What the programme includes
- Risk assessment: which markets, payment methods, products and players carry more risk. It sets the thresholds for checks.
- KYC: the player's identity, age, address and payment method.
- Source of funds and source of wealth: where the money comes from and how the player earned it.
- Transaction monitoring: rules and alerts on deposits, bets and withdrawals.
- PEP and sanctions screening: politically exposed persons and sanctions lists, at registration and regularly after it.
- Enhanced due diligence (EDD): for high risk, for example large amounts or PEPs.
- Suspicious activity reports to the financial intelligence unit (FIU). The procedure and deadlines are set by the licence and the market's law.
Red flags
- Money without play: a deposit and a withdrawal with almost no bets. The casino is used as a transit account.
- Third-party payment methods: a card or wallet in someone else's name, many cards on one account.
- Splitting (structuring): a series of deposits just below the check threshold instead of one large one.
- Amounts that do not fit the profile: spending does not match what is known about the player's income.
One sign proves nothing, but it is a reason to check. Links between accounts are found the same way as with multi-accounting.
How it works at an operator
- Thresholds set in the policy, not by eye: the check does not depend on a manager's mood.
- Documents in advance: in the player's language and with a clear timeframe, so the first withdrawal does not get stuck.
- Withdrawal by the same method as the deposit, where possible.
- A manager guides a VIP player through the check personally, but the player is not told about a report to the FIU: in many markets that is expressly prohibited.
Common mistakes
- Checking only at withdrawal. The player learns about the check while waiting for their money. Request documents as the player approaches the threshold.
- The same rules for everyone. Without a risk assessment, checks get in the way of ordinary players and miss the real schemes.
- Bonuses on top of red flags. A player with an open payment dispute or risk signs gets no bonuses, and the exclusion is checked before every send.