Date post: | 05-Dec-2014 |
Category: |
Economy & Finance |
Upload: | brock55 |
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On-line Gaming eLottery – eBingo – eCasino - ePoker
Bryon Hodgkin – Director Operational Compliance
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How did we build a viable,
secure gaming environment
on the Internet?
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Time Line
•PlayNow - eLottery
•$70/week 2004
•PlayNow - eBingo
•$70/week 2008
•PlayNow - eCasino
•$9999/week 2010
•PlayNow - ePoker
•$9999/week 2011
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Internal Stakeholders:
Business
Security
Finance
Consumer Services
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4 Business Sectors
Registration
Deposits
Game Play
Withdrawals
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eGaming Management System
PAM (Player Management
System)
Lottery Bingo Casino
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Registration “Know your Player”
Satisfy:
– Location of Player
– Age of Player
– Qualify to Play
Expedient Process
Player Agreement
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Registration Process
1 player = 1 account Verification
IP address verification (BC)
Self-exclusion verification
Player provides credit card information
Address / DOB and credit card verification (soft hit)
Create new player account in the PAM
End of automated process Verification not passed
Player provides identification information
If resolved (Manual Process)
Send a confirmation letter
Create suspended account in the PAM
Outsourced
Third Party
PAM
PAM
PAM
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Deposit
1 Player = 1 Account
1 credit card per account
Transactions validated by a third party
Deposit limit ($9999/week)
No prepaid credit card
48 hour hold on all withdrawal request
Daily follow-up
Player set daily limits
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Deposit Process
1. Credit card 2. Interac Online
Customer request
Payment validation
New Credit card?
No
Update PAM
Yes
Deposit limit $9999 / week
Validation process
Name/Address
Third Party
PAM
PAM
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Game Play
eCasino
eBingo
Player
eLottery
Review Daily
Reports –
Win/Loss
Monitor Games
Payout
Listen to Players
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Withdrawals
Verified Win
Meet Fintrac Reporting
Leverage Marketing
Player Experience
3 Levels of Withdrawals
> $100,000
> $10,000
> $1,000
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Withdrawal Process
>$10,000 (24 h period)
Verify bank account Fintrac report
Payout via EFT
In person review (cheque payment)
Play Verified Verify collection of occupation
Request
>$100,000 (24 h period)
Bank account Information Collected/Verified
Withdrawal amount Collect occupation (Fintrac)
* Note Fintrac Reporting does not apply to Lottery
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The Next Step – Add ePoker
eCasino
eLottery
eBingo
ePoker
Player
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What we did
August 2009; beginning of the project
Estimated the risk
Participated in meetings/conference calls between jurisdictions and our partners
Developed operational policies and procedures
Built and organizational structure for the ePoker business, finance, & security departments
Established the roles and responsibilities for internal and external partners
Selling point: It is a safe & secure poker network
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Create a strong partnership…Canadian Poker Network
ePoker
Player Account Manager
eCasino
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Security & Surveillance
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Canadian Poker Network
Game play
Deposit
Withdrawal
No cash-money allowed (including pre-paid card)
Credit card transaction verified
Credit card & Interact online validation
$9,999 weekly threshold
1 credit card per account
Only by EFT
All request >$1,000 will be investigated
48 hours pending for all request
Withdrawal transactions >$10,000 will be reported to Fintrac
1 player = 1 account
Buy-in limit ($3,000 per day)
Daily verification; win / loss and game activities
Suspicious transaction will be reported to Fintrac
Registration
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Canadian Poker Network -
Player’s Responsibilities
Not allowed to collude with another player
Not allowed to lose money deliberately to another player
May not deliberately accept money from other players
Not allowed to chat about their cards or game play
Not allowed to give other players advice on how to play
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Fraud and Collusion
Risk Evaluation:
Common types of poker room fraud
– Collusion between 2 or more players (Best Hand, Squeeze Play, Soft Play)
– “Chip dumping” (moving funds)
Countermeasures:
– The surveillance of the poker room is conducted by G2, they are responsible for identifying possible integrity issues of the game
– Partnership between BCLC, LQ, and G2
– Buy-in limit ($3000/day)
– Win/loss report (+/-20%)
– All player complaints will be investigated
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Fraud
Risk Evaluation:
General Risks
– Fraudsters moving funds
– Stolen credit card
– Money laundering
– Identity theft (player account)
– Bonus abuse
Countermeasures:
– Zero tolerance policy
– 1 player = 1 account
– 1 credit card per account
– Deposit limit ($9999/wk)
– Secure transactions
– No prepaid credit cards
– Transactions validated by a third party
– 1 method for withdrawal (EFT)
– 48 hours hold on all withdrawal requests
– Fintrac reports for $10K + transactions and suspicious transactions
– Daily follow-up (4 business sectors)
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Common SFTP Server
BC
LC SFTP
Server
Canadian Poker Network
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ePoker Withdrawals
Verified Win
48 hour review period if required
Meet Fintrac Reporting
Leverage Marketing
Player Experience
3 Levels of Withdrawals
> $100,000
> $10,000
> $1,000
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ePoker Withdrawal Process
>$10,000 (24 h period)
Verify bank account Fintrac report
Payout via EFT
In person review (cheque payment)
Play Verified Verify collection of occupation
Request
>$100,000 (24 h period)
Bank account Information Collected/Verified
Withdrawal amount Collect occupation (Fintrac)
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Money Laundering and Fintrac
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Any Questions?