By Bob Waller<\/strong><\/p>\nI find it baffling that operations and marketing teams (as well as some more senior management staffers), place the blame for low sign up and\/or retention rates firmly at the door of compliance, payments, fraud and AML teams who advise on and implement the various processes by which these teams look to mitigate threats to the business.<\/p>\n
When you consider that apart from cowboy and unlicensed operators who choose not to adhere to the prevailing legal and regulatory processes, most licensed operators have a similar KYC, CDD, EDD and payments frameworks that apply to customers. This means that albeit the methods for achieving passes in these areas may be different, based on the product used, the detail required is the same. Consequently, gamblers will be used to the hoops they are required to jump through as they move between operators and in general expect to be asked to jump through them in that same way we all expect to be asked to provide our personal and payment data when shopping online whether it be with Amazon, eBay or Tesco.![\"\"](\"https:\/\/gaming-awards.com\/NEWS\/wp-content\/uploads\/2020\/12\/Marketing-300x200.jpg\")
<\/p>\n
As these processes are not unique to the operator concerned, the dilution of perfectly reasonable compliance and fraud\/ML mitigation processes, many of which are required by law and\/or regulation, does not and will never increase or decrease for that matter, onboarding rates. This is because most customers are not actually impacted by these measures until after they have signed-up, deposited, played and then hit a ML threshold. Notwithstanding the UK age requirement at sign up.<\/p>\n
It is an established fact that online gamblers have little brand loyalty (most hold an average of 3 to 5 accounts). They are superstitious and value driven and are attracted by the bonus and promotional offers that best suit them. This is a group of people who will leave one operator for another on a whim and if asked to explain, blame the first thing that comes to mind for this change, \u2018I don\u2019t want to answer any more questions\u2019, \u2018I\u2019m not allowed to withdraw to an account different to the one I deposited from\u2019; anything except the real reason.<\/p>\n
To be completely even handed, there are times when a withdrawal or gaming may be delayed because of the aforementioned hoops in play, yet these will be required in order to satisfy legal or regulatory reasons and to protect the customer and the business. As mentioned already, not anything a regular gambler online hasn\u2019t experienced before with other operators.<\/p>\n
The reasons I believe are founded in a few camps.<\/p>\n
*The first being borne of the perception of luck and when a losing streak occurs, the gambler wants out to greener pastures where they are convinced their luck will improve. In general, the operator will see them again. Their activity is generally routine and not outstanding and in reality, they are the gamblers who maintain the ongoing business for operators along with genuine VIP gamblers who are a whole other issue.<\/p>\n
*Another is the gambler who only stays when they are getting something for nothing, first time bonus, new season bonus, first time casino bonus, new game bonus, anything that gives them the chance to play for free. If and when they exhaust these freebies, ask for and get no more, they\u2019re off to find another operator they can squeeze.<\/p>\n
![\"\"](\"https:\/\/gaming-awards.com\/NEWS\/wp-content\/uploads\/2020\/12\/arm-wrestle-300x250.jpg\")
* The next are those unfortunate gamblers who have a problem and cannot stop themselves, no matter how bad their situation becomes. These are the customers that may pass through initial KYC and CDD but rarely stand up to an EDD check and once their ability to afford their gambling levels is questioned, drop off the platform to find easier gambling opportunities. This group has increased several-fold over the last 18 months due to greater media coverage of political and public debate about problem gambling, leading to a better understanding and awareness of the problem by all, including those in trouble and more recently COVID.<\/p>\n
* The last group are fraudsters and by this I include anyone who are serial bonus abusers, those using false identities, compromised payment data, arbitrage bettors sometimes using group funds for the big outcomes and the constant money launderers in their many and complex forms. In many cases, this is the real problem group for anyone in the compliance, payments, fraud and AML teams because in many cases the gamblers from this group can, for quite a while, appear to be good customers and even potential VIPs. So, when one of these teams start to enquire as to the veracity of the gambler, their data and activity, operations and marketing get quite annoyed. This false premise is also built upon the fact that many of this group will send in proof of ID before even being asked for it, reassuring marketing and operations of their genuine intentions.<\/p>\n
This last group are the cause of many a dispute between the teams and promulgates the divide that separates them.<\/p>\n
It is unfortunate that due to many reasons surrounding monitoring, investigations and submissions of SARs (the lack of any constructive response following the submission of a SAR isn\u2019t unique to gaming operators and it doesn\u2019t help anyone for everything to be held in limbo), many of these investigations do not arrive at a conclusive answer, the person in question goes dark. In that I mean, they use any number of strategies to avoid detection or identification or to just keep everything too blurred to arrive at a conclusion. Self-exclusion, abandonment of the gaming account and even complaints to the regulator or more often, an independent paid complaint resolution service.<\/p>\n
To improve retention rates and as a result, onboarding rates through word of mouth and favourable media coverage, both social and within the associated press, operators should strive to employ excellent PSP services who deliver a secure and stable service for customers, stable gaming platforms that encompass an accurate audit trail of internal and external activity and provide the necessary data and functionality to enable teams to monitor customer activity and communication and eliminate all the technical faults that really do make a difference to the genuine gambler. I\u2019m sure if you were to ask any operator for the top five complaints from their customers, in there would be, \u2018I can\u2019t deposit\/withdraw or quickly enough\u2019. \u2018I wasn\u2019t able to get my bet on\/stake that spin\/play that game because the system froze\u2019. \u2018The odds were incorrect\u2019, \u2018I wasn\u2019t able to access the website\u2019 etcetera, etcetera. Not many would include reference to confirming their identity, address or payment instrument.<\/p>\n
The requirements to jump through hoops set by compliance, payments, fraud and AML teams are complained about mostly by those groups outlined above who are not genuine gamblers but those who, whilst they may bring in money from time to time, do not represent real profitability due to the cost of time and effort spent in attempting to defend against them, identifying them and reporting them. The reason being these checks highlight they are usually not who they say they are or they shouldn\u2019t be gambling or are looking to defraud the operator or someone else in some way.<\/p>\n
The gamblers who are bonus hunters or offer no commercial long-term value to the company are the ones who generally complain the loudest and take the most time and resource to manage once they get through.<\/p>\n
Yes, a few gamblers will feel some questions intrusive, especially considering no one from PC World asks you where you got the funds to buy that \u00a33,000 television or Churchill ask if you really can afford the \u00a3250 monthly payments for your car insurance and would you please prove it in either instance! But in the main, knowing these hoops are the same for each operator, merely a different colour, genuine gambling customers accept it as part and parcel of their gambling experience.<\/p>\n
I contend, after all of the above, that nothing put in place by compliance, payments, fraud and AML teams really prevents gamblers from staying with an operator or joining them. Let\u2019s face it, very few people read the terms and conditions before ticking the box to confirm their agreement with and acceptance of them, so how could these processes impact the number of new registrations with the exception of bad press, be it word of mouth or otherwise.<\/p>\n
These teams are there to protect the business, its senior officers and its genuine customers, not harm or restrict it. In fact, some of the most commercially successful operators in the world (William Hill, GVC, Kindred) are using compliance and player safety as a unique selling proposition and customers seem to be responding positively. In taking this approach they attract more genuine players with greater player lifetime values and keep out those that are simply a commercial and financial drain on the company. A bonus ring of 20 players who are successfully onboarded but only deposit and play the minimum and only when the bonus is in their favour will always be up on the company. They will improve the acquisition rates but will result in a negative hit on the bottom line. These operators have learnt the hard way being hit with some of the largest fines meted out, which in turn has had a reputational impact across the world.<\/p>\n
It is a great shame that many whose role is within the compliance, payments, fraud and AML fields are almost unwanted but required for the business to operate and retain the licence and so are tolerated, rather than cherished by the employers they serve.
\nAcross many industries, sales and marketing teams, although not so much operations teams, are venerated and rewarded for successes with some companies taking the top sales and marketing staff away on lavish trips and paying large bonuses to them.<\/p>\n
In contrast, compliance, payments, fraud and AML teams are queried and at times asked to justify the need to suspend, close and report accounts and even fraud groups. They are rarely congratulated, let alone rewarded and this is due to the perceived loss of income their actions result in. Whilst some may think it so, this is not a case of sour grapes. Rather, it is time to take a fresh look at the work the compliance, payments, fraud and AML teams undertake to protect the business, understand it fully and show them they are appreciated by supporting their actions accordingly.<\/p>\n
ABOUT BOB WALLER:<\/strong><\/p>\nI\u2019m known as Bob Waller and I am a Money Laundering Reporting Officer and Anti-Money Laundering Compliance Officer for an online gaming company. I enjoy the role I have as a follow on from my years as a police officer, working to safeguard others using common sense and discretion. This I learnt on the front line of policing and during my 13 years combating fraud and money laundering in the gaming industry to create a balance in what I do day to day. I was born in East London, brought up and educated in the borough of Greenwich and am married with 2 grown sons.<\/p>\n
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A comment on experiences within online gambling. A personal view By Bob Waller I find it baffling that operations and marketing teams (as well as some more senior management staffers), place the blame for low sign up and\/or retention rates firmly at the door of compliance, payments, fraud and AML teams who advise on and […]<\/p>\n","protected":false},"author":3,"featured_media":44034,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[11,8,132],"tags":[],"class_list":["post-44031","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-headlines","category-latest","category-sportsbetting"],"yoast_head":"\n
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