Worked examples for the online wagering industry

John opens a betting account with online wagering operator ABC Bets and deposits $8,000 into the account using a credit card. ABC Bets correctly verifies John’s identity.

John doesn’t place any wagers or conduct other wagering transactions on his account. After one week John asks ABC Bets to withdraw the $8,000 and close his account.

The bank that issued John’s credit card does not allow the transfer, so ABC Bets is unable to transfer the funds from his wagering account to his credit card. John asks for the funds to be transferred to a bank account instead.

ABC Bets’s transaction monitoring program identifies this behaviour as appearing suspicious and applies its enhanced customer due diligence (ECDD) program.

ABC Bets contacts John who explains that he wants to close his account because he has bills to pay and is no longer interested in gambling. ABC Bets asks John to provide evidence within two weeks, to prove his ownership of the nominated bank account such as a bank statement.

ABC Bets also checks social media sites and finds information showing that John has an interest in gambling and his claims of having an extravagant lifestyle.

Two weeks later, John still has not provided proof of ownership of the nominated bank account.

ABC Bets concludes that this behaviour is suspicious. A suspicious matter report (SMR) is provided to AUSTRAC and an alert is placed on the account. The SMR clearly explains what led ABC Bets to form a suspicion, the ECDD measures employed and their findings and the action ABC Bets took as a result.

Jane opens a wagering account with XYZ Bets and deposits $5,000 using a credit card held in the name of her business.

Jane makes no wagers or other transactions on her account and after ten days asks to withdraw $4,500 and transfer it to her partner David. David is not a customer of XYZ.

XYZ does not deposit money into third-party accounts and declines to transfer the funds from Jane’s wagering account to David’s bank account. Jane asks for the funds to be transferred into a joint bank account she holds with David instead.

XYZ’s transaction monitoring program identifies this behaviour as appearing suspicious and applies its enhanced customer due diligence program (ECDD).

XYZ’s customer care team verifies Jane’s identity and asks her to provide documentation to prove her ownership of the nominated bank account. Jane provides a recent bank statement that shows that the nominated bank account is held in joint names, one of which is hers.

XYZ pays the requested amount into the joint bank account nominated by Jane.

Although XYZ is able to verify that the nominated bank account was partly owned by Jane, it still concludes that the behaviour is suspicious. A suspicious matter report (SMR) is provided to AUSTRAC and an alert is placed on the account. The SMR clearly explains what led XYZ to form a suspicion, the ECDD measures they applied and their findings, and the action XYZ took as a result.

BetCo opens a wagering account for Robert and verifies his identity. Over the next three weeks Robert deposits $7,000 into his account using several credit cards, but does not conduct any wagering.

A few days later Robert has still not conducted any wagering. He contacts BetCo’s customer care team to advise that he is experiencing financial difficulty and asks for the balance in his wagering account to be deposited into a bank account.

BetCo’s transaction monitoring program identifies this behaviour as appearing suspicious and applies its enhanced customer due diligence program (ECDD).

BetCo’s customer care team asks Robert to provide documentation to prove his ownership of the nominated bank account. Robert provides a recent bank statement that shows that the nominated bank account is held in his name.

As BetCo is processing the withdrawal, one of the initial credit card payments that funded Robert’s wagering account is disputed.

As a consequence of this disputed transaction, BetCo suspends Robert’s wagering account and ceases processing the withdrawal request. Through further investigations, BetCo identifies that the credit card used for the disputed transaction is a corporate credit card that belongs to Robert’s employer.

BetCo concludes that the behaviour is suspicious. A suspicious matter report (SMR) is provided to AUSTRAC and an alert is placed on the account. The SMR clearly explains what led BetCo to form a suspicion, the ECDD measures employed and their findings, details about the fraudulent transaction, and the action BetCo took as a result.

ABC Bets’s transaction monitoring program detects that one of its customers, Angela, has made regular deposits and subsequent withdrawals to and from the same source over a period of the previous four weeks, as shown below:

As Angela has not conducted any wagering transactions, ABC Bets is concerned that Angela has opened the account for purposes other than for wagering. ABC Bets’s transaction monitoring program identifies this behaviour as appearing suspicious and applies its enhanced customer due diligence program (ECDD).

ABC Bets reviews Angela’s previous transactions as well as recorded calls of their engagement with her, however cannot form any conclusion that explains her activity.

ABC Bets concludes that the behaviour is suspicious. A suspicious matter report (SMR) is provided to AUSTRAC and an alert is placed on the account. The SMR clearly explains what led ABC Bets to form a suspicion, the ECDD measures employed and their findings, and the action ABC Bets took as a result.

Bill opened a wagering account with XYZ Betting three months ago. He has been funding his wagering account through frequent cash deposits of between $500 and $2,000 at participating newsagents and other outlets, sometimes depositing multiple times per day.

Bill typically places bets on short odds favourites and when he does receive a payout into his account, he requests an immediate withdrawal of that payout.

XYZ Betting’s transaction monitoring program triggers an alert as a result of Bill’s frequent cash deposits together with his immediate withdrawals following payouts and applies its enhanced customer due diligence program (ECDD).

Upon contacting Bill to understand his source of wealth, Bill refuses to provide any information around his employment status or bank statements.

XYZ Betting concludes that the behaviour is suspicious. A suspicious matter report (SMR) is provided to AUSTRAC and an alert is placed on the account. The SMR clearly explains what led XYZ Betting to form a suspicion, the ECDD measures employed and their findings, and the action XYZ Betting took as a result.

Anne has held a wagering account with WagerCo for over four years. Anne has only ever wagered with small sums of money and primarily just on annual high profile sporting events.

WagerCo’s transaction monitoring program identifies a dramatic increase in the number and value of deposits into Anne’s betting account together with an increase in the frequency and value of betting activity.

As a result WagerCo applies its enhanced customer due diligence program, which includes ascertaining Anne’s source of wealth.

WagerCo’s customer care team contacts Anne and she advises them that she works part-time but has recently inherited a substantial sum of money. Documents provided by Anne confirm her claim.

WagerCo is satisfied with Anne’s explanation and does not deem Anne’s betting activity as suspicious. No suspicious matter report is provided to AUSTRAC.

A customer referring to himself as Neil makes multiple attempts to open a wagering account with ABC Bets. The customer uses variations of his name, date of birth and email address.

ABC Bets’s transaction monitoring program detects these multiple attempts to create an account and links them together using the mobile phone device ID as a unique identifier.

As a result, ABC Bets applies its enhanced customer due diligence program. ABC Bets then decides to place a block on all of the accounts as well as the mobile phone device that was used in the account opening attempts.

ABC Bets concludes that the behaviour is suspicious. A suspicious matter report (SMR) is provided to AUSTRAC and an alert is placed on the accounts. The SMR clearly explains the information that led ABC Bets to form a suspicion, the ECDD measures employed and their findings, and the action ABC Bets took as a result.