Compliance + Payment: Integration reduces risk

Compliance + Payment: Integration reduces risk.

Too often, businesses across sectors consider compliance an extra responsibility, over and above what they need to do with the product or service they sell or provide.

But regulation is a license to operate. Without weaving regulation into how you deliver your product is likely to leave any risk management to occur after the fact.

In an age-old adage, stopping a problem happening is more effective than dealing with the consequences of a problem. This article, the third in our series, focuses on payments and integrated risk reduction.

Regulatory posture

AUSTRAC makes it clear that effective AML risk management is an expectation. Across the enforcement matters in the last 24 months, there are key themes:

• Need to understand risk,
• Must act to mitigate the risk,
• Make sure your people know what to do about risk, and
• Be responsible to your community in managing risk.

In the world of pubs and clubs, AUSTRAC do not issue a license to operate, but you must comply with AML laws or face a challenge to your ability to operate. In effect, offering electronic gaming machines (EGMs), means that you must exhibit those four key expectations ofAUSTRAC:

• Know what risks of money laundering (ML) are present with EGMs,
• Have controls that allow you todetect and mitigate ML risk,
• Your people are trained and know what controls they operate for your business, and
• By doing these things well, and reviewing how effective you are at it, is being responsible to the social community that you serve.

The payout at $5,000 and above

A payout at $5,000 or above is the trigger for most of your AML obligations as they relate to a player – that is the winner from your community from their EGM play.

The payout becomes the part of your EGM product offer, that offers you the opportunity to meet the 4 expectations articulated by AUSTRAC.

You have a winner engaged with your staff and they can:

1. Confirm the person is who they say they are (customer identity verification)
2. Determine if the person presents a higher risk of money laundering – for example, are they a politically exposed person (PEP)?
3. Ask questions about the person, how and why they use EGMs and find out more about them to determine if any indicators of ML risk are present to allow them to continue to use EGMs at your venue, and
4. What do they want to do with their winnings – where is it getting sent?

Moving from making a payment, to a compliance-led payment

All of these 4 outcomes can happen when your customer has:

1. Won money and
2. Is motivated to work with you to help you meet your responsibility to your community - and ultimately receive their winnings.

This proactive approach to a winning payout integrates your product with compliance.

Cruz Tech and the Cruz Payouts platform is the way to manage payout and compliance with your winner.

• Link the winnings from and EGM to a payment
• Know your winning player
• Determine if your winning player has any high-risk ML attributes
• Record any actions or investigations about the winning player
• Know where the bank payment goes – does the account name for the winnings match the person you identified?

Cruz’s compliance-led payments for payouts provides control at the point where it is needed.