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Risk and Fraud Monitoring
Comprehensive Guide to Risk and Fraud Monitoring
Step 1: Overview
The Payments and Risk team monitors incoming and outgoing transactions to ensure optimal traffic, detect irregular activity, and maintain clean financial operations.
Step 2: Monitor Credit Card Chargeback Rates
High chargeback rates can have significant implications:
- Placement on scheme mitigation programs: High chargeback rates may trigger additional monitoring by card networks.
- Financial penalties: VISA and Mastercard fines can range from $25,000 to $225,000 per Merchant ID (MID).
- Increased processing costs: Elevated chargeback rates lead to higher fees.
- Loss of processing privileges: Excessive chargebacks can result in termination of credit card payment options.
Step 3: Detect Credit Card Fraud
Be vigilant for common fraud techniques:
- Identity theft: Using stolen information to create accounts or make transactions.
- Card testing: Small transactions to validate stolen card data.
- Account takeover: Unauthorized use of legitimate accounts for fraud.
- Friendly chargebacks: Disputing legitimate transactions post-betting.
Identify red flags in deposit patterns:
- Rapid succession of small deposits.
- Unusual timing (odd hours).
- Geographic mismatches or inconsistent amounts.
- Multiple cards or frequent payment method changes.
- Sudden large deposits or repeated failed attempts.
Step 4: Monitor Bonus Fraud
Bonus fraud undermines promotional efforts, creating financial risk and damaging the brand reputation.
Types of bonus fraud:
- Multi-accounting: Claiming bonuses multiple times with fake accounts.
- Bonus abuse: Exploiting terms for financial gain.
- Collusion: Coordinated play to manipulate bonus outcomes.
- Bonus hunting: Systematic exploitation across platforms.
- Identity fraud: Using fake or stolen identities for multiple claims.
Detection and mitigation strategies:
- Watch for unusual bonus claims or usage patterns.
- Identify shared IPs, devices, or payment methods across accounts.
- Monitor high bonus conversion rates and suspicious betting behaviors.
- Exclude high RTP, low variance games from bonus eligibility.
Step 5: Detect Affiliate Fraud
Affiliate fraud occurs when affiliates manipulate deposit activities for personal gain. Common tactics include:
- Self-depositing: Affiliates creating fake accounts to earn commissions.
- Incentivized deposits: Offering players bonuses outside the casino’s terms.
- Deposit abuse: Encouraging multiple small deposits to exploit bonus systems.
- Misattribution: Using techniques like cookie stuffing to claim undue credit.
Mitigation involves collaboration between payments and affiliate teams, analyzing deposit patterns, user behavior, and cross-referencing affiliate data.
Risk and Compliance Procedures
Verify the Match
- Confirm the accuracy of the match by comparing the player’s details (name, date of birth, nationality, etc.) with the PEP or sanction list information.
- Ensure it’s not a false positive, as name similarities can often trigger alerts.
Categorize the Match
- If PEP only:
- A PEP designation does not prohibit activity but requires enhanced due diligence (EDD) due to higher money laundering risk.
- Proceed with EDD measures such as:
- Identifying the source of funds and wealth.
- Monitoring transactions more closely.
- If sanctioned:
- Transactions or account activity must immediately cease.
- In most jurisdictions, engaging in financial transactions with sanctioned individuals is illegal.
Freeze the Account (If Sanctioned)
- Block or freeze funds immediately to ensure compliance with legal obligations.
- Prevent any withdrawal, transfer, or use of the account until further action is decided.
Report to Authorities
- File a Suspicious Activity Report (SAR):
- Report the case to your jurisdiction’s Financial Intelligence Unit (FIU) or the relevant authority (e.g., OFAC in the U.S., or the EU Sanctions Authority).
- Notify regulators and your financial partners if required by law.
Internal Review
- Assess whether your due diligence and KYC processes properly identified this match during onboarding.
- Strengthen screening measures if necessary.
Take Additional Actions
- If legal, consult with your AML officer or legal team about the specific jurisdiction’s requirements for handling sanctioned individuals or PEPs.
- Retain all evidence, communication, and reports related to the match.
Documentation
- Keep detailed records of actions taken, including:
- Match verification.
- Communications with authorities.
- Account activity before the freeze.