Intelligence – Know Your Customer

helping me to identify and tick the box, is this a politician?’ That’s one of the AML regulations, identifying politicians; and the banks, law firms, and casinos all, as part of their AML, need to identify them. For a bank it may be important to track a politician because they might come in and deposit £50,000 in £50 notes – the bank has to ask, where has the money come from? Similarly a casino may know the player is a politician, so they may watch the player’s activities closer; they are also look at, does this player have enough money to gamble, and if they’re betting a lot, where are they getting that money? We help them to efficiently do that by getting our data aligned to their workflow. Also, what we have seen recently is the regulator pushing

to identify the wealth, where the money comes from; we help the operator by doing reports looking at the individuals that are VIPs potentially, to help them analyse the wealth. We can do that because we have a lot of unique assets at Acuris to track where people make their money, where liquidity events have happened; again there is no silver bullet, we can’t look at their bank accounts but we can find what is in the public domain and use our research assets to identify where some of that wealth is from, and to build a bigger picture of that individual to help the operator comply with regulations.

CI: There is an element of imprecision to it then, because presumably legally there is only so far you can drill down with this. Do you reach a point with your reports and research where you have to say to the client, you take it from here? JL: My experience with gaming customers and regulators is that regulators want to see from an organisation that they have done all they can to comply, and that they have done all they can to mitigate these specific risks. If they feel that an organisation has not set up a policy – have you established a really good policy to say, we will check all of our customers, and will check them at the outset to say who they are, check their passports, ask the right questions. That policy will be rolled out within the casino, the betting firm, online or wherever, but there is no point having that policy without having controls, without having checks you can make to verify what you have been told. You’ve asked the customer what’s your name, date of birth, where did you get this

money – the policy says you have to ask those questions; you have that information, now you want to go and check if it’s true or not or if there is any other information out in the public domain. Because we have those data assets, we may have profiles on these people because they fit certain risk categories we cover – are you a politician, are you on a sanction list or Her Majesty’s Treasury list, for example. One of the lists of people that you cannot work with; we collect those, aggregate them for our work. We also include negative news – it may be someone we have already tracked as part of a risk category that regulations are telling us to track. For example, John Smith walks through the door, they see he is on our database, he’s a politician, that’s fine. Politicians are good customers, he has some money to spend, but we will watch him carefully and we may order an enhanced due diligence report on him to find out more and see what is out there. Or it could be the case that John Smith walks through the door and there is nothing on John Smith because he is not sanctioned, is not in the news for any negative reason that we cover, is not a politician – but he is spending huge amounts of money. Is there anything out there in the public domain that we can use to help you here? We have the capability to explore that. There may be scope to do further checks – we recently acquired a company called Blackpeak, based in Hong Kong and Singapore, which does a higher level of reporting, particularly for mergers and acquisitions, IPOs and the like; this kind of reporting goes beyond open source and looks at the source of information. To an extent, the regulator wants to see that you follow that

process, that you have implemented a policy, follow it and do all that you can. Money laundering still happens, but the fines are always lower or non-existent if the company has done as much as they can and followed the letter of the law in terms of the policies and controls they should be implementing.

CI: How much of your product suite is from C6 and how much is from Acuris – how has the suite evolved with the acquisition? JL: C6 has been around since 2004 and has been known in gaming for a decade or more; in terms of things we have added, we have the backing of Acuris as a company, Hamilton Matthews, and we are owned by the ION Group and they have invested significant resources into the

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