are making me feel like some kind of criminal now. Let them escalate it i will even give them the tel number of the Police station in my city lol ...

I dont want to do any of the above i just want it sorted and if not then I suppose I would have no choice but to take further action.

My understanding is, they can only hold your money while an investigation is ongoing therefore if your details haven't been passed to law enforcement they can't hold it.

 

[Chipkin9]

The Money Laundering Regulations

1.27 The Regulations (8) represent the UK's response to the EU Directive and implement the law in the UK on this topic. They set requirements for the AML/CTFregime within the regulated sector (which includes casinos).

1.28 The Regulations apply to non-remote and remote casinos, licensed by the Commission, who act in the course of business carried on by them in the UK. This includes remote casinos which either:
• have at least one piece of remote gambling equipment situated in Great Britain, or
• do not have remote gambling equipment situated in Great Britain, but the gambling facilities provided by remote casino are used in Great Britain. (9)

1.29 The Regulations impose additional requirements on the regulated sector. These include risk assessments and requirements in respect of written policies, procedures and controls, internal controls, CDD, record keeping and training.

1.30 This guidance sets out how casino operators must and can comply with the law governing money laundering and terrorist financing. The law places responsibilities on theCommission as the supervisory authority for casinos. The Commission should produce guidance that helps casino operators to meet the requirements of the law, and is workable in the remote and non-remote casino environments and is approved by HM Treasury. Thisguidance, therefore, covers the full requirements of the UK law as it affects casinos.


The role of gambling operators

1.31 Operators have a responsibility to uphold the three licensing objectives set out in the Gambling Act 2005 (the Act). The first of those licensing objectives is to prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime.

1.32 As described in the preceding paragraphs, money laundering in the gambling sector takes two main forms:
•Exchanging money, assets, goods and property that were acquired criminally for money or assets that appear to be legitimate or 'clean' (so called classic money laundering). This is frequently achieved by transferring or passing the funds through some form of legitimate business transaction or structure.
•Theuse of criminal proceeds to fund gambling as a leisure activity (so called criminal or 'lifestyle'spend).

1.33 In order to avoid committing offences under POCA, operators should report instances of known or suspected money laundering or terrorist financing by customers to the National Crime Agency (the NCA) and, where a defence (appropriate consent) is requested, wait for such defence (consent) to deal with a transaction or an arrangement involving the customer, or wait until a set period has elapsed before proceeding.

1.34 Operators should be aware that there is no minimum financial threshold for the management and reporting of known or suspected money laundering or terrorist financing activity.


The role of the Gambling Commission

1.35 The Commission requires operators to prevent gambling being a source of crime or disorder, being associated with crime or disorder or being used to support crime. This guidance document is an important frame of reference to help casino operators meet that objective. Whilst potential breaches of POCA and the Terrorism Act will normally be reported to the NCA and fall to the police to investigate, the Commission, in its role as the gambling regulator, seeks assurance that risks to the licensing objectives posed by money laundering activity and terrorist financing are effectively managed, and this guidance will assist casino operators to meet their obligations under POCA , the Regulations and the Terrorism Act, where appropriate.

1.36 Under the Regulations (10), the Commission is designated as the supervisory authority for casinos. The Regulations (11) stipulate that a supervisory authority must:
• effectively monitor the relevant persons for which it is the supervisory authority and take necessary measures for the purpose of securing compliance by such persons with the requirements of the Regulations
• adopt a risk-based approach to the exercise of its supervisory functions, having identified and assessed the risks of money laundering and terrorist financing to which the relevant persons for which it is the supervisory authority are subject
• ensure that its employees and officers have access to relevant information on the risks of money laundering and terrorist financing which affect its sector
• base the frequency and intensity of its on-site and off-site supervision on the risk profiles it has prepared
• keep a record in writing of the actions it has taken in the course of its supervision and of its reasons for deciding not to act in a particular case
• take effective measures to encourage its sector to report breaches of the provisions of the Regulations to it.

1.37 In accordance with its risk-based approach, the supervisory authority must take appropriate measures to review:
• the risk assessments carried out by relevant persons to identify and assess the risks of money laundering and terrorist financing to which the business is subject
• the adequacy of the policies, procedures and controls adopted by the relevant persons and the way that those policies, procedures and controls have been implemented (12).

1.38 The Commission therefore adopts a risk-based approach to its role as supervisory authority. We focus our attention on circumstances where the processing of criminal funds or criminal spend indicates serious failures in an operator’s arrangements for the management of risk and compliance with POCA, the Regulationsand the Terrorism Act or a breach of a licence condition, or makes a reasonably significant contribution to the financial performance of the business, particularly concerning their continued suitability to hold a licence (13).

1.39 Where a casino operator fails to uphold the licensing objectives, for example by being ineffective in applying AML/CTF controls or ignoring their responsibilities under POCA, the Regulations and the Terrorism Act, or breaches an applicable licence condition, the Commission will consider reviewing the operating licence under section 116 of the Act. This could result in the suspension or revocation of the operator’s licence under sections 118 and 119 of the Act. The Commission may also consider imposing a financial penalty where a licence condition has been breached, in accordance with section 121 of the Act.

I've done a good bit of reading on it. If anyone is interested in reading the whole thing (It's really long) - Old / Expired Link

It seems like the UKGC has a firm grip on casino operators and take AML quite seriously. Threatening to revoke operators Licenses if they don't comply with carrying out checks on suspected money launderers.

However, these checks are at the discretion of the Casino and should only be carried out if they actually suspect Money Laundering from what I understand; And I feel it's something casino's will abuse.

And here is the part where people get confused about it being a RG issue.


Customer relationships

3.1 Casino operators should be mindful that some risk indicators (for example, a pattern of increasing spend or spend inconsistent with apparent source of income) could be indicative of money laundering, but also equally of problem gambling, or both. There may also be patterns of play (for example, chasing losses) that appear to be indicative of problem gambling that could also be considered to indicate other risks (for example, spend that is inconsistent with the individual’s apparent legitimate income could be the proceeds of crime). While patterns of play may be one indicator of risk, casino operators should satisfy themselves that they have asked, or are prepared to ask, the necessary questions of customers when deciding whether to establish a business relationship, maintain the relationship or terminate the relationship. In summary, it is perfectly plausible that an individual attempting to spend criminal proceeds or launder money could also be a problem gambler, but one does not necessarily follow the other. The responsibility is on the operator to be in a position to understand these dynamics and mitigate any risks to the licensing objectives.

So again, SoW is not about RG.

 

[Slottery]

If the details are requested under the AML regulations, it's very clear from the UKGC guidelines they cannot use it for RG, or any other purpose.

Sure if operator in their request is stating that this information will be only used for AML purposes and not to fill in their social responsibility, but guess operators not really state that in their requests, or at least haven't seen that stated that way but mentioning these both elements (for sure operators don't have standard letters for these but all their own ones). Would that be nicer that today operator ask your SOW for AML purpose and holding you from any game play and once it have been reviewed, then next day send exactly same request for RG purposes to make process take twice much time and provide exactly same documents twice, wouldn't really prefer that option.....

If your provided SOW is not even near cover your level of spending and operator just see that there is no AML included and let player keep playing over his budget, not stoping UKGC for fining operator when they miss clear sign of RG.

 

[shadow123]

Jesus what a bloody mess,Think the UKGC need a kick up the arse,listen to what people are saying, and think things though
properly before issuing these crappy directives.Typical of the way the establishment works in this country,they know best and
we comply without question.Would love to see what would happen if a casino happenned to have an MP who played and issued
a SOW request.Now they do have things to hide.

 

[Deeplay]

Well they are not responding so im really not sure what to do in over 10 years of gaming online I have never be treat in this way ever! So to Rizk casino if you think I have done something wrong go ahead take what ever action you feel you need to! I have zero to hide apart from my customers private information! Or repay me what is owed.

I cant believe I am having to write all this on a open forum how professional is that from the casino that it takes airing this in public to get resolution.

The only way I can prove that the money in my paypal comes not from some south American drug cartel is by showing them direct payments from clients which as I have told them I can not and will not do.

They seem happy with this choice as it now allows them to keep so far both my deposits and my winnings / pending withdraws. It is a total mess! I have been with Rizk almost since day one they have all my personal details, copies of my debit card, skrill screen shots, utility bills , everything. And me as just the low end player it is starting to feel like I am getting screwed over. Sad day indeed when a Casino that is held in such high esteem can make such a balls up of things!

 

[colinsunderland]

Sure if operator in their request is stating that this information will be only used for AML purposes and not to fill in their social responsibility, but guess operators not really state that in their requests, or at least haven't seen that stated that way but mentioning these both elements (for sure operators don't have standard letters for these but all their own ones). Would that be nicer that today operator ask your SOW for AML purpose and holding you from any game play and once it have been reviewed, then next day send exactly same request for RG purposes to make process take twice much time and provide exactly same documents twice, wouldn't really prefer that option.....

If your provided SOW is not even near cover your level of spending and operator just see that there is no AML included and let player keep playing over his budget, not stoping UKGC for fining operator when they miss clear sign of RG.

In this case they stated

In order to comply with the new European Union 4th Directive on anti-money laundering

So is clearly AML.

If it wasn't then,

how your income is generated and where it comes from

also shows its AML. RG requests wouldn't have that bit, as where your income comes from has nothing to do with affordability.

The UKGC guidelines state

7.33 Any personal data obtained by casino operators for the purposes of the Regulations may only be processed for the purposes of preventing money laundering and terrorist financing.127

7.34 Personal data should not be used for any other purpose unless:
• use of the data is permitted by or under any law other than the Regulations, or
• the casino operator has obtained the agreement of the subject of the data to the proposed use of the data.128

The Captain stated Rizk's legal department say the information can be used for both, but hasn't explained further. It can't, and that comes from a discussion I had with the UKGC about this exact thing.

If your AML documentation shows you cannot afford the levels of spend then they cannot use it to show you are a problem gambler. I actually think that's stupid, but thats the way it is. It also means a casino can't get into trouble if they ignore it.

In my view there should be a compliance officer who's job is ONLY to deal with AML requests, and the information he gets should not be accessible by other members of staff for any purpose.

Also, casinos should ONLY be requesting this information if a customer is a high risk of being involved in criminal activity.

 

[Slottery]

In this case they stated

In order to comply with the new European Union 4th Directive on anti-money laundering

So is clearly AML.

If it wasn't then,

how your income is generated and where it comes from

also shows its AML. RG requests wouldn't have that bit, as where your income comes from has nothing to do with affordability.

The UKGC guidelines state

7.33 Any personal data obtained by casino operators for the purposes of the Regulations may only be processed for the purposes of preventing money laundering and terrorist financing.127

7.34 Personal data should not be used for any other purpose unless:
• use of the data is permitted by or under any law other than the Regulations, or
• the casino operator has obtained the agreement of the subject of the data to the proposed use of the data.128

The Captain stated Rizk's legal department say the information can be used for both, but hasn't explained further. It can't, and that comes from a discussion I had with the UKGC about this exact thing.

If your AML documentation shows you cannot afford the levels of spend then they cannot use it to show you are a problem gambler. I actually think that's stupid, but thats the way it is. It also means a casino can't get into trouble if they ignore it.

In my view there should be a compliance officer who's job is ONLY to deal with AML requests, and the information he gets should not be accessible by other members of staff for any purpose.

Also, casinos should ONLY be requesting this information if a customer is a high risk of being involved in criminal activity.

Stand corrected, sorry, missed this exact letter sent, would it be ok if there would be included "and our social responsibility about our customers responsible gaming" etc...? As i somehow have feeling that if it comes out that operator have received SOW which is not matching even near the level player is spending (even amounts wouldn't be that big but player would have low income vs playing and don't trigger any clear RG signs) and don't do anything as departments can't communicate between each others, it wouldn't stop UKGC to put nice price tag for failing to fill social responsibility when having documents which clearly point out that player in question is spending significant part of incomes for gambling.

Casinos usually only accepting withdrawals back to same source where deposit has came and if you always deposit and withdraw with same credit card, there really is hard to see ML anywhere, especially if you wager your deposits multiple times, but still i know many people who have received SOW request (nothing to do with Rizk and GIG anymore, but in general that how casinos should compete in these cases if they hold information which could prevent somebody from sometimes really harmful situation by overspending and they can't use it if it was on AML purposes, can't alarm RG department). I could had assume that this information shouldn't be used to build customer profile for targeted marketing for wealthy people or other purposes, but using it for RG purposes i personally can see positive impacts for possible problem gambler who could then be interacted by operator and social responsibility could be filled.

 

[Betreels Casino & Sports]

The UKGC needs to provide better guidelines/rules for this. Example: what amount deposited should trigger a SOW request? Over what period must this amount be spent? Can the amount be a sum of Deposits Less Cashouts? etc. etc.

It's simply not fair in its current format and is going to get worse if casinos simply apply their own interpretation of the laws.

 

[brianmon]

If the UKGC is implementing this because of an EU directive.
Shouldn't it be down to the people who drew up the European Union 4th Directive on anti-money laundering, to specify the correct procedures and thresholds etc. So the UKGC can pass it down the line to the casinos.

It seems like the UKGC is in the same position as their casinos. They've been told to do something by the EU. But not been told how to do it.

I assume Deeplay isn't a UK player, since the emails from Rizk are quoting European Union 4th Directive on anti-money laundering and not UKGC

 

[Chipkin9]

The UKGC needs to provide better guidelines/rules for this. Example: what amount deposited should trigger a SOW request? Over what period must this amount be spent? Can the amount be a sum of Deposits Less Cashouts? etc. etc.

It's simply not fair in its current format and is going to get worse if casinos simply apply their own interpretation of the laws.

The Money Laundering Regulations

1.34 Operators should be aware that there is no minimum financial threshold for the management and reporting of known or suspected money laundering or terrorist financing activity.

Casino's are free to ask for SoW whenever they feel like it at thier own discretion. Like I said...Casino's will abuse this as I think they are doing in this very case.

They shouldn't carry out SoW unless they suspect an illegitimate source of funds based on player activity. Rizk need to inform Deeplay why they are asking him for this SoW; according to the UKGC at least.

If they don't suspect him of funding his account with illegitimate funds, then why are they asking for his SoW?

If Deeplay is using his Bank's Debit Card, then it's impossible for the proceeds to be illegal. Since the Banks would be reporting any suspicious activities on the account to the authorities.

If he's using E-Wallets it's harder to determine where money is coming from.

This is why Casino's have stopped issuing match bonuses for deposits being made by Skrill, Neteller etc etc..because they don't want to be complicit in facilitating, yet they will accept the deposits

 

[Deeplay]

If the UKGC is implementing this because of an EU directive.
Shouldn't it be down to the people who drew up the European Union 4th Directive on anti-money laundering, to specify the correct procedures and thresholds etc. So the UKGC can pass it down the line to the casinos.

It seems like the UKGC is in the same position as their casinos. They've been told to do something by the EU. But not been told how to do it.

I assume Deeplay isn't a UK player, since the emails from Rizk are quoting European Union 4th Directive on anti-money laundering and not UKGC

I am very much a UK player. Born and bred Yorkshire man with some Italian thrown in for good measure ;-)

 

[Deeplay]

The Money Laundering Regulations

1.34 Operators should be aware that there is no minimum financial threshold for the management and reporting of known or suspected money laundering or terrorist financing activity.



If Deeplay is using his Bank's Debit Card, then it's impossible for the proceeds to be illegal. Since the Banks would be reporting any suspicious activities on the account to the authorities.

Correct last 4 or so deposits were with my RBS Visa Debit card. Of which Rizk Casino hold front and back copies all verified ...

 

[brianmon]

I am very much a UK player. Born and bred Yorkshire man with some Italian thrown in for good measure ;-)

Sorry, I was just going by your location, on your profile

 

[Chipkin9]

Sorry, I was just going by your location, on your profile

Isn't the UK in Europe?

 

[Chipkin9]

Correct last 4 or so deposits were with my RBS Visa Debit card. Of which Rizk Casino hold front and back copies all verified ...

Then Rizk definitely needs to explain why they are carrying out this SoW on you.

 

[Slottery]

The UKGC needs to provide better guidelines/rules for this. Example: what amount deposited should trigger a SOW request? Over what period must this amount be spent? Can the amount be a sum of Deposits Less Cashouts? etc. etc.

It's simply not fair in its current format and is going to get worse if casinos simply apply their own interpretation of the laws.

That would be great for ML purposes if you would know that "Ok, in this site i still can deposit and withdraw £xxxx before SOW is requested, then have to jump to other site" If these, like it seems, will be asked from players and it will not go anywhere, could be ok even randomly just take some players for little scare for these suspicious accounts with bad means. Anyway, not fan of this like i guess nobody here, but as you have seen these UKGC fines for operators, will understand them quite well too.

 

[ternur]

I've said before that I personally find it problematic when a SOW is requested for one purpose and used for another. That's another question entirely though (and not entirely without data protection consequences).

But.

The SOW is being used by operators for both purposes. The UKGC seem to require this. Let's look at the Old / Expired Link (Customer Interaction) and for example the

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:

The UKGC found that SJ breached social responsibility code provision 3.4.1. (Customer Interaction) partly because SJ did not have in place alerts so they would be able to form a "holistic view of the customers gambling activities". (RG)

They also found that SJ failed to comply with financial requirements (AML).

The UKGC then stated:

To avoid making the same mistakes operators should consider the following questions:

• Will your policies identify at risk customers who may not be displaying obvious signs of, or
overt behaviour associated with, problem gambling?
• Have you ensured you are regularly updating and reviewing anti-money laundering policies?
• Are you gaining a holistic picture of the customer source of funds/wealth using all of the
information available?
• Once an at risk customer has been identified via an alert, do you have in place procedures
for reviewing all the information available in order to decide how to respond?

So the UKGC is in fact viewing the situation in a way that a SOW can be, and actually should be used for RG purposes as well. In reality the two objectives (AML and RG) are mixed. And operators must use all of the information available to meet these requirements. That includes the SOW.

 

[Chipkin9]

I've said before that I personally find it problematic when a SOW is requested for one purpose and used for another. That's another question entirely though (and not entirely without data protection consequences).

But.

The SOW is being used by operators for both purposes. The UKGC seem to require this. Let's look at the Old / Expired Link (Customer Interaction) and for example the

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

:

The UKGC found that SJ breached social responsibility code provision 3.4.1. (Customer Interaction) partly because SJ did not have in place alerts so they would be able to form a "holistic view of the customers gambling activities". (RG)

They also found that SJ failed to comply with financial requirements (AML).

The UKGC then stated:



So the UKGC is in fact viewing the situation in a way that a SOW can be, and actually should be used for RG purposes as well. In reality the two objectives (AML and RG) are mixed. And operators must use all of the information available to meet these requirements. That includes the SOW.

No no. That is a guideline the UKGC has outlined to help Casino operators make the distinction between ML's and PG's.

SoW should only be requested if a player is suspected of being involved in criminal activity. Not if he is a problem gambler. Casino's have ways of identifying who is who and what is what based on player activity and history.

Player A for example: Deposits small amounts, yet always reverses his winnings and losses them back to the casino. (Possible Problem Gambler)
Player B: Deposits high amounts frequently and sometimes loses back his winnings (Possible Gambling Problem)
Player C: Deposits high amounts frequently and never reverses winnings (Definitely not a Problem Gambler)

Player C would be more likely the Money Launderer in this instance, since losing back any winnings generated would defeat the purpose of Laundering your money in the first place

Just an example of course.

That's the point of the guideline.

 

[ternur]

If Deeplay is using his Bank's Debit Card, then it's impossible for the proceeds to be illegal. Since the Banks would be reporting any suspicious activities on the account to the authorities.

That's not entirely correct Chipkin (Sorry to quote you again, not picking on you. You make valid observations )

Money is being laundered through banks daily. Even though banks monitor and report suspicious activity, it's in no way a perfect system and the funds could still come from illegal activities. A casino can't rely on the fact that if the deposit comes from a bank account, then the money is clean and no further investigation is required.

 

[colinsunderland]

So the UKGC is in fact viewing the situation in a way that a SOW can be, and actually should be used for RG purposes as well. In reality the two objectives (AML and RG) are mixed. And operators must use all of the information available to meet these requirements. That includes the SOW.

I understand where you are coming from, but, as SOW information cannot be used for any other purpose, it wouldn't be classed as 'information available'. It isn't, as legally it isn't available.
It would be no different to a casino hacking your facebook account, reading messages between you and your mate where you told him you had spent your rent that month at a casino, then blocking your account on RG issues as a result of that message. They wouldn't be allowed to do that, as even if they held the information, legally they couldn't use it.

 

[colinsunderland]

That's not entirely correct Chipkin (Sorry to quote you again, not picking on you. You make valid observations )

Money is being laundered through banks daily. Even though banks monitor and report suspicious activity, it's in no way a perfect system and the funds could still come from illegal activities. A casino can't rely on the fact that if the deposit comes from a bank account, then the money is clean and no further investigation is required.

Yes I agree. Banks tend to only do AML checks on transactions of £10k +
I could go rob a cash machine tonight, pop £5k into my account tomorrow and gamble it.

@Captain Rizk could you point us towards the legislation that allows you to withhold a customer's funds if they refuse to supply the documentation please?

@Casinomeister now the casino have confirmed they won't return the funds, what are your views please?

 

[Chipkin9]

That's not entirely correct Chipkin (Sorry to quote you again, not picking on you. You make valid observations )

Money is being laundered through banks daily. Even though banks monitor and report suspicious activity, it's in no way a perfect system and the funds could still come from illegal activities. A casino can't rely on the fact that if the deposit comes from a bank account, then the money is clean and no further investigation is required.

Ok fair enough point. Even though it's highly likely they will eventually get caught.

 

[ternur]

No no. That is a guideline the UKGC has outlined to help Casino operators make the distinction between ML's and PG's.

I might have linked a summary instead of full version of licence conditions and codes of practice. But the customer interaction provision is the same -- which was used in the SJ case. "All of the information available" to me includes the SOW.