European Gaming Lawyer magazine Spring 2014

RESPONSIBILITY Player registration B2C PLATFORM PARTNERS B2B NETWORK PROVIDER 90% 100% 50% 10% A player registers on a website and submits required player details (name, address, bank account). Player vetting processes are carried out at this stage. Age veriﬁcation Information security and sharing Facilitating game play Responsible gaming Payment system Age veriﬁcation checks are completed based upon information provided by the player. Access to sensitive functionality such as player information is appropriately controlled. Contracts between platform partners and network providers must contain suﬃcient information sharing provisions to identify responsibility and enable the required action for any suspected money laundering, terrorist ﬁnancing, collusion, cheating, underage and problem gambling incident. Complaints and dispute resolution Cheating / collusion detection Money laundering N/A 50% Access to sensitive functionality in facilitating game play is appropriately controlled. Contracts between platform partners and network providers must contain suﬃcient information sharing provisions to identify responsibility and enable the required action for any suspected money laundering, terrorist ﬁnancing, collusion, cheating, underage and problem gambling incident. N/A 100% 80% 20% The game is fair and played according to game rules. This would include making assurance of all RNG operations where appropriate. This also includes the administration of player table allocation, player pairings and player locations. Adequate controls that are required in order to maintain the overall integrity of the game include suﬃcient controls over risks of unsuitable ownership and criminal inﬂuence, risks of employees inﬂuencing gameplay and adequate game testing. Primary responsibility for handling any problem gambling issues such as direct contact with the player, providing spend limits, self-exclusion and identifying problem gamblers. The platform partner can see some activity that may indicate problem gambling including all gambling activity for which it is fully responsible. The platform partner can also see problematic account/wallet activity e.g. a customer frequently changing credit/debit cards or increasing ﬁnancial limits. The platform partner cannot see activity within the game, but can see movement of funds between the general account/ wallet. To get the full picture the network provider is required to communicate to the platform partner any instances of suspected problem gambling behavior within the gameplay. 80% During the registration process payment details are provided by a player (e.g. visa card, mastercard) who deposits money into the main gambling account. Protection of player funds The network provider is only given a player identity code number when a player is sent to the network. Whilst the network provider does not have direct contact with a player nor know what other gambling the player participates in, the network provider is responsible for identifying player patterns within gameplay that could indicate a problem gambler and then reporting these to the platform partner. The network provider is also responsible for ensuring that they have adequate programs in place to identify reckless or irresponsible play, including all reasonable security norms e.g. spotting collusion / chip dumping. 20% Although the network provider does not have direct contact with the player, they are responsible for assisting the platform partner with the complaints / disputes process and providing all reasonable information on gameplay to enable dispute resolution. 50% 50% 80% 20% 10% 90% 20% 80% In order to ensure adequate player protection in the event of a platform partner suﬀering ﬁnancial distress, the platform partner may be required by the network provider to maintain an ongoing security deposit with the network provider as an eﬀective control against non-payment. The platform partner will generally handle any ﬁrst line complaints / disputes from the player, but may have to obtain information from the network provider if it relates to speciﬁc in-game transactions. The platform partner will hold the personal information on their players. Whilst the only information that will normally be transferred to the network provider is the user name, IP address and fund amount, the platform partner is required to respond to all reasonable requests for further information from the network provider when cheating or collusion is suspected. The platform partner can detect aspects under their control so may identify suspicions based on the player due diligence checks or gambling account transactions (e.g. funding gambling account from one source but withdrawing to another). The platform partner must comply with the money laundering requirements of the jurisdiction that they are licensed in. The network provider is required to set the level of security deposit required from each platform partner in order to ensure adequate player protection. Any such security deposits must be maintained separately from the network provider’s own funds and may only be used in the event of default by the relevant platform partner. Although the network provider does not have direct contact with the player, they are responsible for assi

European Gaming Lawyer magazine Spring 2014 | Page 27