KSA flags Betent and Play North for AML violations

This is the first time KSA has published sanctions related to the Wwft.

KSA announced investigations into Betent and Play North Limited on 3 May 2022. As part of the investigations, KSA requested 15 examples of customer investigations from each operator.

Although Betent and PlayNorth provided the requested information, they did not provide the dates on which certain actions occured. This meant it was “unclear” how certain conclusions on risk analysis were reached by the operators.

KSA also noted that Betent had retained the BSN numbers of customers in the data they provided. This is not a requirement outlined in the Wwft. A BSN number is a unique personal number issued to every citizen of the Netherlands, if they are registered on the country’s Personal Records Database.

The regulator requested that Betent destroys all BSN numbers they have retained.

Not investigating source of funds

After the operators provided the correct customer information, KSA continued its investigations into Betent and Play North Limited.

Of the 17 examples of customer investigations submitted, KSA said 12 were insufficient.

For Betent, KSA found that the operator was not investigating the source of funds of players that had experienced high losses. These included instances of players losing €110,000 in one month, €25,000 in one month and €85,000 in six months without intervention.

This violates article three, paragraph two, section (d) of the Wwft. This requires operators to investigate source of funds as part of customer due diligence.

Monitoring customer behaviour

KSA concluded that Betent is unable to monitor customer behaviour continuously and “is therefore unable to ensure that these correspond to Betent’s knowledge of the player and his risk profile with, if necessary, an investigation into the source of the funds”.

Yesterday, a KSA report into duty of care saw the regulator conclude that players are at risk of “serious damage” from operators that are unable to monitor in real-time.

Betent objected to KSA’s ruling. On 14 February 2023, KSA’s board upheld the regulator’s original decision.

For Play North Limited, KSA ruled that 11 of the 14 customer investigations submitted were insufficient.

It made the same conclusion for Play North Limited as it did for Betent, concluding that it was unable to continuously monitor customer behaviour.

KSA presented an instance where a player had lost €135,000 within two months. In another instance, a player lost €12,000 within a week and a half. Neither of these examples triggered source of funds investigations. This was despite KSA noting that “various alerts” had gone off, for matters such as “binge gambling” and “chasing losses”.

Play North Limited submitted an objection to KSA’s ruling, which was struck down by the regulator’s board.

After both operators were made aware of the decisions in November 2022, each was given three months to make amendments to obviate the violations.