As industry operators are being further pressured to improve their AML and compliance disciplines, all stakeholders face a tough balancing act in servicing betting consumers’, verification, customer services, payment and UX options.
Speaking at BOFCON2018, Marc Wood Head of Gaming at Pay360 details how industry leaders should approach 2018’s AML and Compliance conundrum
SBC: Hi Marc. In 2018, why has AML and Fraud Prevention become the prevalent topic for all industry stakeholders?
Marc Wood: AML and Fraud protection has always been a fundamental part of running an effective online gaming business. What has changed over the last couple of years is the impact of massively increased regulatory scrutiny by the UKGC, new data protection legislation such as GDPR and the recent multi-million-dollar fines of not having robust enough policies, systems and procedures in place.
Another recent relevant industry issue not specifically AML and Fraud related, but associated, has been under the scrutiny of the gaming affiliate networks and operator responsibilities in a general “compliance” context.
I think that there is a genuine industry concern that in 2018 we may see not just fines being levied, but licence suspensions could be on the cards and it may be a significant sacrificial lamb operator(s), to make the point.
SBC: Are the industry’s recent AML failures a social responsibility or operational matter. Is it essential to make a clear distinction when labelling AML procedures?
MW: Yes it is correct to make a distinction, there is a fine line between aggressively growing the business and encouraging people to gamble more from a social responsibility perspective, but also being able to stop potential money laundering or fraudulent activities. They are separate problems and require different policies, procedures, data and systems to solve.
For example, not being able to flag up a situation where a player who maybe earns £30k a year, is stealing money from their employer and spends £100’000 plus playing Bingo makes the industry look rather foolish.
Similarly, being able to distinguish between a fraudster and someone who is just in over their head and is a Problem Gambler has to be solved. So the issue is understanding who the player is, their social and economic background and having auditable automated systems in place to be able to help operationally.
SBC: As a digital payments specialist, how does Pay360 work with industry stakeholders to create AML and Fraud Prevention best practices?
MW: Our strategy over the last two years has been to work with gaming stakeholders to expand our pure payments processing and legacy fraud detection making available a wide range of over 60, third-party data assets. This creates a flexible decision-making platform called Optimise to enable the automation and audit of AML, Fraud, Bonus Abuse, Source of Funds and Problem Gambling issues.
SBC: What prevalent factors, values and dynamics, would you advise industry operators to research when planning AML procedures? Where do you feel industry stakeholders are currently blindsided?
MW: I think the industry suffers from the use of legacy backend platforms that do not make the automation, monitoring, triggering and investigating of potential breaches easy. Sadly this results in a significant expense in manual processes needed in place to execute the AML policy and procedure which can be error-prone.
It is important also to note that it’s not only the problem of legacy systems but also of internal legacy processes. Due to perhaps lack of support and flexibility to adapt to what is needed operators can be blindsided by the legacy tools, processes and data they use. To truly tackle the problem operators need to be open to new approaches and not try and squeeze a new process into the wrong structure.
As for researching, in my view the current situation will only get more difficult, the UK has been particularly aggressive, but other licencing authorities throughout the world will follow and soon. The issue outside of the UK and to be understood, is what can actually be done in particular countries especially with the availability of third-party data and information sources to help in ensuring the execution of AML etc procedures.
SBC: The industry’s AML concerns, take place during a period when consumers are more aware of their personal data and online profile. How does Pay360 create effective payment services/solutions that do not breach customer data concerns?
MW: Pay 360 has a wide range of online, physical payments, fraud & risk management solutions designed to ensure compliance with current and future data protection legislation. Our goal is to enable our customers to implement appropriate payment solutions that either minimise or in some cases remove the likelihood of breaching data protection laws entirely.
As an aside across other industry sectors we serve we have seen a massive focus in the last year of the impending GDPR legislation, surprisingly this does not seem to be taken as a real problem in the gaming sector, and that deadline is only a couple of months away on May 25th.
SBC: You are speaking on industry operational disciplines at the BOFCON 2018 conference. What do you want delegates to learn about effective AML procedures?
MW: To provide a discussion forum, which enables delegates to understand what is and importantly what is not possible to do to improve their AML, Fraud and Compliance needs. Using data and analytics-driven approaches to reduce the likelihood of breaches and avoid the resultant bad PR, brand damage, cost of fines and protecting gaming licences.
Marc Wood – Head of Gaming – Pay360