A remote gaming operator has been fined nearly €223,000 after the Financial Intelligence Analysis Unit (FIAU) found it guilty of several regulatory breaches.
Although Trannel International Limited had a policy regulating customer risk assessments, a significant portion of its customers who reached the €2,000 deposit threshold were not assigned a risk rating, the FIAU said in its decision following an off-site compliance examination carried out in October 2020.
The company’s failure to conduct documented assessments for the majority of its customer base not only constituted a breach of its obligations but also hampered its ability to determine the proper level of customer due diligence to be applied, as well as the degree and extent of ongoing monitoring to be performed, the unit said.
The FIAU said the company immediately applied a remedy by ensuring that its customers were adequately assessed.
For 40 per cent of the player profiles reviewed, the risk ratings assigned following a manual review were deemed inappropriate in light of certain risk factors identified. Among those factors were significant deposit amounts, velocity of transactions, and the use of higher-risk payment methods.
In 70 per cent of the player profiles reviewed, the company failed to retain a copy of the open-source intelligence obtained from the internet, opting only to include the webpage links and a brief note describing the contents.
The compliance examination report also raised concerns regarding the company’s non-compliance with its obligations related to the collection of information about the purpose and intended nature of the business relationship, particularly regarding the player’s income and source of wealth. Failure to obtain sufficient information related to the player’s source of wealth was found in half the player profiles reviewed by the FIAU, while the company failed to perform enhanced due diligence for 30 per cent of the player profiles reviewed and inadequate due diligence for another 30 per cent.
Concerning transaction monitoring, the FIAU found that the company had failed to appropriately scrutinise transactions for 80 per cent of the player profiles reviewed. Citing examples, the FIAU said that over a period of less than three months, a particular player made deposits of approximately €300,000 and incurred losses amounting to over €200,000. Although a review was carried out on the player by the anti-money laundering team, this was only after deposits had already surpassed €70,000.
Another player made deposits of €3.5 million utilising at least 12 different payment methods. In a source of wealth questionnaire completed one month after registration, the player declared that he is a merchant for goods/services and has a salary of €20,000 a month. Despite evidence that the player had a certain level of accumulated wealth, the player’s activity was still inconsistent with the income available at his disposal.
A third player, residing in Vietnam, deposited over €350,000 in three months and incurred losses equal to approximately €150,000. The player even received funds from third-party wallets, elevating his risk.
The FIAU said the company did not obtain any additional documentation to substantiate the player’s source of income and ensure it was sufficient to sustain the player’s gameplay.
After taking into consideration its findings, the FIAU imposed an administrative penalty of €222,736 for the breaches identified. The fine is subject to appeal.