SOW..

[nikantw]

As we already know, 3rd line from Guts confirms its a blanket request from everyone (for whatever reason).

 

[brianmon]

I was asked by Betat to send SOW documents, which I refused, and told them to close my account, which they haven't done.

Apparenty this was for responsible gaming reasons. So, why is my account still open, and why are they constantly sending me 100% deposit bonus offers?

It doesn't seem very responsible to me

 

[EkJR]

I'm sorry but most of what you say is incorrect. You might want to go and read the actual documentation issued by the ukgc regarding money laundering regulations as your interpretation is wrong.

Yep, because it's not as clear as has been made out. Unless there has been other guidance issued of course which players are unaware of.

 

[nikantw]

All players should refuse giving any SoW documents.
Answer questions, yes. Complete a form, ok.
Anything more no. Have UKGC ask for that and only give it to them.

Its time to stop this nonsense and get a bit serious about ML, RG and why not SE (SE has nothing to do with the topic but is also a mess).

 

[aceking123]

Similar problem over at casino euro to be fair theyve requested in nov SOW ,i replied that i would require them to supply evidence & paperwork links etc etc so i can see its required from ukgc & its now law.

i had a response from them,i suggested they stopped taking any more deposits & suspended my account untill it was cleared up. Same with paying out anything.

Made 2k in deposits yesterday theyve now suspended my account & demanded the SOW docs, pay slips etc.

So i have copies of e mails sent back & fourth on the 28 of dec with my concerns.

So im going to fight this one out with them, because im not happy the way its been dealt with.

 

[mack341]

I think its accepted a fair number of casinos have used/still use repeated KYC to stall withdrawals, now it seems SOW's will be used for this purpose too. In the cases where UKGC have issued fines for SOW failures there were good grounds for doing so, they were a million miles away from the op's situation.

My gut feeling though is some casinos will try to exploit SOWs for the purpose they were not intended and blame UKGC, later on down the road once UKGC realise online casinos have been taking the proverbial they will issue further guidance.

 

[Jono777]

To be fair to Guts on this one, that form (if it is the same one I completed) has been there for a good while and it is not too intrusive IMO.

It is when AMOUNTS start getting requested along with pay slips and full bank statements etc etc etc where I would draw the line.

@OP as you say you've done the form, after I did, I was left alone and account operational as before (previously did standard KYC)

If you've been paid (skim read thread so don't know) I think you'll be ok moving forward (for now) just bear in mind this SoW is the future of online full KYC so my advice from now on would be prepared for it every deposit and every withdrawal - If it doesn't come then happy days but think before playing if you're not 100% happy with it.

FWIW, I hate it but could legally and comfortably satisfy it but I know the "risks" when I play so the onus is fully on me. In general, I feel accepting this as a player has to be one of, if not THE most awful thing I have come across in 16 years on online play!

 

[mack341]

I wonder if the casino's sign up terms and conditions now have a paragraph informing potential customers that copies of their bank statements, payslips may be requested at a later date?

 

[Mark_32Red (retired acct)]

Hello Everyone!

There has been a lot of interests towards this topic since it was introduced in igaming and given the nature of the documents requested, I understand it's a controversial subject which can cause a bit stir and confusion as it is a relatively new regulation in the online casino industry. Our goal is to make it as a painless and smooth process to the customer as possible since this is something that cannot be neglected.

We are obligated to verify customers Source of Wealth due to the UKGC regulations stating we need to know where the funds from the customer's deposits are coming from. We also need to follow the Responsible Gaming guidelines and ensure player's safety which may also lead for request of SOW related documents.

Being a fully licenced and responsible casino operator, we are also required to comply with certain regulatory requirements, as per our obligation to both EU and national requirements.



You are correct when it comes “where deposits and withdrawals reach 2.000 Euro” following the UKGC regulations, we are entitled to request SOW if the AML threshold when this threshold is met. If this threshold is met, that's when we ask for the Source of Wealth questionnaire, possibly also Source of Funds documents such as payslips, work contracts, a sale of properties or similar to maintain the player safety of our players.

Source of Wealth Questionnaire may trigger on deposit and also withdrawals for a lifetime amount when it reaches the threshold or any deposits/withdrawals, as this is a new procedure that started last year which then allows us to request any SoW documents/questionnaires from players for their safety.

The Source of Wealth is mostly asked for UK players, in order to make sure there are players who're not playing if they're loaning funds, in debt, unemployed with no income, low salary, or on welfare.

This is something the UKGC has ruled which we need to follow in order to be able to operate in the United Kingdom.

I’ll keep this brief as I don’t want to get into a public debate, but SOW and AML are not the same thing. AML has a strict limit where SOW is based on a casinos own ‘risk rating’ - so many are not getting these things right.

We haven’t got the answers, you haven’t got the answers. But let’s not confuse the two. The problem is we are dealing with Responsible Gaming (RG), Source of Wealth (SOW), Source of Funds (SOF) and also Anti Money Laundering (AML) - a ton of legislation with acronyms with many being up to the operator to set the thresholds.

I’m a casino player as well as an operator and I’ve seen varied ways of tackling them and it’s an area which needs improvement. The biggest bugbear for me is asking a long term player for docs as they hit a limit after x years. It’s hard to explain. Thankfully our loyal players seem to understand the industry is changing.

Mark

 

[colinsunderland]

I’ll keep this brief as I don’t want to get into a public debate, but SOW and AML are not the same thing. AML has a strict limit where SOW is based on a casinos own ‘risk rating’ - so many are not getting these things right.

We haven’t got the answers, you haven’t got the answers. But let’s not confuse the two. The problem is we are dealing with Responsible Gaming (RG), Source of Wealth (SOW), Source of Funds (SOF) and also Anti Money Laundering (AML) - a ton of legislation with acronyms with many being up to the operator to set the thresholds.

I’m a casino player as well as an operator and I’ve seen varied ways of tackling them and it’s an area which needs improvement. The biggest bugbear for me is asking a long term player for docs as they hit a limit after x years. It’s hard to explain. Thankfully our loyal players seem to understand the industry is changing.

Mark

I don't understand your post Mark, surely SOW and SOF are the same thing?
You say AML has strict limits, can you link to that please, as it didn't have previously and I've not seen anything that changes the earlier UKGC guidance, which was basically, you can only ask for SOW for AML if the customer is considered to be a high risk of being involved in crime etc. Also, any documentation provided for AML purposes could only be used for that, nothing else, including RG issues.
I don't see how limits can possibly put someone into a high risk group of customers, in fact its ridiculous, something I think you agree with, if I had deposited £10 a week for 10 years, I would be over £5000, if someone deposited £5000 tonight they would be at the same level, yet clearly show completely different risks.
I am talking from a UK perspective, if its different elsewhere then fair enough

 

[dpp00]

The Source of Wealth is mostly asked for UK players, in order to make sure there are players who're not playing if they're loaning funds, in debt, unemployed with no income, low salary, or on welfare.

and there is big brothers manifesto in all its glory, you control peoples money you control them under the pretense of helping them from themselves,

so low income/welfare/ have a loan/ we have decided you cant throw a tenner in a casino once a week, the natural progression here is

you cant afford that pint in yr local/ you cant afford those fish fingers/you certainly cant afford a pack of fags/ under new guide lines we cant sell you that bag of crisps cause there fattening,

its both shameful and horrifying in equal measure.

 

[Mark_32Red (retired acct)]

I don't understand your post Mark, surely SOW and SOF are the same thing?
You say AML has strict limits, can you link to that please, as it didn't have previously and I've not seen anything that changes the earlier UKGC guidance, which was basically, you can only ask for SOW for AML if the customer is considered to be a high risk of being involved in crime etc. Also, any documentation provided for AML purposes could only be used for that, nothing else, including RG issues.
I don't see how limits can possibly put someone into a high risk group of customers, in fact its ridiculous, something I think you agree with, if I had deposited £10 a week for 10 years, I would be over £5000, if someone deposited £5000 tonight they would be at the same level, yet clearly show completely different risks.
I am talking from a UK perspective, if its different elsewhere then fair enough

Hi Colin,

I don’t have any links I can share but I’ll see what I can find when back in the office.

With regards to SOF & SOW it’s not quite the same and they will usually be required at different times.

SOF - source of funds, proof of where the cash came from e.g. making sure the deposit method belongs to you.

SOW - making sure you earned the funds deposited legitimately.

As I said above policies vary in different businesses and with no strict guidance it can often vary depending on other influences such as RG. It’s a challenge for sure but ultimately it’s in place to help prevent fraud and protect players.

Mark

 

[Slottery]

Hi Colin,

I don’t have any links I can share but I’ll see what I can find when back in the office.

With regards to SOF & SOW it’s not quite the same and they will usually be required at different times.

SOF - source of funds, proof of where the cash came from e.g. making sure the deposit method belongs to you.

SOW - making sure you earned the funds deposited legitimately.

As I said above policies vary in different businesses and with no strict guidance it can often vary depending on other influences such as RG. It’s a challenge for sure but ultimately it’s in place to help prevent fraud and protect players.

Mark

Would see it bit differently, SOW is what's requested to see players income (questionnaire used many times first and if need, then some payslips or other proof) and financial situation to assign risk level to player, if everything is in line, all is ok.

SOF would be more that if player is sending you bank statement where are incoming transactions which are not clear and not matching with SOW what player have provided or player is making some very big deposit which don't match to SOW information you are holding you would need proof that money is from legal source.

Making sure that deposit method belongs to player will be picked up in KYC checks and also when transaction is made from credit card or bank account, it will clearly shows owner of that account like if you use 3rd party credit card or bank account, you will be picked up latest when you try to withdraw to it, like we have seen in many topics, so that's not really SOF related, you can see from who deposit is coming (if not anonymous method used) but you want to know from where money came to players bank account when you request SOF.

That can agree very much that clearer guidelines should be provided from authorities to make this process bit more similar practice for operators like KYC pretty much is now. This SOW/SOF thing have been around quite a while already and still nobody (including myself) has not very clear picture what would be best practice in this process and therefore like forecast said in some topic like year ago, we have been having quite many of these topics and can see we still will if these kind of scenarios like OP:s keep happening.

Good weekend for everybody

 

[colinsunderland]

Hi Colin,

I don’t have any links I can share but I’ll see what I can find when back in the office.

With regards to SOF & SOW it’s not quite the same and they will usually be required at different times.

SOF - source of funds, proof of where the cash came from e.g. making sure the deposit method belongs to you.

SOW - making sure you earned the funds deposited legitimately.

As I said above policies vary in different businesses and with no strict guidance it can often vary depending on other influences such as RG. It’s a challenge for sure but ultimately it’s in place to help prevent fraud and protect players.

Mark

Thanks Mark, the last document I saw addressing this was

Old / Expired Link

Which says stuff like

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 operators can offset any burden of taking a risk-based approach with the benefits of having a realistic assessment of the threat of the operator being misused in connection with money laundering or terrorist financing. It focuses the effort where it is most needed and will have most impact. It is not a blanket one size fits all approach, and therefore operators have a degree of flexibility in their methods of compliance.

Where a customer is assessed as presenting higher risk, additional information in respect of that customer should be collected. This will help the casino operator judge whether the higher risk that the customer is perceived to present is likely to materialise, and provide grounds for proportionate and recorded decisions.

which is why I don't understand when casinos say there are financial thresholds they have to adhere to.

thanks for replying

 

[pinnit2014]

That's what i thought regarding AML - there is no threshold. Otherwise it would be contrary to a risk based approach whereby you could justifiably asked for SOW for someone with 20k of deposits but not someone, per their low risk assessment, of 50k. But i've seen people reference 10k etc which I've not seen.

Using withdrawal x, deposit y doesn't really make sense to me and appears to be contrary to the legislation because under that you're not risk assessing, you're just implementing an arbitrary 'net' amount. Which if you think about it may expose a casino more than actually taking them time to look at patterns/risks etc.

 

[Slottery]

Using withdrawal x, deposit y doesn't really make sense to me and appears to be contrary to the legislation because under that you're not risk assessing, you're just implementing an arbitrary 'net' amount. Which if you think about it may expose a casino more than actually taking them time to look at patterns/risks etc.

Exactly, if it's done automatically based on your lifetime thresholds within last 7 years, no suspicious game patterns (low risk table games, chip dumping in poker, only wagering deposit ones), anonymous payment methods and other possible triggers what would give you higher risk score than other with same amount of threshold, playing high volatility slots, always using own same credit card as payment method, not gambling huge amounts and hardly ever make withdrawals.

If you really would like to laundry money through online casinos to get most of it clean with these kind of patterns above, wouldn't you play just small amounts and very many casinos with your Paysafe or other prepaid cards not to ring any bells and get SOW/SOF questions? Then when you have thousands hundreds or millions dirty money, you most probably get some other way than online gaming to make it clean.

 

[nikantw]

The only way I can see anyone do serious ML is by owning an online casino. I think there is a case of that with some Malta casinos and Mafia.
I don't think it is an easy or good idea for a player. Playing patern is easy to spot and there are many other problems.
As many said SoF is the standard KYC.
That leaves only the deposit limit and where did you get the money.
No reason for casinos to ask docs for that. Only UKGC should in special cases.

 

[brianmon]

The only way I can see anyone do serious ML is by owning an online casino. I think there is a case of that with some Malta casinos and Mafia.
I don't think it is an easy or good idea for a player. Playing patern is easy to spot and there are many other problems.
As many said SoF is the standard KYC.
That leaves only the deposit limit and where did you get the money.
No reason for casinos to ask docs for that. Only UKGC should in special cases.

Which is probably why all this has come about. Certain casinos laundering money through 'anonymous' accounts.
So now everyone has to suffer, because all accounts now have to be proved to be legitimate.

 

[colinsunderland]

The only way I can see anyone do serious ML is by owning an online casino. I think there is a case of that with some Malta casinos and Mafia.
I don't think it is an easy or good idea for a player. Playing patern is easy to spot and there are many other problems.
As many said SoF is the standard KYC.
That leaves only the deposit limit and where did you get the money.
No reason for casinos to ask docs for that. Only UKGC should in special cases.

Quite easy to launder money through Videoslots tbh, not so much pretty much any other casino.
It isn't just about laundering in the strict sense of the word though, could be people doing crime, benefit fraud etc.

 

[brianmon]

Quite easy to launder money through Videoslots tbh, not so much pretty much any other casino.
It isn't just about laundering in the strict sense of the word though, could be people doing crime, benefit fraud etc.

Yeah, I deposited at VS almost every week last year, by debit card, and was forced to withdraw to Neteller every time I made a withdrawal request.
Because I'd made most of my deposits, the previous year via Neteller

 

[Aryol]

Just sad that there is still this stalling of withdraws in the heads of some casino managers. I know that they want to make money, but sometimes we get into things that are insane. Once I asked if I am verified, they told me yes, I asked maybe 3 times. Deposited, won and then they wanted more documents for 150 €. I just played my money down, was not that smart and maybe I did not expect ~90 complete dead spins in Vikings (I had less than 200 spins till bust at 1 €).

But not super angry on them, at the very end it was my fault. I did not expect ~25 % RTP but I am happy that this happened the first time at 150 € and not on the other "big" hits I had. This just helped me to play super responsible, I just sorted the casinos out and did not deposit anymore after that. But I will deposit again, but I changed my amounts from 40 € - 200 € to 10 € - 40 €. But first I will take a 4-week break to compensate the 150 €. Like magic, I can hold me for this time but I can not stop playing it down when I am angry.

What I want to express is that SOW will be mostly used to stall withdraws or just asking randomly a few players. There is no point of nearly asking every player who deposits 10 €, which probably was stolen from an old granny lol and now they money needs to ... bah... lol just the answer from Guts made me laugh in the other thread.

 

[pinnit2014]

The only way I can see anyone do serious ML is by owning an online casino. I think there is a case of that with some Malta casinos and Mafia.
I don't think it is an easy or good idea for a player. Playing patern is easy to spot and there are many other problems.
As many said SoF is the standard KYC.
That leaves only the deposit limit and where did you get the money.
No reason for casinos to ask docs for that. Only UKGC should in special cases.

Don’t know about that, as it would mean the casinos are essentially then outsourcing some of their AML controls to a third party (albeit a regulator). And when the fines/charges come for breaches it’s going to be the casino who would be liable anyhow (unless they countersued the GC )

End of day I don’t necessarily buy into the fact that the casinos need spoon fed by the UKGC. These people are meant to be business folk who should have an idea over how to meet their legislative responsibilities.

 

[colinsunderland]

Yeah, I deposited at VS almost every week last year, by debit card, and was forced to withdraw to Neteller every time I made a withdrawal request.
Because I'd made most of my deposits, the previous year via Neteller

Yep, exactly.

 

[nikantw]

Quite easy to launder money through Videoslots tbh, not so much pretty much any other casino.
It isn't just about laundering in the strict sense of the word though, could be people doing crime, benefit fraud etc.

I disagree. I don't think it is easy (KYC on every step) and I don't even think many authorities consider online gambling cashouts as "clean income". Acceptable after checks, maybe.
Where you see problem I see anti-fraud. And more measures recently in place. As for crime, that is a job for the police.

Anywhay my point was and remains that there is no real reason and it is not acceptable for every player to give detailed financial information to everyone.

 

[colinsunderland]

I disagree. I don't think it is easy (KYC on every step) and I don't even think many authorities consider online gambling cashouts as "clean income". Acceptable after checks, maybe.
Where you see problem I see anti-fraud. And more measures recently in place. As for crime, that is a job for the police.

Anywhay my point was and remains that there is no real reason and it is not acceptable for every player to give detailed financial information to everyone.

But what checks couldn't someone money laundering get round?
Certainly in the UK gambling winnings would be classed as clean income, yes if someone was doing a full investigation and requested full account activity from Videoslots it wouldn't pass, but that level of scrutiny is rare, and if its just to clean some money to buy a car or deposit on a house, or income from working on the fiddle or similar, it would work. I don't think theres another casino you could do the same with, apart from some of the main bookies.