:: ADVISORY
4) Track player location when required. In states that require gamers to be physically within their borders, geo-location software or IP address tracking can spot non-resident players. If using IP addresses, companies should be on the lookout for proxy servers that are routing traffic elsewhere. 5) Document procedures and prioritize the risk assessment. Operators should have written procedures in place, and should conduct thorough risk assessments that identify security gaps and reflect real-world operations. 6) Maintain risk-based thresholds that trigger enhanced due diligence. Operators should define the events or thresholds that trigger enhanced due diligence. When players meet these thresholds, enhanced due diligence measures should be undertaken. These may include: matching patron identities to credit rating agency data, checking local language media sources for adverse news, or verifying patron sources of wealth / sources of funds. 7) Be wary of wire transfers to high-risk locations. Redemptions should follow due-diligence procedures as well. Funds transfers to high-risk9 jurisdictions may be warning signs, particularly if they’re outside a patron’s normal geographic footprint. 8) Institute a culture of compliance. An iGaming company’s leadership should be engaged and actively support and understand compliance efforts. Online casinos, with their stash of data and their ability to track customers’ gaming activity, can leverage their technology expertise to spot bad actors. As the public becomes more familiar with the implications of data mining, they’ll want to see how big data is being put to good use. They should expect nothing less. :: CGi References
1 ”Tim Stocks presentation to KPMG Gibraltar eGaming Summit 2015,
https://www.kpmg.com/GI/en/IssuesAndInsights/ArticlesPublications/E vents/eSummit-2015/Documents/Tim-Stocks.pdf 2 “2015 Internet Gambling Legislation,” National Conference of State Legislators, http://www.ncsl.org/research/financial-services-andcommerce/2015-internet-gambling-legislation.aspx 3 “International Standards on Combating Money Laundering and the Financing of Terrorism: The FATF Recommendations,” Financial Action Task Force, updated 2015, http://www.fatfgafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recomm
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endations.pdf 4 “Vulnerabilities of Casinos and Gaming Sector,” Financial Action Task Force, 2009, http://www.fatfgafi.org/publications/methodsandtrends/documents/vulnerabilitiesofca sinosandgamingsector.html 5 http://calvinayre.com/2015/08/24/casino/china-macau-sign-pact-totoughens-money-laundering-measures/ 6 “Money Laundering,” 2nd ed., 2013, UK Gambling Commission. 7 “Regulation 5A, Operation of Interactive Gaming,” http://gaming.nv.gov/modules/showdocument.aspx?documentid=294 8“Best Practices for Anti-Money Laundering Compliance,” American Gambling Association, December 2004. https://www.americangaming.org/sites/default/files/research_files/agabest-practices-re-aml-compliance-122014.pdf 9http://www.fatf-gafi.org/publications/high-riskandnoncooperativejurisdictions/documents/fatf-compliance-february-2016.html 10 http://www.reviewjournal.com/business/casinos-gaming/las-vegassands-return-474-million-avoid-criminal-charges 11https://www.fincen.gov/news_room/ea/files/Tinian_Dynasty_Assess ment.pdf 12https://www.fincen.gov/news_room/ea/files/20150302%20Assessme nt%20of%20Civil%20Money%20Penalty%20Trump%20Taj%20Mahal%2 0(post-approval%20by%20bankruptcy%20court).pdf 13https://www.fincen.gov/news_room/nr/files/Caesars_Palace_ASSESS MENT.pdf 14https://www.fincen.gov/news_room/nr/html/20160405.html 15http://calvinayre.com/2015/12/16/casino/caesars-uk-spanked-foraml-lapses/ 16http://calvinayre.com/2015/09/07/business/ukgc-spank-rank-groupanti-money-laundering-lapses/ 17http://calvinayre.com/2016/02/29/business/paddy-power-fined-antimoney-laundering-know-your-customer-lapses/ VASILIOS CHRISOS & ALEC MASSEY
Vasilios P. Chrisos is a principal in the financial crimes unit of PricewaterhouseCoopers LLP. He has over 20 years of experience assisting companies on all aspects of financial crime compliance with a particular focus on AML and sanctions matters. He has advised casino operators on the design and implementation of comprehensive, risk-based AML and sanctions compliance programs, including the execution of enhanced due diligence (EDD) measures for higher-risk patrons and the investigation of potentially suspicious levels of play. He has also advised institutions on communication strategies with the applicable regulatory authorities, including regular updates and submissions on the progress of remediation efforts. Mr. Chrisos serves on the Global Advisory Board of the Association of Certified Anti-Money Laundering Specialists (ACAMS). Alec Massey is a director in PwC's Risk and Regulatory consulting practice and advises his hospitality and gaming clients on the strategic, operational, financial, and regulatory risks impacting their business. Alec has over 14 years of experience assisting organizations with these challenges and works closely with our financial crimes unit to deliver AML and sanctions solutions to gaming clients.