On May 3, 2022, the KSA (Netherlands Gambling Authority) initiated an investigation into Entain’s brand, BetEnt. They requested 15 player surveys to gather information.

Unfortunately, the player surveys provided to the KSA were incomplete and had missing dates. This raised concerns that proper risk analysis had not been conducted until after the KSA’s request.

To ensure a thorough investigation, the KSA requested the original documents with accurate evidence.

In August, BetEnt once again provided inadequate evidence to the KSA. Eventually, when the player’s data was submitted, it revealed that 12 out of 17 players had not met the standards for Anti-Money Laundering (AML) measures.

These failures included insufficient checks on players who had lost large amounts of money, ranging from €12,000 to €110,000, within a single month.

BetEnt argues that the obligations under the Wwft were only recently applied to license holders in the online gaming market. However, the KSA disputes this, pointing out that the regulations were actually published on 8 February 2021.

It was discovered that BetEnt’s risk analysis procedures were either severely lacking or non-existent, as they were unable to guarantee proper monitoring of player transactions.

This failure to investigate the source of funds resulted in BetEnt violating the AML Act Article 3, Paragraph 2, (d).

During their investigation, the KSA found that five client surveys did not provide a source of funds, even though these were younger customers with significant net losses.

Furthermore, three transactions that violated the Wwft were not reported to the KSA in a timely manner, which is a violation of Article 16 of the Wwft.

BetEnt argued in their appeal that the KSA did not explicitly highlight the AML policies during the license application process, leading BetEnt to believe their own policies were sufficient.

The KSA responded by stating, “BetEnt is responsible for complying with the applicable laws and regulations.”

Despite BetEnt’s efforts to improve their AML practices, such as hiring a new team, the KSA will still enforce their decision due to the initial violation.

In their response, the KSA emphasized that BetEnt’s only reference to AML policy was their new and most current one, in addition to their efforts to recruit new staff and take charge of customer due diligence.

Regarding Play North, it was discovered that no action was taken when players spent large sums of money on the platform.

A thorough investigation revealed that Player A lost €135,000 in just one month, Player B lost €20,000 in a single day, and Player C deposited €25,000 within an hour, only to lose it all over two months.

The KSA encountered challenges while examining Play North’s anti-money laundering procedures, as the operator did not have an adequate player management system in place.

Consequently, it was uncertain whether the player surveys had been tampered with after they were compiled for the investigation.

In response to this, Play North has now implemented the Jira Player Management System to effectively monitor players and transactions.

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