Ray Wilson, AMLGS: Industry deserves praise for its reaction to a new normal

During the global lockdown, online gambling incumbents were served with a raft of instant compliance enforcements applied across the board. Ray Wilson, director of UK-based gambling compliance consultancy AMLGS, has taken the positives from the gambling sector’s response to the COVID-19 challenge.

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Impressive and encouraging – two words that we do not hear often when referring to gambling operators and their approach to compliance but, nonetheless, two words that AMLGS feels best describe how the majority of operators have handled the huge challenge that was handed to them when COVID-19 impacted the UK.

Unfortunately, as frequently witnessed by this industry, much of the hard work has been overshadowed by negative press and papers published by governing bodies that have minimal first-hand knowledge about gambling operations other than what they themselves have read.

Often this represents unfair criticism from those without the appropriate level of knowledge and expertise – but let’s focus on the positives.

Since the COVID challenge was laid out for operators, they have risen to it. To manage what could have been a huge increase in problem gambling and instead see almost no difference in the ‘post-pandemic’ period has been great to see – noting, of course, that we are not out of the woods yet.

Many of the operators we work with have put in strenuous effort to protect consumers and meet regulatory requirements. Our launch of the Responsible Gambling Risk Assessment (RGRA) has enabled operators to quickly assess their customer base and dynamically apply appropriate measures.

With several of our partners subject to regulatory compliance assessments, the RGRA – along with their Compliance Health Checks – allowed these companies to evidence their policies and procedures to the high standard required. We want to highlight some examples of how operators have risen to the Covid-19 challenge.

One of our partners went to extreme lengths to ensure that they applied strict measures to their customer base as soon as COVID-19 started to make an impact. They did not wait for regulatory guidance, they were proactive and in an attempt to apply the best protection possible began increasing interactions, customer reviews and ongoing monitoring was also increased across the entire customer base..

Another operator used this opportunity to reach out to their customer base in the form of welfare checks whilst simultaneously verifying Source of Wealth and affordability. This is something we do not hear enough of from the regulator or media outlets.  From our perspective it showed a clear determination to act on behalf of consumers and exceeded regulatory expectations for both Anti-Money Laundering and Safer Gambling.

For those of you that attended our webinar with the Malta Gaming Authority and global customer onboarding, identification and investigation provider HooYu or listened to our interviews with global partners Arctic Intelligence, you would likely have heard of our Responsible Gambling Risk Assessment and our Compliance Health Check mentioned.

Whilst the FATF identified a number of increased risks on AML/CTF/Counter Fraud regimes within regulator sectors across the globe,  we were encouraged to see that statistics show that they have not actually been realised within the gambling sector to a tangible extent. Largely due to the improvement in the industries accountability of the Compliance function.

Our RGRA has come at what appears to be just the right time for our operators. It is essentially a mandatory licensing requirement for all operators in emerging markets (which we anticipate will become a requirement across all of the major markets in the near future).

Operators will be expected to provide an accurate assessment of the risk to their customers from problem gambling, accompanied by the appropriate level of mitigation. This is exactly what our RGRA offers and which a number of partners have already undertaken.

The Health-Check is a compliance MOT and, of course, it is better to have this done before something goes wrong. Operators should not wait to be put on notice of an audit/assessment – conducting an annual health check delivers assurances that no skeletons will come out of the closet during an assessment.

At AMLGS, we conduct mock interviews using templates designed alongside regulators’ own auditors to get businesses ready for the environment that they will likely experience. AMLGS reviews every aspect of compliance procedures.

Better us identify a problem than the regulator, something which has proven beneficial for every operator that has utilised this service.

We work with many of those reading this along with other operators across Europe and again, we want to congratulate you them, all their efforts. In a time when the sector is faced with seemingly non-stop bombardment of legislative changes and negative media coverage. But as the industry begins to open up again since lockdown restrictions have been eased we believe it is our job as your partners to highlight the all good work across the industry that has been done during these unprecedented times.

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Ray Wilson – Director  – AML Global Solutions (AMLGS)