KOMPLI-GLOBAL
Jane Jee
Martin Pashley
providing solutions that incorporate artificial intelligence and which are now available, proper CDD can be carried out quickly, efficiently and without any customer friction.
necessary Customer Due Diligence (CDD). Player profiles are not set properly – the skillset of the staff is often not sufficient to understand the scores and alerts – (e.g. cultural differences, age differences). The interpretation of profiles may be inaccurate or inadequate and operators simply do not have the staff to cope with the alerts generated. By the time an analyst has reviewed a customer, the offence may have already been committed. Technology, properly devised and combined with skilled human resources, offers the appropriate solution.
Earlier this year, William Hill, for example, made a serious assumption on a verbal conversation, which seems staggering in the context of what happened – how could they have got it so wrong? William Hill permitted a customer to deposit huge amounts of money over 14 months, based only on verbal confirmation of their income. In any other industry, verbal confirmation is not acceptable. Documentation for source of funds should always
be required for verification. In addition, had sufficient CDD been conducted at the point of account opening, this situation would have been avoided. Operators may not see this as a practical solution, as additional checks and a longer account opening process will deter customers from opening an account. However, with cutting edge technology
Looking at the wider industry, do you think that because of the nature of online gambling and the amounts of money that can potentially be involved, it is ripe for money laundering and criminal activity? Gambling in general has always been ripe for criminal activity. Gambling has been used to launder money for as long as organised crime and gambling have co-existed. The industry involves a huge volume of cash flow and transactions, it doesn’t involve a physical product and gambling wins are tax free in many jurisdictions. All these factors, with the addition of multiple jurisdictions (some of which are regulatory havens) and virtual cash flow, mean that there is considerable potential for money laundering in online gaming.
What can you tell me about companies searching the deep web and various databases to check on customers? The vast majority of gaming companies wouldn’t know how to access deep-web searching, let alone adopt technology to achieve this. Most operators still rely on structured data aggregators do basic KYC checking which is inaccurate, inadequate – often out of date and no longer fit for purpose.
Do you consider many of the current methods in use to be outdated? What – if anything – is holding companies back from using more modern methods? Since regulation of the gaming industry mandated that age verification & KYC checking should be carried out, most operators have used simple KYC
JULY 2018 51 “
The only surprise is that fines of this nature have not been levied before
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