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In cases of identity fraud, operators were advised to close accounts upon establishing fraud and to reserve balances when bank account ownership cannot be confirmed.
Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.
For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.
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Here are some of the dossier’s key findings, some of which raise questions around Evolution’s compliance operations during the period assessed.
Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains it carried out an extensive technical, operational and compliance review of Evolution’s “business practices, public record database research and an assessment of the company’s anti-money laundering compliance procedures and processes, as they related to the allegations contained in the ‘anonymous report'”.
Tests carried out using a VPN to access banned markets found Evolution’s games had been available to players in the prohibited jurisdictions of UAE, Singapore, Hong Kong and Saudi Arabia.
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Van Bruggen insisted more time was needed to establish whether an age limit hike to 21 would actually have the adverse effect of pushing young people in the Netherlands towards unlicensed offerings.
Among those pushing for the increased age limit were the SGP’s Diederik van Dijk and the CDA’s Tijs van den Brink.
Van Bruggen said the matter would be raised in subsequent progress reports.