November 13, 2023 • 19 mins
KYC is critical for gaming companies, to keep themselves and their players safe. With the boom in online gaming, regulators worldwide are updating and issuing guidance around player onboarding and responsible gaming. In this episode, Adam Doyle, Head of Gaming for the LexisNexis® RiskNarrative™ platform, discusses the meticulous process of validating players and safeguarding them against issues like underage gambling or money laundering. He shares the subtle warning signs that hint towards troubling gambling habits and the protocols operators can employ to make informed decisions. Listen and learn how tracking a customer's typical activity pattern can help spot anomalies and unusual behaviors.
For more information on the KYC requirements for gambling operators, visit risk.lexisnexis.com/global/en/gaming-gambling. For more information on the RiskNarrative platform, visit risk.lexisnexis.com/global/en/products/risknarrative
DISCLAIMER: The information provided in this podcast is for informational purposes only and is not intended to and shall not be used as legal advice. The views and opinions expressed in this podcast are solely those of the speakers and do not necessarily reflect the views or positions of LexisNexis Risk Solutions. LexisNexis Risk Solutions does not warrant that the information provided in this podcast is accurate or error-free.
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:12):
Hi everyone, welcome back to the Rig Tech Pulse.
You're here with Julia, andtoday I'm joined by Adam Doyle,
who is head of gambling for theLexus Nexus risk narrative
platform.
We're here to talk about onlinegaming, everything, kyc, your
responsible gaming, what thereis requirements are.
So, adam, thank you so much forjoining me on the Rig Tech
Pulse today.
Speaker 2 (00:30):
Thanks, julia, nice to meet you.
Speaker 1 (00:32):
I wondered if you could give us a quick overview
of maybe a little bit about yourrole, what your
responsibilities are, what kindof operators you work with, and
then we can dive into some ofthose KYC points.
Speaker 2 (00:42):
Yeah, perfect.
So I came over from the tunenarrative business just over two
years ago.
I was part of the managementteam there, but also I had been
looking after the gamblingvertical.
So I've been working in thesort of identity management
space for about 15 years now andfor a lot of that time as well
as sort of supporting andmanagement teams, a lot of it
(01:03):
has had a key focus on thegambling businesses.
I think over the years I'veprobably been involved in about
400 gambling operatorscontracting wise, and that's on
a global level.
So I'm hoping what I reallyhave been doing over the last
two years with Lexus Nexus isit's supporting the sales team
from around the globe andhelping them go through the
(01:25):
process of initial conversationswith the operators and then
closing the contracts.
Speaker 1 (01:31):
So you're a busy man.
Speaker 2 (01:34):
Yes, my wife enjoys the six o'clock wake-ups and the
11 o'clock still on calls withthe US and the the D'Atom teams.
Speaker 1 (01:42):
The joys of global business.
I wonder if we start ourconversation today?
Obviously, kyc.
You know your customer, anybody.
You're familiar with our work.
We work very closely withfinancial institutions, so KYC
is a very familiar term.
What does it mean specificallywhen you were talking about
gaming and gambling operators?
I think specifically from anonline perspective, because
that's where we really seem tobe focusing the conversation
(02:05):
today.
Speaker 2 (02:06):
Yeah, exactly, I think.
If you just quickly look at theland-based bit, it's very
simple, isn't it?
If you go into any casinos, theexpect to show you whether it's
a drive-in license or passport,and that's very simple.
In the unseen environment itbecomes very challenging.
But if you look at things likethe UK GC, they specifically say
that an operator, as and when aplayer registers, at that point
(02:27):
they have to validate theirplayer, and what they're looking
to do is the initial one isthey're ensuring that players
are over the relevant age.
So in the UK it's making surethat someone's 18 and above.
The expectations that they puton the operator is that they
have to validate to name,address and date a birth and,
like I said, the main reason forthat is it's ensuring it's
(02:48):
protecting players under the ageof 18.
On top of that as well, whatthey're also doing is the UK GC
are ensuring that the protectingplayers are protecting
operators against money laundersand also sort of politely
exposed people.
So we're making sure that ourPrime Minister is not spending
the UK's budget on his gamblinghabit.
And then, further down the line, what they're really doing is
(03:10):
they're trying to ensure thatthe protecting players that
can't afford to gamble, toensure that they're not gambling
above their means.
So they're probably the corefocus is that they're really
looking to for an operator tocarry out.
Speaker 1 (03:23):
And that's that piece around this sort of responsible
gaming and player safety.
I mean, is there?
I know that you can't sharespecific examples, but what
would be a red flag when itcomes to somebody maybe gaming
more than they should be able to?
How does a gaming operator getthat information to make that
decision?
Speaker 2 (03:42):
Yeah, so there is a consultation document that's
going out at the moment whichshould hopefully be a lot more
clarification by the end of thisyear, but a lot of it I think,
if we look at a lot of it, iscommon sense.
So where there has been somefines, an operator, you know
they have to take accountabilityin the sense that they've never
seen this player before They'veregistered and within six hours
(04:04):
they've spent over £100,000.
You know, that's quite a bit.
I'm going to say that thatshouldn't be allowed, especially
when no due diligence has beencarried out.
So some of the measures thathave been put in place is if
someone has spent more than £100, a couple of £100 within a
certain time, or an annualamount or that's a lower level
where they'd expect you to seeright, has this person got any
(04:26):
CCJs?
Have they got any outstandingpayments?
And then when people have spentyou know, maybe, let's say the
number that's being used is£2,000 within a year, Once that
carries out, they're expectingpeople to really sort of have a
look at whether it's financialinformation out there.
So Kato is a system that'scurrently well previously been
used and looking to be broughtback.
(04:47):
We do have a supplier thathelps us look and get loan
outcome information, so that'svery good because a lot of the
people that are vulnerable haveprobably been taken out loans,
so that's very powerful.
And then the other way that theUK GC is suggesting is looking
at open banking information.
But again, where you can haveopen banking information?
I'm sure, like everyone wholistens to this, they probably
(05:08):
have a food account.
Me and my wife, we have a foodaccount, several hundred pounds
going into that a month, and allyou're seeing is on the 15th
they're having this into it.
You're not seeing anything else.
So going down that route is notreally allowing you to see any
vulnerable activities.
Speaker 1 (05:24):
So it's kind of a combination of various different
factors and also that commonsense it triggers.
Yeah, yeah.
Speaker 2 (05:29):
It's very much triggers.
If you once you you know oncesomeone's been on a website for
a while, you can see what theirtypical pattern is.
For example, me, on a Saturday,I might bet on horse racing and
football, and I'm typicallyspending £50 on a weekend,
whereas if one weekend I'm nowspending a thousand and I'm
betting on the next availablebet, whether it's horse racing,
(05:50):
football, ping pong, tennis,that type of stuff.
That's another good indicatorthat this probably person's
either one their accounts beingtaken over or two they're now
potentially subring from anaddiction issue.
Speaker 1 (06:01):
Can't you, can't you.
And so I suppose there's a lotto consider in terms of
obviously carrying out the rightchecks, ensuring that player
safety, ensuring thatresponsible gaming is there.
When you speak to complianceofficers at these gaming firms
and you know, when you go in andhave these initial discussions
with them, what is it that youthink?
What do they really strugglewith?
(06:21):
And so that's keeping them upat night.
Speaker 2 (06:24):
The things that you really see now is especially
let's call it these tier oneoperators.
The amount of transactions thatthey're going through.
It's crazy.
We're talking hundreds ofthousands of transactions a day.
What we see with some operatorsis they're either using old
technology which, as theirvolumes have grown and as
they've grown as a business,they sticky tape and blue tack
(06:45):
something together to try andhelp them, which really it
normally takes about five peopleto pull the report and seven
days.
So the struggle is it's stayingon top of that as and when it's
happening.
That's something really whereLexus Nexus is a business where
we're really helping peoplebecause we have the ability to
monitor people as and when thetransactions are going through.
(07:07):
So when a flag is hit, we canfreeze an account, we can flag
it to the compliance team, sothat's something that really
gives them peace of mind thatthey're not 24 hours but after
the incident has happened.
So that's really where we tryand give a compliance person
peace of mind is that they knowas and when someone hits a
threshold that they deemsomething needs to happen.
(07:29):
Our system makes sure thathappens straight away.
Speaker 1 (07:33):
And we were talking before in earlier conversations
outside of this podcast.
You mentioned there was aphrase about the single view of
a player.
Can you maybe explain that,because that's quite an
interesting concept.
Speaker 2 (07:43):
Yeah.
So the one point that the UK GCreally took about is having
this single view of the customer.
Unfortunately, at the moment,what you have in the gambling
space is sharing data issomething that's not really
there, because it's a lack oftrust.
Operators believe that if theyflag that someone's hit this
level, people will just stopputting their VIPs on there.
(08:03):
So when sort of VIP tries tocome on there, they'll be
flagged is don't touch them.
So when we talk about a singleview, we're talking about we're
talking to get a single view ofthe operator, so let's say, of
Adam Doe.
So what?
We have the ability with allthe different products that we
have a Lexus Nexus we have theability from point of
registration so we can look atdevices of this person.
(08:24):
So, using the likes of threatmetrics, we can actually see has
this person been associatedwith bad activities previously?
Then, obviously, with thedifferent products that we have
globally, we have the ability tolook at this person's name,
address and date of birth andensure that, at the right age to
play, and as and when thisperson's starting to spend and
deposit whether it's three daysor whether it's three years we
(08:45):
can constantly be looking at theamount of spend, what the best
and gone the time that they'vebeen playing.
So the operators, they'll havetheir own risk based level of.
We don't believe that thisperson should be playing more
than three hours on slots everyseven days.
So with this system, not onlywere we able to look at data,
we're able to look at theability to communicate.
So, as and when this happens, wecan actually it can be on a
(09:09):
chat box where they could have achat with someone and say
actually it's two o'clock in themorning on a Saturday.
Typically people are playing atthis time of this amount.
I've been out drinking and theythink they're the next big
poker player when they're not.
So it's that instant andability to be able to
communicate and demonstrate tothe operator, to the regulators,
as and when these points arehappening You're actually on the
(09:29):
ball.
And it's the same withquestionnaires as well.
Once people are hitting certainthresholds, you actually be
able to have a questionnaire andsort of ask them the questions
of should you be spending thisamount?
And that's really the point.
You want the ability to have aview of that whole customer's
life cycle, from day one to five, ten years down the line, and
be able to demonstrate that, asan operator, you're going above
(09:51):
and beyond to make sure yourplayers are using this as an
entertainment side and not usingit as an addiction side that
could cause issues to themselvesand their family members.
Speaker 1 (10:01):
On that point, then, because obviously we've talked a
lot about triggers in place tostop people when they are
getting to a point where it'sbecoming problematic.
We've talked about making surethat people are who they say
they are and conducting thoseKYC checks.
When you've got people who arejust like you said, on a
Saturday, you want to bet onsome horse racing, you want to
bet on some football, how dooperators balance that?
Customer experience is huge andwe've just released a study
(10:23):
which puts customer experiencein terms of top of priority for
compliance officers.
How do they ensure that thechecks and making sure that
you're aligned with therequirements isn't impacting
this customer experience forgenuine players who just want to
have a good time, who don'thave a problem and they want to
(10:44):
be on board quickly and theydon't want to have to go through
various blockages if they arejust wanting to spend £50 on a
football game?
Speaker 2 (10:54):
Yeah, I think that's probably over the next year to
three years where the biggestchallenge is coming from the
operators, because what we'rereally seeing now is that the
regulators around the world arestarting to treat gambling
rather than as an entertainment.
Now it's starting to treat itas going through a loan
application these points thatthey're talking about when
(11:16):
people are hitting and spendingthis amount of money.
You need to know more.
You need to know more.
That's really where thechallenge that the operators are
having is one, making sure thatthey're aligned into regulation
, because obviously they don'twant to be hit with a
significant fine.
But two, they don't want tomake the player think.
Well, actually I've been askedless questions when I've gone
(11:37):
for a loan or a mortgage, sothat's where it's really the
juggling act.
I think what we're really goingto see, especially in the UK
with the new consultationdocument, is that it's trying to
make it a level playing field,and what I mean by that is
gamblers are not loyal.
So where you'll have whetherit's retail brands, shopping
brands you can build thatloyalty, but with gamblers
(12:00):
there's not.
They're looking for quick, fastand seamless.
So if I go on one website andthey're asking for my savings
and my pay slips.
I'm just going to go to thenext one until you actually get
on, and that's one of the thingsthat operators are really
asking for that if it's a levelplaying field and people
everyone's asking for this oreveryone's not asking for this,
(12:22):
that's fine.
And I think that's what a lotof operators are hoping with the
new regulations is that it'sgoing to be clear, it's going to
be precise and it's going to besaying everyone has to do that.
And by doing that, it's fine,because whether I'm a player
going on one site or a playergoing on the other one, the
expectations is exactly the same.
Speaker 1 (12:44):
And so, while operators are waiting for those
new responsible gaming outlines,what in your mind?
You've been working in thisindustry for many years.
What is a comprehensivecompliance process in terms of
doing the right checks,balancing customer experience?
What are some of the key thingsthat should be considered?
Speaker 2 (13:05):
Yeah, I think when a player initially signs up, it's
obviously an operator needs toget an understanding of what's
this person's habits.
What do they typically do?
So to start off with a lot ofit is common sense.
If I just come on there and I'mstanding thousands of pounds,
that's something where you'regoing to have to have a look at
this.
At some point you will have toask someone for how much do you
(13:28):
earn?
Let's have a look at your payslips.
But I would say the majority ofpeople are keeping that sort of
low level amount where itdoesn't look stupid.
It's a 10, it's a 20 pound beton the weekend.
So I think it's really justwhere and again going back to
what LexusNexus do is a business.
With our transactionalbehaviour and monitoring, we're
able that an operator canactually hardwire in the
(13:52):
regulators outlines of what isexpecting and what they class as
worrying indicators.
And also as a business you'llhave with these different
operators, the big ones, whichare PLC companies they're
obviously going to put in a highlevel of risk than some newer
sort of business, or let's callit a tier two or tier three.
So it really comes down to thecompanies what they believe is
(14:16):
ethical, but what we try and dois we try and allow them to
implement the right stuff, where, if someone is coming in and
they're starting to spendthousands of pounds within a
first day or a first week,that's where we give them the
ability to communicate with thecustomer and say right, we are
doing this as a regulationrequirement, but we're also
doing it ethically, to make surethat you're not spending more
(14:37):
than you should be able to spendin the gambling environment.
Speaker 1 (14:42):
So okay, so kind of factoring in the right.
The right pressure is up front,but then also the right
triggers throughout kind of theplaying cycle.
Speaker 2 (14:50):
Yeah, yeah, and to your point, before, it's
balancing it, it's making surethat when they are starting to
have the communication with theplayer, it's making sure that
they're aware as they're doingit, because they're trying to
protect you and making sure thatyou're using their services as
an enjoyment rather than usingthe inch their services to chase
a loss or you might bestruggling with money and it's
(15:13):
to pay for your next bill.
So that's really where it'sdefined balance and, like I said
, there are going to be newguidelines that coming out, but
a lot of it at the times whereit is common sense, people
should not be spending X amountof money.
And if they do, I suppose ifyou're going for a loan and you
want to borrow £5,000, you knowthat actually they're going to
(15:36):
ask me for this information.
So again, I think where we talkabout education from the
operator side, it's actually gotto be players education as well
, and they've got to realisethat when people are spending
certain amount of money, yes, itis your money, but again, the
operators are given expectationsto carry out these relevant
checks.
So I think it's a playereducation.
So if you look, for example, inSweden Sweden they have no
(16:00):
issues giving any operator anyinformation.
If I didn't ask a Swedishplayer to provide a certain
amount of information, theywould probably think, well, is
this a dodgy website, becausethey're not asking me for this
information?
So I think in the UK playersespecially, it's an education
process.
Speaker 1 (16:16):
Got you and obviously we've talked about the UK
Gaming Commission.
You've just mentioned Swedenthere.
Is there anything thatoperators, if they're looking to
move from the UK, if they'relooking to move into emerging
markets?
Obviously online gaming isbeing legalised and it's
starting to open up in a lotmore markets.
What can these operators takemaybe from the UKGC regulations
(16:40):
when it comes into moving intoemerging markets?
Can they do a copy paste andmaybe tweak it from there to
help them speed up?
Or is it a complete overhaul,depending on the regulations?
Speaker 2 (16:52):
Yeah, I think if you follow the guidelines of the
UKGC, you won't be far away frombeing in the right place.
To your point, yes, there isprobably tweaks.
So when you look at differentregulations, jurisdictions
around the world, they might notsay right, you're doing it on
registration.
It might be on first deposit orwithdrawal or spend of a
certain amount.
So, touching back on what thebenefits that you'll find,
(17:16):
obviously from the Lexussolution is, you don't want a
one size fits all Because, forexample, what the UKGC is asking
if you move to the likes ofMalta, the UKGC is probably
tighter than what you need.
So, again, it's making sure youhave a solution that fits the
regulation as it's supposed tobe.
So, again, with the Lexussolution, what we're doing is
(17:39):
whether it states whether it'sdifferent countries, you can
specifically tune the rules tomeet the relevant regulations.
And again, what that's doing isit's making sure that you're
playing in a level playing field.
If you're applying the UKGCregulations in, let's say, in an
Asia market, you're justbasically going to be kicking
out a load of customers whereyou don't need to because that
(18:00):
regulation piece is not in placein that country.
So, again, it's specificallyhaving the right rules and
responsible abilities in eachstate country jurisdiction
Perfect.
Speaker 1 (18:13):
And that's a nice wrap up, I think, to conclude
this episode.
I think, Adam, if you were toleave Listus with one piece of
advice, particularly for gamingoperators who this is relevant
to, what would that be?
Speaker 2 (18:25):
Yeah, I think one of the things that we're really
seeing is that there's a lot ofresearch being carried out by
companies to understandaddiction issues and also how
people play in an onlineenvironment, and I think I
mentioned it before.
There is a lot of transactionsthat are going through these
operators.
(18:45):
It is physically impossible todeal with this with humans just
sitting there and dealing withevery transaction as it's going
through, and technology hassignificantly improved since the
late 90s when the gamblingmarket started, and also there's
a hell of a lot of data outthere.
I think unless operators reallystart embracing the technology
and data, it's going to reallyimpact with them with fines.
(19:08):
So data and technologies there,use it, because not only will
it ensure that you don't haveany issues with fines, it will
also make the customer journeyfar better and again it will
reduce the amount of work thatyou're having to do from your
customer service teams.
Speaker 1 (19:22):
I hope that's great.
Thank you so much, adam Doyle.
Lex and Lex for the RiskSolutions Really appreciate your
time today.
Speaker 2 (19:28):
Thanks to you, Liz.
Speaker 1 (19:29):
And for anybody who's interested, we will include a
couple of links to some relevantcontent and also to some of
those products that Adammentioned in the podcast.
So thank you so much for tuningin and we will see you again
next time on the Rig Tech Pulse.
Hi everyone, welcome back to the Rig Tech Pulse.
You're here with Julia, andtoday I'm joined by Adam Doyle,
who is head of gambling for theLexus Nexus risk narrative
platform.
We're here to talk about onlinegaming, everything, kyc, your
responsible gaming, what thereis requirements are.
So, adam, thank you so much forjoining me on the Rig Tech
Pulse today.
Speaker 2 (00:30):
Thanks, julia, nice to meet you.
Speaker 1 (00:32):
I wondered if you could give us a quick overview
of maybe a little bit about yourrole, what your
responsibilities are, what kindof operators you work with, and
then we can dive into some ofthose KYC points.
Speaker 2 (00:42):
Yeah, perfect.
So I came over from the tunenarrative business just over two
years ago.
I was part of the managementteam there, but also I had been
looking after the gamblingvertical.
So I've been working in thesort of identity management
space for about 15 years now andfor a lot of that time as well
as sort of supporting andmanagement teams, a lot of it
(01:03):
has had a key focus on thegambling businesses.
I think over the years I'veprobably been involved in about
400 gambling operatorscontracting wise, and that's on
a global level.
So I'm hoping what I reallyhave been doing over the last
two years with Lexus Nexus isit's supporting the sales team
from around the globe andhelping them go through the
(01:25):
process of initial conversationswith the operators and then
closing the contracts.
Speaker 1 (01:31):
So you're a busy man.
Speaker 2 (01:34):
Yes, my wife enjoys the six o'clock wake-ups and the
11 o'clock still on calls withthe US and the the D'Atom teams.
Speaker 1 (01:42):
The joys of global business.
I wonder if we start ourconversation today?
Obviously, kyc.
You know your customer, anybody.
You're familiar with our work.
We work very closely withfinancial institutions, so KYC
is a very familiar term.
What does it mean specificallywhen you were talking about
gaming and gambling operators?
I think specifically from anonline perspective, because
that's where we really seem tobe focusing the conversation
(02:05):
today.
Speaker 2 (02:06):
Yeah, exactly, I think.
If you just quickly look at theland-based bit, it's very
simple, isn't it?
If you go into any casinos, theexpect to show you whether it's
a drive-in license or passport,and that's very simple.
In the unseen environment itbecomes very challenging.
But if you look at things likethe UK GC, they specifically say
that an operator, as and when aplayer registers, at that point
(02:27):
they have to validate theirplayer, and what they're looking
to do is the initial one isthey're ensuring that players
are over the relevant age.
So in the UK it's making surethat someone's 18 and above.
The expectations that they puton the operator is that they
have to validate to name,address and date a birth and,
like I said, the main reason forthat is it's ensuring it's
(02:48):
protecting players under the ageof 18.
On top of that as well, whatthey're also doing is the UK GC
are ensuring that the protectingplayers are protecting
operators against money laundersand also sort of politely
exposed people.
So we're making sure that ourPrime Minister is not spending
the UK's budget on his gamblinghabit.
And then, further down the line, what they're really doing is
(03:10):
they're trying to ensure thatthe protecting players that
can't afford to gamble, toensure that they're not gambling
above their means.
So they're probably the corefocus is that they're really
looking to for an operator tocarry out.
Speaker 1 (03:23):
And that's that piece around this sort of responsible
gaming and player safety.
I mean, is there?
I know that you can't sharespecific examples, but what
would be a red flag when itcomes to somebody maybe gaming
more than they should be able to?
How does a gaming operator getthat information to make that
decision?
Speaker 2 (03:42):
Yeah, so there is a consultation document that's
going out at the moment whichshould hopefully be a lot more
clarification by the end of thisyear, but a lot of it I think,
if we look at a lot of it, iscommon sense.
So where there has been somefines, an operator, you know
they have to take accountabilityin the sense that they've never
seen this player before They'veregistered and within six hours
(04:04):
they've spent over £100,000.
You know, that's quite a bit.
I'm going to say that thatshouldn't be allowed, especially
when no due diligence has beencarried out.
So some of the measures thathave been put in place is if
someone has spent more than £100, a couple of £100 within a
certain time, or an annualamount or that's a lower level
where they'd expect you to seeright, has this person got any
(04:26):
CCJs?
Have they got any outstandingpayments?
And then when people have spentyou know, maybe, let's say the
number that's being used is£2,000 within a year, Once that
carries out, they're expectingpeople to really sort of have a
look at whether it's financialinformation out there.
So Kato is a system that'scurrently well previously been
used and looking to be broughtback.
(04:47):
We do have a supplier thathelps us look and get loan
outcome information, so that'svery good because a lot of the
people that are vulnerable haveprobably been taken out loans,
so that's very powerful.
And then the other way that theUK GC is suggesting is looking
at open banking information.
But again, where you can haveopen banking information?
I'm sure, like everyone wholistens to this, they probably
(05:08):
have a food account.
Me and my wife, we have a foodaccount, several hundred pounds
going into that a month, and allyou're seeing is on the 15th
they're having this into it.
You're not seeing anything else.
So going down that route is notreally allowing you to see any
vulnerable activities.
Speaker 1 (05:24):
So it's kind of a combination of various different
factors and also that commonsense it triggers.
Yeah, yeah.
Speaker 2 (05:29):
It's very much triggers.
If you once you you know oncesomeone's been on a website for
a while, you can see what theirtypical pattern is.
For example, me, on a Saturday,I might bet on horse racing and
football, and I'm typicallyspending £50 on a weekend,
whereas if one weekend I'm nowspending a thousand and I'm
betting on the next availablebet, whether it's horse racing,
(05:50):
football, ping pong, tennis,that type of stuff.
That's another good indicatorthat this probably person's
either one their accounts beingtaken over or two they're now
potentially subring from anaddiction issue.
Speaker 1 (06:01):
Can't you, can't you.
And so I suppose there's a lotto consider in terms of
obviously carrying out the rightchecks, ensuring that player
safety, ensuring thatresponsible gaming is there.
When you speak to complianceofficers at these gaming firms
and you know, when you go in andhave these initial discussions
with them, what is it that youthink?
What do they really strugglewith?
(06:21):
And so that's keeping them upat night.
Speaker 2 (06:24):
The things that you really see now is especially
let's call it these tier oneoperators.
The amount of transactions thatthey're going through.
It's crazy.
We're talking hundreds ofthousands of transactions a day.
What we see with some operatorsis they're either using old
technology which, as theirvolumes have grown and as
they've grown as a business,they sticky tape and blue tack
(06:45):
something together to try andhelp them, which really it
normally takes about five peopleto pull the report and seven
days.
So the struggle is it's stayingon top of that as and when it's
happening.
That's something really whereLexus Nexus is a business where
we're really helping peoplebecause we have the ability to
monitor people as and when thetransactions are going through.
(07:07):
So when a flag is hit, we canfreeze an account, we can flag
it to the compliance team, sothat's something that really
gives them peace of mind thatthey're not 24 hours but after
the incident has happened.
So that's really where we tryand give a compliance person
peace of mind is that they knowas and when someone hits a
threshold that they deemsomething needs to happen.
(07:29):
Our system makes sure thathappens straight away.
Speaker 1 (07:33):
And we were talking before in earlier conversations
outside of this podcast.
You mentioned there was aphrase about the single view of
a player.
Can you maybe explain that,because that's quite an
interesting concept.
Speaker 2 (07:43):
Yeah.
So the one point that the UK GCreally took about is having
this single view of the customer.
Unfortunately, at the moment,what you have in the gambling
space is sharing data issomething that's not really
there, because it's a lack oftrust.
Operators believe that if theyflag that someone's hit this
level, people will just stopputting their VIPs on there.
(08:03):
So when sort of VIP tries tocome on there, they'll be
flagged is don't touch them.
So when we talk about a singleview, we're talking about we're
talking to get a single view ofthe operator, so let's say, of
Adam Doe.
So what?
We have the ability with allthe different products that we
have a Lexus Nexus we have theability from point of
registration so we can look atdevices of this person.
(08:24):
So, using the likes of threatmetrics, we can actually see has
this person been associatedwith bad activities previously?
Then, obviously, with thedifferent products that we have
globally, we have the ability tolook at this person's name,
address and date of birth andensure that, at the right age to
play, and as and when thisperson's starting to spend and
deposit whether it's three daysor whether it's three years we
(08:45):
can constantly be looking at theamount of spend, what the best
and gone the time that they'vebeen playing.
So the operators, they'll havetheir own risk based level of.
We don't believe that thisperson should be playing more
than three hours on slots everyseven days.
So with this system, not onlywere we able to look at data,
we're able to look at theability to communicate.
So, as and when this happens, wecan actually it can be on a
(09:09):
chat box where they could have achat with someone and say
actually it's two o'clock in themorning on a Saturday.
Typically people are playing atthis time of this amount.
I've been out drinking and theythink they're the next big
poker player when they're not.
So it's that instant andability to be able to
communicate and demonstrate tothe operator, to the regulators,
as and when these points arehappening You're actually on the
(09:29):
ball.
And it's the same withquestionnaires as well.
Once people are hitting certainthresholds, you actually be
able to have a questionnaire andsort of ask them the questions
of should you be spending thisamount?
And that's really the point.
You want the ability to have aview of that whole customer's
life cycle, from day one to five, ten years down the line, and
be able to demonstrate that, asan operator, you're going above
(09:51):
and beyond to make sure yourplayers are using this as an
entertainment side and not usingit as an addiction side that
could cause issues to themselvesand their family members.
Speaker 1 (10:01):
On that point, then, because obviously we've talked a
lot about triggers in place tostop people when they are
getting to a point where it'sbecoming problematic.
We've talked about making surethat people are who they say
they are and conducting thoseKYC checks.
When you've got people who arejust like you said, on a
Saturday, you want to bet onsome horse racing, you want to
bet on some football, how dooperators balance that?
Customer experience is huge andwe've just released a study
(10:23):
which puts customer experiencein terms of top of priority for
compliance officers.
How do they ensure that thechecks and making sure that
you're aligned with therequirements isn't impacting
this customer experience forgenuine players who just want to
have a good time, who don'thave a problem and they want to
(10:44):
be on board quickly and theydon't want to have to go through
various blockages if they arejust wanting to spend £50 on a
football game?
Speaker 2 (10:54):
Yeah, I think that's probably over the next year to
three years where the biggestchallenge is coming from the
operators, because what we'rereally seeing now is that the
regulators around the world arestarting to treat gambling
rather than as an entertainment.
Now it's starting to treat itas going through a loan
application these points thatthey're talking about when
(11:16):
people are hitting and spendingthis amount of money.
You need to know more.
You need to know more.
That's really where thechallenge that the operators are
having is one, making sure thatthey're aligned into regulation
, because obviously they don'twant to be hit with a
significant fine.
But two, they don't want tomake the player think.
Well, actually I've been askedless questions when I've gone
(11:37):
for a loan or a mortgage, sothat's where it's really the
juggling act.
I think what we're really goingto see, especially in the UK
with the new consultationdocument, is that it's trying to
make it a level playing field,and what I mean by that is
gamblers are not loyal.
So where you'll have whetherit's retail brands, shopping
brands you can build thatloyalty, but with gamblers
(12:00):
there's not.
They're looking for quick, fastand seamless.
So if I go on one website andthey're asking for my savings
and my pay slips.
I'm just going to go to thenext one until you actually get
on, and that's one of the thingsthat operators are really
asking for that if it's a levelplaying field and people
everyone's asking for this oreveryone's not asking for this,
(12:22):
that's fine.
And I think that's what a lotof operators are hoping with the
new regulations is that it'sgoing to be clear, it's going to
be precise and it's going to besaying everyone has to do that.
And by doing that, it's fine,because whether I'm a player
going on one site or a playergoing on the other one, the
expectations is exactly the same.
Speaker 1 (12:44):
And so, while operators are waiting for those
new responsible gaming outlines,what in your mind?
You've been working in thisindustry for many years.
What is a comprehensivecompliance process in terms of
doing the right checks,balancing customer experience?
What are some of the key thingsthat should be considered?
Speaker 2 (13:05):
Yeah, I think when a player initially signs up, it's
obviously an operator needs toget an understanding of what's
this person's habits.
What do they typically do?
So to start off with a lot ofit is common sense.
If I just come on there and I'mstanding thousands of pounds,
that's something where you'regoing to have to have a look at
this.
At some point you will have toask someone for how much do you
(13:28):
earn?
Let's have a look at your payslips.
But I would say the majority ofpeople are keeping that sort of
low level amount where itdoesn't look stupid.
It's a 10, it's a 20 pound beton the weekend.
So I think it's really justwhere and again going back to
what LexusNexus do is a business.
With our transactionalbehaviour and monitoring, we're
able that an operator canactually hardwire in the
(13:52):
regulators outlines of what isexpecting and what they class as
worrying indicators.
And also as a business you'llhave with these different
operators, the big ones, whichare PLC companies they're
obviously going to put in a highlevel of risk than some newer
sort of business, or let's callit a tier two or tier three.
So it really comes down to thecompanies what they believe is
(14:16):
ethical, but what we try and dois we try and allow them to
implement the right stuff, where, if someone is coming in and
they're starting to spendthousands of pounds within a
first day or a first week,that's where we give them the
ability to communicate with thecustomer and say right, we are
doing this as a regulationrequirement, but we're also
doing it ethically, to make surethat you're not spending more
(14:37):
than you should be able to spendin the gambling environment.
Speaker 1 (14:42):
So okay, so kind of factoring in the right.
The right pressure is up front,but then also the right
triggers throughout kind of theplaying cycle.
Speaker 2 (14:50):
Yeah, yeah, and to your point, before, it's
balancing it, it's making surethat when they are starting to
have the communication with theplayer, it's making sure that
they're aware as they're doingit, because they're trying to
protect you and making sure thatyou're using their services as
an enjoyment rather than usingthe inch their services to chase
a loss or you might bestruggling with money and it's
(15:13):
to pay for your next bill.
So that's really where it'sdefined balance and, like I said
, there are going to be newguidelines that coming out, but
a lot of it at the times whereit is common sense, people
should not be spending X amountof money.
And if they do, I suppose ifyou're going for a loan and you
want to borrow £5,000, you knowthat actually they're going to
(15:36):
ask me for this information.
So again, I think where we talkabout education from the
operator side, it's actually gotto be players education as well
, and they've got to realisethat when people are spending
certain amount of money, yes, itis your money, but again, the
operators are given expectationsto carry out these relevant
checks.
So I think it's a playereducation.
So if you look, for example, inSweden Sweden they have no
(16:00):
issues giving any operator anyinformation.
If I didn't ask a Swedishplayer to provide a certain
amount of information, theywould probably think, well, is
this a dodgy website, becausethey're not asking me for this
information?
So I think in the UK playersespecially, it's an education
process.
Speaker 1 (16:16):
Got you and obviously we've talked about the UK
Gaming Commission.
You've just mentioned Swedenthere.
Is there anything thatoperators, if they're looking to
move from the UK, if they'relooking to move into emerging
markets?
Obviously online gaming isbeing legalised and it's
starting to open up in a lotmore markets.
What can these operators takemaybe from the UKGC regulations
(16:40):
when it comes into moving intoemerging markets?
Can they do a copy paste andmaybe tweak it from there to
help them speed up?
Or is it a complete overhaul,depending on the regulations?
Speaker 2 (16:52):
Yeah, I think if you follow the guidelines of the
UKGC, you won't be far away frombeing in the right place.
To your point, yes, there isprobably tweaks.
So when you look at differentregulations, jurisdictions
around the world, they might notsay right, you're doing it on
registration.
It might be on first deposit orwithdrawal or spend of a
certain amount.
So, touching back on what thebenefits that you'll find,
(17:16):
obviously from the Lexussolution is, you don't want a
one size fits all Because, forexample, what the UKGC is asking
if you move to the likes ofMalta, the UKGC is probably
tighter than what you need.
So, again, it's making sure youhave a solution that fits the
regulation as it's supposed tobe.
So, again, with the Lexussolution, what we're doing is
(17:39):
whether it states whether it'sdifferent countries, you can
specifically tune the rules tomeet the relevant regulations.
And again, what that's doing isit's making sure that you're
playing in a level playing field.
If you're applying the UKGCregulations in, let's say, in an
Asia market, you're justbasically going to be kicking
out a load of customers whereyou don't need to because that
(18:00):
regulation piece is not in placein that country.
So, again, it's specificallyhaving the right rules and
responsible abilities in eachstate country jurisdiction
Perfect.
Speaker 1 (18:13):
And that's a nice wrap up, I think, to conclude
this episode.
I think, Adam, if you were toleave Listus with one piece of
advice, particularly for gamingoperators who this is relevant
to, what would that be?
Speaker 2 (18:25):
Yeah, I think one of the things that we're really
seeing is that there's a lot ofresearch being carried out by
companies to understandaddiction issues and also how
people play in an onlineenvironment, and I think I
mentioned it before.
There is a lot of transactionsthat are going through these
operators.
(18:45):
It is physically impossible todeal with this with humans just
sitting there and dealing withevery transaction as it's going
through, and technology hassignificantly improved since the
late 90s when the gamblingmarket started, and also there's
a hell of a lot of data outthere.
I think unless operators reallystart embracing the technology
and data, it's going to reallyimpact with them with fines.
(19:08):
So data and technologies there,use it, because not only will
it ensure that you don't haveany issues with fines, it will
also make the customer journeyfar better and again it will
reduce the amount of work thatyou're having to do from your
customer service teams.
Speaker 1 (19:22):
I hope that's great.
Thank you so much, adam Doyle.
Lex and Lex for the RiskSolutions Really appreciate your
time today.
Speaker 2 (19:28):
Thanks to you, Liz.
Speaker 1 (19:29):
And for anybody who's interested, we will include a
couple of links to some relevantcontent and also to some of
those products that Adammentioned in the podcast.
So thank you so much for tuningin and we will see you again
next time on the Rig Tech Pulse.
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