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  1. #21
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    I wonder how you can promote with good faith iGaming sites who verify their customers with ID and proof of address, but refuse to submit these documents yourself to establish a business relationship with that casino?

    If you believe a casino does not handle personal data of its customers the right way, you have to restrain from promoting the casino.

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  3. #22
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    Quote Originally Posted by casinoFM View Post
    I wonder how you can promote with good faith iGaming sites who verify their customers with ID and proof of address, but refuse to submit these documents yourself to establish a business relationship with that casino?

    If you believe a casino does not handle personal data of its customers the right way, you have to restrain from promoting the casino.
    "in good faith". I was wondering when this chestnut would pop up. Somehow avoided to answer all my questions too, but that's easier than investigating and providing a real result.

    I'm getting back to work. I think it's time to leave the 99% of affiliates to their WordPress sites ('cos they'd have a heart attack if asked to make anything in WordPad) here and just do what I'm going to do. The new breed is a sheep in sheep's clothing and the casinos know it. You're in for a proper kicking and you've got no idea.

    FictionNet out. I'll see the pro's at AAC. The rest, enjoy yourselves. Whilst you can.

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  5. #23
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    Why did you sign up with a programm which clearly states in their terms and conditions they will request documentation?

    REGISTRATION, IDENTITY VERIFICATION AND COMMENCEMENT
    The Affiliate shall apply to join the Network by completing the registration form on the Website.
    Completion and submission of the registration form shall signify the Affiliate’s acceptance of these Terms and Conditions and any amendments thereto made by BGO Entertainment from time to time and published on the Website. After the submission of the registration form, BGO will run a verification of the Affiliates identity based on the information provided by the Affiliate and by obtaining further information from public and other data sources. The Affiliate agrees to provide BGO with any supporting documents, which BGO may further request, both during the registration process and on an on-going basis as required, for the purposes of Customer Due Diligence. Supporting documents required may include (but are not limited to), any or all of the following:
    For Individuals: Valid Photo Identification such as: a copy of a valid passport or driving licence. Valid Proof of Address such as: copy of a utility bill , letter of reference from the individuals bank or a copy of a bank statement; not more than 3 months old.
    For Companies: a copy of the company’s certificate of incorporation; register of Members & Shareholders, articles of association (or equivalent document); duly approved corporate resolution; certificate of good standing; power of attorney; and information regarding the identity of the beneficial owners and directors of the company.
    https://www.bgobuddies.com/terms/

    I agree that "and SEIZE the earnings." as written in the email is clearly unacceptable. But with regards to the verification process I cant understand your point of view. Why did you sign these Terms and conditions in the first place?

  6. #24
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    Quote Originally Posted by casinoFM View Post
    Why did you sign up with a programm which clearly states in their terms and conditions they will request documentation? [/COLOR]
    Why don't you know how to use the Wayback Machine to see these terms were not in place when I joined BGO?
    https://web.archive.org/web/20150403...ies.com/terms/

    I totally give up. You deserve what's coming to you.

    Now I really am out.

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  8. #25
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    Quote Originally Posted by universal4 View Post
    Its it not as simple as one rule regarding KYC but far too many worldwide, and they differ quite a bit in different companies. And whether you want to believe it or not, an affiliate does have a client/provider relationship with the affiliate programs. It doesn't matter really if you change the wording to sub-contractor/contractor or any other type wording.

    I liked the simplified explanations referenced here in what a few of the different rules contain. (obviously each individual company depending on where they are based, or what country a lot of their client connections come from may affect what they take on as company terms regarding verification procedures etc)
    https://www.trulioo.com/blog/kyc/


    While I agree what BGO is doing to use as an excuse to close accounts and seize funds certainly is not cool, I do think we all have to live with the fact that most affiliate programs have either already started to move toward or WILL move toward more strict verification procedures for all affiliates.

    Rick
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    Any opinion:

    - about programs never providing themselves what they try ask from affiliates?

    - about programs asking a ridiculous amount of unnecessary docs meanwhile paying affiliate commission via dodgy Costa Rica, Belize, Panama or Bitcoin constructions?

    - why it would be relevant to a affiliate program who is the UBO of an official registered company with an official TAX number

    - why it would be relevant to a affiliate program to get a Utility Bill (or any proof of address) of a Director

    Company and TAX details all are publicly available and checked yearly by registered accountants and tax-authorities of the country one has registered.... You really think John Doe the affiliate manager needs to check on them?!

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  10. #26
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    We all know how programs would react if as affiliates, we asked for documentation from them to fulfill our KYC requirements. The standard of what is reasonable would certainly be different.

    I understand the industry is changing and certain policies and procedure have to be implemented, but it seems there are programs that use these changes to their advantage and blame them as an excuse for their bad behavior.

    Just my personal opinion.
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  12. #27
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    Quote Originally Posted by Anthony View Post
    We all know how programs would react if as affiliates, we asked for documentation from them to fulfill our KYC requirements. The standard of what is reasonable would certainly be different.

    I understand the industry is changing and certain policies and procedure have to be implemented, but it seems there are programs that use these changes to their advantage and blame them as an excuse for their bad behavior.

    Just my personal opinion.
    Great, so I assume GPWA asks all their sponsors exactly the same docs (your customers not?) and kicks out all of them who refuse to deliver?

    ps. Since they pay you a fair amount do not hesitate to ask for:
    - Proof of Incorporation
    - Director Register: Each director listed on the director register will need to provide a copy of his/her ID and proof of address
    - ID: A passport or ID card that must not expire within the next 6 months
    - Proof of Address: for example, a utility bill no older than 3 months. The ID and proof of address must match the details on the Director Register


    Please ensure that these documents are in English. If they are unable to provide the documents in English, then they will need to be certified by a notary or lawyer before they are sent to you.


    If for any reason they are unable to provide these corporate documents, they are then required to send the following documents:
    - ID: A passport or ID card that must not expire within the next 6 months
    - Proof of Address: for example a utility bill no older than 3 months
    - Proof of Payment Details: a bank statement no older than 3 months and clearly show the name, address and bank account number. The screenshots will need to be certified by a notary or lawyer.


    The documents should be:
    Sent via an attachment in either a JPEG, BMP or PNG format.
    The documents are not to be tampered with.
    The documents are to show all 4 corners.
    The documents are to be in colour.
    The documents are not to be scanned.
    Last edited by affy; 6 April 2019 at 3:56 pm.

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  14. #28
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    Quote Originally Posted by FictionNet View Post
    So are the programs lying and illegally closing accounts? Has anyone SEEN anything in writing that tells the aff prog that they require their affs passports and bank statements?

    The convo kinda stops until that question is answered.
    Yes
    In the US, the CIP mandates that any individual conducting financial transactions needs to have their identity verified. Provisioned in the Patriot Act, the CIP is designed to limit money laundering, terrorism funding, corruption and other illegal activities.
    Since most countries have similar rules in place, an affiliate program that "pays" affiliates is just covering themselves in advance by wanting to follow "KYC" or similar rules, since even if the particular rule in place in that country, may or may not define what a "customer" is, I think almost all of them can interpret it to mean any individual or company that is paid or has other financial transactions with them.

    https://www.govinfo.gov/content/pkg/...sec103-121.pdf

    I agree that some programs may be over-reaching a little too far, but it has become something more an more programs are have or planning to adopt, I do think we need to accept the fact.

    I think adding watermarks or additional images or words to the document scans is a great idea.

    Rick
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  16. #29
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    Any opinion:

    - about programs never providing themselves what they try ask from affiliates?
    Yes, I think it would be great if this, or at least a portion of some form of this could be provided as to allow more transparency as to who is behind the affiliate program or corporate entity in control of the program, but that may be a little longer in comping.

    Although I do think in some cases some will say they will not comply, and that affiliates are free to choose who they want to promote.

    Rick
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  17. #30
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    Quote Originally Posted by FictionNet View Post
    Noone seems to have answered this either: "If it's a legal requirement to have my ID, then about 96 of 100 programs I work with are breaking the law. I even asked some directly. Nope, not needed legally, they tell me."

    So are the programs lying and illegally closing accounts? Has anyone SEEN anything in writing that tells the aff prog that they require their affs passports and bank statements?

    The convo kinda stops until that question is answered.
    I'll have a go - are your 100 programs UKGC licensed?
    MY UK licensed and domiciled programs (currently at four plus two others which I have discontinued) have asked for ID.
    Interestingly in 2017 BetVictor called their KYC compliance Know your COMPANY.

    I also had an outfit based in Malta (Interwetten) that wanted notarized copies and a notarized police report.

    Programs in Australia are mixed - Ladbrokes Australia asked (UK lead direction?)- while Neds / Casino Rewards have not.

    Curacao, and Costa Rica companies have not bothered.
    Although Pinnacle did ask for a utility bill with name and address when making a big payment from my player account - so they have some KYC.

    I expect each jurisdiction has it's own laws and implementations of compliance.
    And it may also have something to do with the amount of funds being sent.
    Last edited by TheGooner; 6 April 2019 at 8:00 pm. Reason: more as I checked my email archives.

  18. #31
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    Quote Originally Posted by TheGooner View Post
    I expect each jurisdiction has it's own laws and implementations of compliance.
    In relation to affiliates: Where are these documented LAWS, programs are using, to demand affiliates, supply KYC ID docs? Someone, anyone, please post a link to these relevant jurisdiction, Government passed laws for affiliates...

    Last month hadn't been paid by Rewards, hence contacted AM, only to be told they just received (5 days later) notification from their 3'rd party processor KYC Docs were required, before future payments are released.

    Was happy to supply... However before sending, wanted to know how my personal info was being handled, stored etc., etc., by said "3'rd party processor". I think that's a fair and reasonable request.

    Bare in mind, this wasn't a request directly from RA, instead, a supposed demand from their 3'rd party processor. The link I received from my AM, wasn't to the 3'rd party processor, but instead, RA's own privacy policy.

    Reiterating, nothing to do with this supposed 3'rd party processor.

    It's not chump change, so I had two choices: bow to this demand, or wave adios to $xxx,xxx are year. Even though I had no idea who their 3'rd party processor was, or more importantly, how my private ID was being handled, stored etc., etc.

    Bad enough in ever day life,when you have to ensure your card's are not being skimmed at the ATM, or some other low-life-crook, is riffling thru your letter box etc., etc. Identity fraud is riff these days.

    IDK about others, but I value my personal data security.

    The OP (and other affiliates) are questioning the validity of these supposed ID checks. Without sighting an relevant Government "laws" specifically stating AFFILIATES must adhere to KYC, I'm too am now holding 'doubt' to legitimacy of these KYC demands.

    Reiterating... Where are these documented LAWS, programs are using, to demand affiliates, supply KYC ID docs? Someone, anyone, please post a link to these relevant jurisdiction, Government passed laws for affiliates...

    NB - Opinions, we can argue till the cows-come-home. Facts on the other hand, we can't. Show me the laws???!!!
    Last edited by AussieDave; 7 April 2019 at 1:23 am. Reason: typos
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  20. #32
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    Quote Originally Posted by TheGooner View Post
    I'll have a go - are your 100 programs UKGC licensed?
    Yes. And some told me its a cash-grab by programs as docs are not legally required.

    eta. I'll go a bit further. Veterans on the casino side have "promised" (their word) that they've not been asked for docs and that this is a cash-grab. Yes, UK licensed. No, I won't name them.
    Last edited by FictionNet; 7 April 2019 at 4:57 am.

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  22. #33
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    Quote Originally Posted by AussieDave View Post
    Reiterating... Where are these documented LAWS, programs are using, to demand affiliates, supply KYC ID docs? Someone, anyone, please post a link to these relevant jurisdiction, Government passed laws for affiliates...
    Good luck with that ... I'd have no idea where to find internet linked copies of the full local NZ statutes - or indeed how to interpret the full bills that get produced - let alone governments from other countries.

    Here is the closest thing / most useful thing I could find locally : (Department of Internal Affairs government website)
    https://www.dia.govt.nz/diawebsite.n...and-Guidelines

    It's a series of official guides and actions for AML/CFT (and KYC) and is about fifty documents long at present :
    Buried in the accountants guidelines from March 2018 (one of the PDFs listed there) is this phrase :

    Prescribed transaction reports (PTRs)
    A prescribed transaction is an international wire transfer of NZ$1,000 or more conducted through a reporting entity or a domestic physical cash transaction of a value equal to or above NZ$10,000.
    That low international transfer value means that it is pretty much most business with offshore funds - including affiliates.

    I see KYC in all forms of financial life now locally - it's appearing in real estate transactions - lawyer interactions - even my accountant. It does not specify affiliates specifically, but anyone making or receiving regular international transactions over $xxx is generally caught up in them.

    Just because I can't find a full copy of the law online easily doesn't make it any less real. I imagine that those fancy books and digests sitting behind my lawyer in a bookcase when I visit them have the printed versions.

    -----------------------------------

    Now NZ doesn't make these things up randomly. They've pretty much been forced into them by the OECD and UK / US / Australia in particular to make sure that they are not seen as a soft touch. I expect most governments to have similar statutes and guidelines for financial services.

    If other affiliates could try and find local government repository sites (like the one above) for their own country then we could build a base of knowledge.
    Last edited by TheGooner; 7 April 2019 at 5:35 am. Reason: more detail

  23. #34
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    Quote Originally Posted by FictionNet View Post
    Why don't you know how to use the Wayback Machine to see these terms were not in place when I joined BGO?
    https://web.archive.org/web/20150403...ies.com/terms/

    I totally give up. You deserve what's coming to you.

    Now I really am out.
    Terms and conditions arent written in stone, especially not in a volatile industry like igaming. If for instance the UK Gambling Commission announces new rules which online operators must follow, this also will affect you as an affiliate. Same goes for the Patriot Act and other stuff...

    I completly agree, that the potential seizure of your funds - if you would not get back to BGO within 7 days - should be considered to be unethical. It s bad business practise for sure - no doubts from my end.

    Having said this I completly understand the need for a KYC process on the operators side. Watermarks are one good way to add another layer of security to your personal data. Other ways are to operate a company (Its not rocket sioence, why not investing 2500 € for a limited in cypress? 12,5 % flat tax doenst sound that bad) or to agree on a individual solution with the affiliate programm.

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    Quote Originally Posted by casinoFM View Post
    Terms and conditions arent written in stone.
    After making yourself look stupid not knowing about the Wayback Machine, you come back with an even more unintelligent remark.

    You don't deserve any more of my time, amateur. Blocked.

  25. #36
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    Quote Originally Posted by AussieDave View Post
    Reiterating... Where are these documented LAWS, programs are using, to demand affiliates, supply KYC ID docs? Someone, anyone, please post a link to these relevant jurisdiction, Government passed laws for affiliates...
    UK Government Money laundering requirements. https://www.gov.uk/guidance/money-la...sponsibilities

    UK - Who needs to register https://www.gov.uk/guidance/money-la...ds-to-register

    Pretty much covers who and why. Affiliates, although not explicitly named, are customers engaged in financial transactions with companies supervised by the Gambling Commission, therefore the companies have to comply by Law.
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    Reiterating: I don't promote to the UK, EU, including AU... All aforementioned countries are blocked on my sites. All affiliate programs I work with are fully aware of this fact.

    Quote Originally Posted by nwalker View Post
    Pretty much covers who and why. Affiliates, although not explicitly named, are customers engaged in financial transactions with companies supervised by the Gambling Commission, therefore the companies have to comply by Law.
    Thanks for posting the links

    However, affiliate are not customers. We're connect solely as B2B (business to business).

    Using your mindset, and given these igaming entities are licensed and regulated by the "Gambling Commission", then any ads they run on UK TV, newspaper ads, PPC on Google, subway poster ads, marketing companies, you name it, any and all business conducted with anyone, anywhere...

    What you saying: is in these instances, every UK licensed igaming/affiliate program, is required by "law" to conduct KYC on ALL of these businesses they deal with. Because according to you, "financial transactions" take place between these parties.

    I'll bet my bottom dollar, that none; zip; zilch; nadda, KYC checks have taken place on the aforementioned B2B companies.
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  28. #38
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    Quote Originally Posted by FictionNet View Post
    its a cash-grab by programs
    Of the emails I've received, demanding KYC (all accept Rewards - which wasn't an email: my AM only said if I don't supply KYC I may not receive payment/s )... However, every other one received, has stated or eluded to, if I don't supply documents within the specified time period, my aff account will be closed. Which also means, my rightful commissions for the life of each player, will also be forfeited... aka STOLEN.

    If this doesn't stink of a cash-grab, I don't know what does.

    Seems most affiliates have short-term-memory issues. I say this, because how many programs make up their own rules (and laws too)???!!!

    And, if that doesn't wash, then they either rebrand and issue new T&C's, which come with the Caveat: If you don't agree to these terms, then your account is closed...Or they set unrealistic quotas (for today's market) and f#ck people over anyway... That STINKS of a CASH GRAB TOO!

    NB - Old-timers like myself, others & including FictionNet, joined programs in the infancy of this industry (circa 2000). In most cases, the T&C's we agreed to, didn't have any of the HorseSh#t, or FU type clauses, which are in most aff program T&C's today. Use the Wayback Machine, and see for yourself.

    The ONLY UK licensed igaming entity NOT to seize ALL funds of an affiliate (Shay) was FullCreamAffiliates. AFAIK (if I have this correct?) Shay's account was closed... BUT was paid, and continued to receive commission on past players, before this (supposed) KYC check came into place.

    @Shay - maybe you'd like to elaborate on this?
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    Quote Originally Posted by casinoFM View Post
    Watermarks are one good way to add another layer of security to your personal data.
    I can assure, NO igaming entity or affiliate program, would accept a Doctor (watermarked) Document. Their UBER AN#L, even about a slight discoloration, or even a reflection of one's thumb etc., etc., in the hologram on a visa card. If you've been paying attention to this thread, or I'll others on the same topic, some affiliates have even been told to supplied notarized "police checks" and other BS docs.
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    Quote Originally Posted by FictionNet View Post
    After making yourself look stupid not knowing about the Wayback Machine, you come back with an even more unintelligent remark.

    You don't deserve any more of my time, amateur. Blocked.
    This escalated quickly

    Anyhow, i dont see any reason for getting personal here. And i doubt i qualify as an amateur since i worked for almost 10 years in Malta, Gibraltar, Hamburg and then Malta again for several big regulated operators, before i decided to start with affiliation myself. FictionNet might have had a wonderful time during the hay days...but these are over and will never come back.

    The future of iGaming - at least in Europe - is in regulated markets. This means not only smaller revenue for us affiliates, but also more compliance, transparency, player and minor protection and proffesionalism. And yes, KYC - although we still can discuss in which form it should be carried out and how casino programs have to store and protect our personal data - is part of it.

    Banner farms and poor websites advertising dodgy casinos without or with weak licences and poor business ethics will hopefully belong to the past. And in a couple of years the igaming industry, the players and the honest affiliates will benefit from that. The success websites like theppogg.com are having by offering additional value to their readers is great to see. And these affiliates will continue growing and play a major role.

    Having said this i completly understand the concerns affiliates have. I still do not understand why for instance the regulatory bodies demand an automatically added watermark when uploading documents to a casino site or better general data protection of these documents. I completly agree that among those affiliate managers are several not trustworthy clowns. But still: This all doesnt mean that we as affiliates dont have our own duties and responsibilities. I dont mind FictionNet calling me a sheep for following those. I now my numbers, i know my mission with my website, and i am more than optimistic regarding the next years. The market is changing, and so do we have to.

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