Fortunately, the compliance and identity verification measures in industries under tight compliance regulations have been effective in restricting terrorist financing. However, the impact of these enhanced regulations and compliance measures in the gaming and financial community may have been to send these individuals to other marketplaces like person-to-person or small retailer-to-consumer.
About 12 years ago when I was president of the Poker Players Alliance, I was asked about person-to-person chip dumping in the online poker marketplace as a method of laundering funds. I responded that there were measures that could be employed in the iGaming space under regulated environments to ensure that measures were in place to combat the likelihood of money laundering and terrorist financing such as effective KYC – requiring that the individual that is verified owns a financial account – that patterns of wagering be monitored and measures be put in place to ensure and verify source of funds, etc.
I did suggest as an off-hand comment that if a person wanted to launder money for the lowest cost they could simply sell goods on eBay or any other person-to-person marketplace and never ship the goods. Unfortunately that has recently occurred according to a settlement between the FBI and eBay: http://time.com/4896684/islamic-state-ebay-paypal/
These basic AML requirements, as part of good regulated financial compliance by most major iGaming providers, form the basis of recently enacted EU AML fourth directive (AMLD4). AML is now the law of the land in the EU as defined by the member states and enforced as defined by each country’s financial authorities.
Measures like AMLD4 form an effective structure for entitles that are not directly covered by these regulations such as retailers outside of the EU like the United States, as a global strategy to combat money laundering and terrorist financing.
Having worked with many of the largest online Internet gaming and payment processors on their identity, age verification, KYC and Anti-Money Laundering (AML) strategies, I can assure you that Aristotle knows the most appropriate measures to mitigate these downside risks to corporate responsibility and compliance requirements. I’d be happy to go into further detail—just give me a call or drop me an email.
Michael Bolcerek
Senior Vice President, Business Development [email protected]