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On-line Gaming eLottery – eBingo – eCasino - ePoker

Bryon Hodgkin – Director Operational Compliance

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How did we build a viable,

secure gaming environment

on the Internet?

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Time Line

•PlayNow - eLottery

•$70/week 2004

•PlayNow - eBingo

•$70/week 2008

•PlayNow - eCasino

•$9999/week 2010

•PlayNow - ePoker

•$9999/week 2011

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Internal Stakeholders:

Business

Security

Finance

Consumer Services

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4 Business Sectors

Registration

Deposits

Game Play

Withdrawals

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eGaming Management System

PAM (Player Management

System)

Lottery Bingo Casino

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Registration “Know your Player”

Satisfy:

– Location of Player

– Age of Player

– Qualify to Play

Expedient Process

Player Agreement

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Registration Process

1 player = 1 account Verification

IP address verification (BC)

Self-exclusion verification

Player provides credit card information

Address / DOB and credit card verification (soft hit)

Create new player account in the PAM

End of automated process Verification not passed

Player provides identification information

If resolved (Manual Process)

Send a confirmation letter

Create suspended account in the PAM

Outsourced

Third Party

PAM

PAM

PAM

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Deposit

1 Player = 1 Account

1 credit card per account

Transactions validated by a third party

Deposit limit ($9999/week)

No prepaid credit card

48 hour hold on all withdrawal request

Daily follow-up

Player set daily limits

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Deposit Process

1. Credit card 2. Interac Online

Customer request

Payment validation

New Credit card?

No

Update PAM

Yes

Deposit limit $9999 / week

Validation process

Name/Address

Third Party

PAM

PAM

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Game Play

eCasino

eBingo

Player

eLottery

Review Daily

Reports –

Win/Loss

Monitor Games

Payout

Listen to Players

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Withdrawals

Verified Win

Meet Fintrac Reporting

Leverage Marketing

Player Experience

3 Levels of Withdrawals

> $100,000

> $10,000

> $1,000

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Withdrawal Process

>$10,000 (24 h period)

Verify bank account Fintrac report

Payout via EFT

In person review (cheque payment)

Play Verified Verify collection of occupation

Request

>$100,000 (24 h period)

Bank account Information Collected/Verified

Withdrawal amount Collect occupation (Fintrac)

* Note Fintrac Reporting does not apply to Lottery

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The Next Step – Add ePoker

eCasino

eLottery

eBingo

ePoker

Player

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What we did

August 2009; beginning of the project

Estimated the risk

Participated in meetings/conference calls between jurisdictions and our partners

Developed operational policies and procedures

Built and organizational structure for the ePoker business, finance, & security departments

Established the roles and responsibilities for internal and external partners

Selling point: It is a safe & secure poker network

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Create a strong partnership…Canadian Poker Network

ePoker

Player Account Manager

eCasino

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Security & Surveillance

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Canadian Poker Network

Game play

Deposit

Withdrawal

No cash-money allowed (including pre-paid card)

Credit card transaction verified

Credit card & Interact online validation

$9,999 weekly threshold

1 credit card per account

Only by EFT

All request >$1,000 will be investigated

48 hours pending for all request

Withdrawal transactions >$10,000 will be reported to Fintrac

1 player = 1 account

Buy-in limit ($3,000 per day)

Daily verification; win / loss and game activities

Suspicious transaction will be reported to Fintrac

Registration

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Canadian Poker Network -

Player’s Responsibilities

Not allowed to collude with another player

Not allowed to lose money deliberately to another player

May not deliberately accept money from other players

Not allowed to chat about their cards or game play

Not allowed to give other players advice on how to play

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Fraud and Collusion

Risk Evaluation:

Common types of poker room fraud

– Collusion between 2 or more players (Best Hand, Squeeze Play, Soft Play)

– “Chip dumping” (moving funds)

Countermeasures:

– The surveillance of the poker room is conducted by G2, they are responsible for identifying possible integrity issues of the game

– Partnership between BCLC, LQ, and G2

– Buy-in limit ($3000/day)

– Win/loss report (+/-20%)

– All player complaints will be investigated

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Fraud

Risk Evaluation:

General Risks

– Fraudsters moving funds

– Stolen credit card

– Money laundering

– Identity theft (player account)

– Bonus abuse

Countermeasures:

– Zero tolerance policy

– 1 player = 1 account

– 1 credit card per account

– Deposit limit ($9999/wk)

– Secure transactions

– No prepaid credit cards

– Transactions validated by a third party

– 1 method for withdrawal (EFT)

– 48 hours hold on all withdrawal requests

– Fintrac reports for $10K + transactions and suspicious transactions

– Daily follow-up (4 business sectors)

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Common SFTP Server

BC

LC SFTP

Server

Canadian Poker Network

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ePoker Withdrawals

Verified Win

48 hour review period if required

Meet Fintrac Reporting

Leverage Marketing

Player Experience

3 Levels of Withdrawals

> $100,000

> $10,000

> $1,000

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ePoker Withdrawal Process

>$10,000 (24 h period)

Verify bank account Fintrac report

Payout via EFT

In person review (cheque payment)

Play Verified Verify collection of occupation

Request

>$100,000 (24 h period)

Bank account Information Collected/Verified

Withdrawal amount Collect occupation (Fintrac)

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Money Laundering and Fintrac

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Any Questions?