Purpose: Onboard players in a way that satisfies MGA requirements, German regulatory expectations and EU AMLD obligations, while minimising friction and false positives.

High-Level Stages:
– Registration & basic data capture (account creation)
– Identity verification (IDV) and age verification
– AML checks (sanctions, PEP, adverse media, internal lists)
– KYC profile creation (risk, geography, product preferences)
– Account activation with market-specific restrictions (e.g. German stake limits, deposit limits)

Detailed Steps:
1. Registration & Front-End Capture
– Player creates an account via web or mobile.
– Core data captured: name, DOB, address, email, phone, nationality, preferred currency, language, self-imposed limits (where required).
– Geo-IP and device fingerprint captured for jurisdiction routing and fraud detection.

2. Age & Jurisdiction Checks
– Age check based on date of birth and jurisdiction rules (e.g. 18+ universally, but additional checks for DE).
– Cross-check allowed markets: block registration from prohibited geographies.

3. Document-Based Identity Verification (IDV)
– Player is prompted to upload ID documents (passport, ID card, driving licence) depending on jurisdiction.
– Automated IDV checks: document validity, MRZ, security features, liveness detection, face-match.
– Manual review if automated checks fail or quality is low.

4. AML Screening
– Names screened against sanctions lists, PEP lists, internal blacklists and adverse media databases.
– Fuzzy matching and suppression rules tuned for gamer population (nicknames, short names).
– Hits flagged for analyst review with risk categories attached.

5. KYC Profile Creation
– Player record enriched with country risk, device risk, payment method risk, and product preferences (sports, casino, live casino, etc.).
– Initial risk category assigned (low/medium/high) with associated controls: limits, monitoring intensity, documentary requirements.

6. Activation & Controls
– Account partially or fully activated depending on verification status (e.g. temporary limits before full verification).
– Country-specific rules applied (e.g. mandatory deposit limits and reality checks for German market, self-exclusion checks against local registers such as OASIS where applicable).
– Ongoing monitoring hooks registered for transactions, behaviour and safer gambling indicators.

Controls:
– Clear KYC policy aligned to MGA and German requirements.
– Dual control for manual overrides (e.g. accepting low IDV quality).
– Logging of every verification attempt and result for audit.

Purpose: Determine that the funds used for gambling originate from legitimate, non-criminal sources, especially for higher spend or higher risk players.

When Triggered:
– Large deposits over defined thresholds (e.g. monthly cumulative deposit triggers).
– Rapid increase in deposit patterns.
– High-risk payment methods (certain e-wallets, third-party transfers).
– AML alert or safer gambling concern.

SOF Workflow:
– Automated detection of threshold breaches or unusual patterns.
– Request to player for supporting documentation (bank statements, payslips, transaction confirmations, salary slips, etc.).
– Verification of name match between payment instrument and player account.
– Cross-check deposits vs stated income and risk profile.
– Identification of red flags: third-party payments, cash-heavy deposits, multiple cards in different names.
– Decision: Accept, reject, request more info, or escalate to AML investigation.

Controls & Record-Keeping:
– Documented rationale for acceptance/rejection of SOF evidence.
– Clear alignment to internal risk-based thresholds.
– Audit-ready evidence package stored under the player’s AML/KYC case.

Purpose: Understand the origin of a player’s overall wealth (not just the immediate funds) where risk or regulatory expectations require deeper investigation.

Triggers:
– VIP status or very high spending behaviour.
– PEP or close associate of PEP.
– High-risk occupation or jurisdiction.
– Adverse media indicating potential criminal activity or corruption.

SOW Review Steps:
– Structured SOW questionnaire completed by player (employment history, business ownership, investments, inheritances, etc.).
– Collection of supporting evidence: tax returns, company filings, proof of property sales, portfolio statements.
– Cross-check information with OSINT and commercial data providers.
– Assessment of consistency: does declared wealth plausibly support gambling volume and patterns?
– Escalation to MLRO for high-risk cases or inconsistencies.

Outcomes:
– SOW accepted with conditions (e.g. limits, enhanced monitoring).
– SOW rejected → potential account restriction or offboarding.
– SAR/STR consideration in extreme cases.

Purpose: Assign a risk level to each player to drive decisions on monitoring, documentation and interventions.

Risk Inputs:
– Country of residence and play.
– Payment methods used and ownership of those methods.
– Deposit and withdrawal patterns.
– Products used (e.g. high-risk casino vs lower-risk sports betting).
– KYC findings (PEP, adverse media, SOF/SOW results).
– Behavioural risk (e.g. high late-night activity, volatile staking patterns).

Risk Categories:
– Low: Low deposit values, no red flags, strong IDV, standard jurisdiction.
– Medium: Moderate deposits, some risk factors (e.g. higher-risk method, complex employment).
– High: Significant spending, red flags, complex or opaque SOF/SOW, PEP, high-risk geography.

Controls:
– Risk category automatically drives periodic review cadence.
– Higher levels trigger stronger SOF/SOW and safer gambling checks.
– Model governance around the rating engine.

Purpose: Enrich player profiles with external and internal data to improve AML, fraud and safer gambling decisions.

Data Sources:
– Device fingerprinting & IP intelligence (VPN, proxy, TOR detection).
– Geo-IP risk scoring.
– Payment provider risk scores.
– External KYC/AML data providers.
– Internal data: previous accounts, cross-brand information, historic closures.

Workflow:
– Scheduled enrichment jobs (e.g. daily/weekly updates from providers).
– Real-time enrichment at key lifecycle points (registration, first deposit, high-value bets).
– Update to risk rating and flags based on new data.
– Automatic routing of high-risk updates to relevant teams (AML / Fraud / Safer Gambling).

Purpose: Provide a consistent response when players fail IDV/KYC, ensuring a balance between recovery and risk control.

Types of Failures:
– Document quality failure (blurry, cut-off, unreadable).
– Document mismatch (name/address inconsistent with account).
– Age verification failure.
– Sanctions/PEP occupation mismatch.
– Fraud suspicion or known compromised identities.

Next Steps:
– Request re-upload with guidelines (better light, full document, etc.).
– Additional document request (e.g. secondary ID, proof of address).
– Temporary restrictions (no withdrawals, capped deposits) while pending.
– Hard failure → account closure, refund decisions, internal blacklist, potentially AML/fraud investigation.

Controls:
– Clear maximum number of verification attempts.
– Escalation paths for borderline or vulnerable customers.

Purpose: Detect early signs that a player may be experiencing gambling-related harm, in line with responsible gambling expectations across EU and German frameworks.

Markers of Harm:
– Increasing deposit frequency and amounts.
– Chasing losses (e.g. high stakes after losses).
– Repeated late-night or long-session play.
– Multiple payment method changes.
– Declined deposits and repeated attempts.
– Player communications that indicate distress or financial difficulty.

Workflow:
– Behavioural rules and models run against transaction and session data.
– Markers aggregated into a harm score by player.
– Thresholds trigger alerts for manual review or auto-interventions (e.g. reality checks, temporary limits).

Purpose: Provide a consistent and scalable mechanism for identifying players at risk based on behavioural patterns.

Components:
– Data pipeline integrating session activity, deposits, withdrawals, game types and time-of-day.
– Rules engine or machine learning model scoring risk.
– Risk bands defining intervention intensity.

Outputs:
– Low risk → flag only, no immediate contact.
– Medium risk → soft interventions (emails, pop-ups, additional safer gambling information).
– High risk → mandatory interaction and review (phone call, chat intervention, possible restriction).

Purpose: Make sure that automated flags lead to structured, human-reviewed safer gambling decisions.

Review Steps:
– Analyst reviews player profile, recent activity, historical markers and previous contacts.
– Cross-check with AML and fraud flags to avoid narrow siloed view.
– Decide on appropriate level of interaction: email, in-chat message, phone call.
– Document findings and rationale in a standardised safer gambling case template.

Purpose: Engage with players in a supportive, non-judgmental way to reduce harm while remaining compliant and empathetic.

Steps:
– Prepare scripted guidance and training for frontline agents.
– Confirm identity and ensure a private channel (especially over the phone).
– Ask open questions about affordability, control, and impact.
– Offer tools: deposit limits, time-outs, self-exclusion, product blocks.
– Immediately apply restrictions if player indicates harm or distress.
– Follow-up plan set: review after X days/weeks.

Purpose: Ensure temporary measures are applied consistently, correctly and with appropriate follow-up.

Restrictions May Include:
– Deposit limits.
– Product limits (e.g. no casino, sports only).
– Time-based limits and session controls.
– Short-term time-outs.

Controls:
– Clear internal rules about who can apply which restrictions.
– Mandatory confirmation messages to players.
– Automatic expiry with mandatory re-review before lifting.

Purpose: Permanently prevent a player from participating where gambling is clearly causing harm or where required by law or regulator.

Steps:
– Player request or operator decision based on evidence of harm.
– Account(s) are closed and flagged as permanently excluded across all brands within the group where possible.
– Integrate with national self-exclusion schemes (e.g. OASIS in Germany, where applicable).
– Remove marketing consents and ensure no promotion is sent to excluded players.
– Provide signposting to support organisations.

Purpose: Demonstrate to regulators (MGA, German authorities, etc.) that safer gambling controls are effective and applied consistently.

Evidence Includes:
– Logs of markers of harm and automated flags.
– Case records of manual reviews and interactions.
– Records of applied restrictions and exclusions.
– Reports and KPIs on interventions, reversals, re-activation outcomes.
– Documentation of policies and updates after audits or regulatory feedback.

Purpose: Manage AML alerts arising from gambling-specific activity and payment flows.

Alert Types:
– Unusual deposit/withdrawal patterns.
– Chips or funds cycling behaviour (in and out with minimal play).
– Use of multiple payment instruments with different ownership markers.
– High-value or high-frequency bets inconsistent with profile.
– Cross-border activity between higher and lower risk jurisdictions.

Workflow:
– Automated alert generation based on scenarios tailored to gaming (e.g. short gameplay duration, near-instant withdrawals).
– Initial triage: remove false technical signals, group related alerts into cases.
– Enrich with KYC, gameplay history, payment data and device information.
– Route to AML analysts for investigation.

Purpose: Identify patterns indicative of money laundering or abuse of the gambling platform.

Patterns Monitored:
– In-and-out patterns with low betting volume (money in, minimal play, money out).
– Structured deposits just below thresholds.
– Frequent use of different cards or wallets.
– Collusive betting patterns (e.g. sports betting syndicates).
– Third-party funding patterns.

Controls:
– Periodic reviews of patterns and typologies (linked to model governance).
– Play-style analysis combined with financial behaviour.

Purpose: Ensure that gambling-related AML cases are documented to the same standard as financial services cases.

Case File Includes:
– All relevant gameplay history and financial transactions.
– Linkage to safer gambling and fraud findings (if any).
– SOF/SOW analysis where applicable.
– Internal communication records.
– Final decision and rationale, including SAR/STR actions.

Purpose: Define when AML-related suspicions require direct contact with the player.

Examples:
– Clarification on transaction purpose.
– Explanation for unusual deposit sources.
– Request for further documentation to support SOF/SOW.

Controls:
– Scripted guidance that avoids tipping-off.
– Joint approach with safer gambling where both issues overlap.

Purpose: Apply appropriate controls to customers classified as high AML risk.

Controls May Include:
– Lower deposit and loss limits.
– Manual review of withdrawals.
– Restriction of certain products or markets.
– Ongoing EDD requirements.
– Increased frequency of monitoring and periodic reviews.

Purpose: Ensure correct, timely AML reporting to FIUs and relevant gambling authorities.

Steps:
– Collation of case findings and supporting evidence.
– SAR/STR submission to the relevant FIU (e.g. FIU in Malta or player's country of residence, based on legal advice).
– Notification to gambling regulators where required (e.g. serious AML breaches, systemic failures).
– Recording all submissions, reference numbers and follow-up correspondence.

Purpose: Detect and handle abuse of welcome bonuses, reload offers and promotions.

Indicators:
– Multiple accounts using the same device or IP claiming the same bonus.
– Very short-term play focused solely on clearing wagering requirements.
– Coordinated betting patterns across related accounts.

Steps:
– Automated detection of suspicious bonus use patterns.
– Investigation across devices, IPs, payment methods and shared data points.
– Removal of bonus eligibility, account closure or winnings confiscation according to T&Cs and legal review.

Purpose: Prevent a single individual from operating multiple accounts to bypass limits, exploit bonuses or commit fraud.

Signals:
– Shared device or browser fingerprint.
– Shared payment instruments.
– Similar registration data with small changes (name variants, addresses, email typos).

Response:
– Link accounts into a single cluster for review.
– Determine intent: bonus abuse, fraud, collusion or legitimate household use.
– Apply sanctions ranging from limits up to permanent exclusion.

Purpose: Assess the risk associated with each access point to help drive AML, fraud and RG decisions.

Components:
– Detection of VPNs, proxies, TOR and emulators.
– Geo-location mismatch between IP and declared address.
– IP sharing across many accounts in a short period.

Outcomes:
– Additional verification steps.
– Blocking access from high-risk IP ranges.
– Referral to AML/fraud teams for correlating risk.

Purpose: Detect and respond to card and payment fraud within the gambling platform.

Stages:
– Pre-deposit checks via payment risk tools.
– Real-time rules for transaction anomalies (amount, velocity, issuer mismatch).
– Chargeback monitoring and investigation.
– Money flows analysis: deposit, bet, withdrawal pattern in relation to fraud claims.

Outcomes:
– Account restrictions or closure.
– Collaboration with payment providers and card schemes.
– Integration with AML and safer gambling where patterns overlap.

Purpose: Funnel suspicious cases from fraud into AML and compliance when legal thresholds are met.

Steps:
– Fraud team flags suspicious behaviour with potential criminal context.
– Handover to AML for assessment under AML frameworks.
– Joint case handling: fraud loss recovery vs AML reporting obligations.
– Decision on SAR/STR and customer treatment.

Purpose: Ensure only players who pass stringent AML, SOF/SOW and safer gambling assessments enter VIP schemes.

Criteria:
– Sustained play and deposits over time (not short-term spikes only).
– Clean fraud and AML history.
– Completed and robust KYC, SOF and, where necessary, SOW checks.
– Balanced view of RG risk (high-risk behaviour may disqualify a player).

Purpose: Apply higher scrutiny to high-value players, especially for cross-border and high-risk profiles.

EDD Elements:
– Detailed SOF/SOW review with documentation.
– Adverse media and OSINT deep-dive.
– Additional checks on business ownership, political connections, and geographic risk.
– Formal MLRO sign-off before or during VIP upgrade.

Purpose: Ensure VIP treatment does not compromise safer gambling obligations.

Controls:
– Higher frequency of RG reviews for VIPs.
– Closer monitoring of deposits, losses, session length and behaviours.
– Clear separation between VIP incentives and RG decision-making (RG team independence).

Purpose: Regularly reassess VIP players from both an AML and RG perspective.

Review Includes:
– Updated SOF/SOW where behaviour has changed significantly.
– Review of new adverse media or sanctions alerts.
– Assessment of RG interventions, if any, and their outcomes.
– Continued suitability for VIP status or decision to downgrade / exit.