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  1. #41
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    Quote Originally Posted by AussieDave View Post

    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?
    This is accurate. Full Cream Affiliates closed our account. They specifically told us in the boiler plate email that all accounts, despite being closed, would be paid on existing customers. Bet the farm that they were good to their word, as we got paid a few times since then.

    My experience with bgo is that they love to retroactively adjust things. It is not beneath them to do a cash grab. When two businesses in the US do business with each other, often a w-9 form is requested. The w-9 form is a request for taxpayer ID number and certification. You put your company info there, your company's registered address, and your EIN. Then you sign stating it is true and correct under penalty of law. The company paying out retains that record for their files. In the event they are audited or in the event that records are requested (say, due to questionable business activity), they provide these forms as supporting evidence on who they are doing business with. Please note, there's no request for passports, there's no utility bills requested, there's no fact check. There's a standard form, which the receiving company fills out and signs, under penalty of law. Anything above and beyond that, unless you're the bank or the tax man, is bullshit and unnecessary. I suspect in the UK there is similar and I also suspect that anything beyond in terns of playing the KYC card is also bullshit.

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  3. #42
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    Funny how some people here try to defend operators that are abusing (I'd say blackmailing!) them. Yet not a word from those people on the fact some of those programs paying out via dodgy construction, have no security in place overseeing who has access to those docs and for sure themselves will never EVER provide what they ask from affiliates

    Why would you even think for a second to provide someone with docs that they will NEVER hand over to you themselves?!

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  5. #43
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    Quote Originally Posted by affy View Post
    Funny how some people here try to defend operators that are abusing (I'd say blackmailing!) them. Yet not a word from those people on the fact some of those programs paying out via dodgy construction, have no security in place overseeing who has access to those docs and for sure themselves will never EVER provide what they ask from affiliates

    Why would you even think for a second to provide someone with docs that they will NEVER hand over to you themselves?!
    I find all this extremely troubling as well.

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    Quote Originally Posted by casinoFM View Post
    websites advertising dodgy casinos without or with weak licences and poor business ethics will hopefully belong to the past.
    It's all good and well to state stuff like this BUT FYI there have been a number of licensed and supposedly regulated casinos who have literally shafted affiliates, by closing accounts (not related to KYC) stealing their players, and their promised life time revenue. Ladbrokes (aka GVC Holdings) to name but one. You can't get more "dodgy" and unethical than that. Actually, it's downright criminal fraud and theft.

    Truth be know, given you've worked for numerous "licensed" operators, then it's possible you've directly or indirectly assist in similar shaftings.

    Anywho...your points are ALL moot points.

    Ladbrokes are Rogued:
    https://www.affiliateguarddog.com/co...-partners.227/
    Last edited by AussieDave; 8 April 2019 at 3:53 pm. Reason: grammatics
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  9. #45
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    Quote Originally Posted by AussieDave View Post
    It's all good and well to state stuff like this BUT FYI there have been a number of licensed and supposedly regulated casinos who have literally shafted affiliates, by closing accounts (not related to KYC) stealing their players, and their promised life time revenue. Ladbrokes (aka GVC Holdings) to name but one. You can't get more "dodgy" and unethical than that. Actually, it's downright criminal fraud and theft.

    Truth be know, given you've worked for numerous "licensed" operators, then it's possible you've directly or indirectly assist in similar shaftings.

    Anywho...your points are ALL moot points.

    Ladbrokes are Rogued:
    https://www.affiliateguarddog.com/co...-partners.227/
    Shaping Affiliates, retagging customers, the introduction of the Admin fee, subsequent "amendments" of the terms and conditions to the disadvantage of the affiliate and other breaches of contracts from the operators site are simply not acceptable. Although I always try to see the operators site and the customer as well, I couldn't agree more on that.

    Here smaller affiliates have to take an active stand against it and fight back. Spreading information about unethical behaviour of operators such as Ladbrokes or skybet is one of the biggest assets of this forum and was one of the main reasons for me to sign up here. I am thankful to benefit from your experience, so i do not do the same mistakes some of the members here in this forum had to go through.

    However, the case of this thread is a bit different. BGO did not seize affiliate earnings but threatened to do so if the affiliate wouldn't get back to the affiliate manager and continues with a KYC process according to the operators standards. While I see the threat and the 7 days deadline itself as a bad move from BGOs side, i struggle to agree that this is a clear case of seizure of the affiliates earnings since he still would be entitled to it if he continues with the KYC process.

    Furthermore I wonder why an affiliate doesn't mind earning money by sending his readers and subscribers to an operator where they have to submit documents if he wouldn't do the same because he doesn't trust their data protection. This is clearly double standards. Again, BGO did not reduce their commission rates retroactively but adjusted the terms and conditions as more or less required to the law. This is really bugging me.

    I only promote operators where i know people personally working for. I try to keep a professional, friendly and honest business relationship with them and communicate regularly (which is quite easy here in Malta, since u bump into these guys anyways quite often ). In case I wouldn't be happy with one of their decisions, first of all I would either meet up with them in person or at least discuss this via skype on the phone. But immediately posting the whole (?) story here on GPWA and a bad review on my own sites(although the quality of the product BGO didn't change at all) is immature. My 11 years old niece would do that, but from a business partner I personally would expect better.


    Affiliates are not the white knights (during the 10 years working for operators i encountered hundreds of cases of affiliate fraud and other behaviour), and Operators are not the bad guys in general. And lets not leave out the most important party - the customer itself. Responsible Gambling, honest information and fair play should never be platitudes. Being affiliates, many of you guys never or only to a certain extend had to deal with the down sides of gambling such as the impact addiction can have on gambling addicts, money laundering or minors gambling, to just mention a few. It is not only about money. A good affiliate takes over responsibility for his content.

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  11. #46
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    Quote Originally Posted by casinoFM View Post
    Shaping Affiliates, retagging customers, the introduction of the Admin fee, subsequent "amendments" of the terms and conditions to the disadvantage of the affiliate and other breaches of contracts from the operators site are simply not acceptable. Although I always try to see the operators site and the customer as well, I couldn't agree more on that.

    Here smaller affiliates have to take an active stand against it and fight back. Spreading information about unethical behaviour of operators such as Ladbrokes or skybet is one of the biggest assets of this forum and was one of the main reasons for me to sign up here. I am thankful to benefit from your experience, so i do not do the same mistakes some of the members here in this forum had to go through.

    However, the case of this thread is a bit different. BGO did not seize affiliate earnings but threatened to do so if the affiliate wouldn't get back to the affiliate manager and continues with a KYC process according to the operators standards. While I see the threat and the 7 days deadline itself as a bad move from BGOs side, i struggle to agree that this is a clear case of seizure of the affiliates earnings since he still would be entitled to it if he continues with the KYC process.

    Furthermore I wonder why an affiliate doesn't mind earning money by sending his readers and subscribers to an operator where they have to submit documents if he wouldn't do the same because he doesn't trust their data protection. This is clearly double standards. Again, BGO did not reduce their commission rates retroactively but adjusted the terms and conditions as more or less required to the law. This is really bugging me.

    I only promote operators where i know people personally working for. I try to keep a professional, friendly and honest business relationship with them and communicate regularly (which is quite easy here in Malta, since u bump into these guys anyways quite often ). In case I wouldn't be happy with one of their decisions, first of all I would either meet up with them in person or at least discuss this via skype on the phone. But immediately posting the whole (?) story here on GPWA and a bad review on my own sites(although the quality of the product BGO didn't change at all) is immature. My 11 years old niece would do that, but from a business partner I personally would expect better.


    Affiliates are not the white knights (during the 10 years working for operators i encountered hundreds of cases of affiliate fraud and other behaviour), and Operators are not the bad guys in general. And lets not leave out the most important party - the customer itself. Responsible Gambling, honest information and fair play should never be platitudes. Being affiliates, many of you guys never or only to a certain extend had to deal with the down sides of gambling such as the impact addiction can have on gambling addicts, money laundering or minors gambling, to just mention a few. It is not only about money. A good affiliate takes over responsibility for his content.
    bgo is a rogue outfit. They have, in the past, seized earnings via the old change in terms and conditions retroactively - discussion.

    With respect to kyc and documents - the players we send are customers (kyc is appropriate). WE as affiliates are not customers. We are technically vendors or service providers. Thus, kyc is not appropriate.

    If their corporate office calls on Joe the plumber to unclog their affiliate manager's toilet because it is clogged with bullshit, they do not perform KYC on turd chasing Joe. No, Joe comes in, unclogs the crapper, and leaves a bill for services rendered. They then pay out to Joe's company for getting rid of the bullshit clogging the pipes (services rendered). They do not slow roll him or threaten him by saying "you have seven days to provide either photo id or proof of corporate ownership along with a newspaper dated for today and an electric bill with proper address, and a fully notarized note from God, and a picture of Earth from space, which better be shown as being flat because we all know the Earth is flat. If it looks round, we'll know it is not a real picture and we'll seize your earnings).

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  13. #47
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    Quote Originally Posted by -Shay- View Post

    With respect to kyc and documents - the players we send are customers (kyc is appropriate). WE as affiliates are not customers. We are technically vendors or service providers. Thus, kyc is not appropriate.
    If the operator is following the UKGC Guidance KYC http://www.gamblingcommission.gov.uk...-operators.pdf it's understandable why they are including 3rd Party Relationships.

    Quote:

    All gambling operators have a responsibility to keep financial crime out of gambling.

    TheProceeds of Crime Act 2002 (POCA)1 places an obligation on gambling operators to be alert to attempts by customers to gamble money acquired unlawfully, either to obtain legitimate or 'clean' money in return (and, in doing so, attempting to disguise the criminal source of the funds) or simply using criminal proceeds to fund gambling. Both modes of operation are described as money laundering.

    1.2 This advice document explains how operators can make sure they and their employees comply with their obligations under POCA. It sets out a number of matters operators need to be aware of and explains their duties and responsibilities under POCA.

    1.3 While the advice focuses primarily on the relationship between operators and their customers, and the money laundering risks presented by transactions with customers,operators should also give due consideration to the money laundering risks posed by their business-to-business relationships, including any third parties they contract with.
    Last edited by nwalker; 9 April 2019 at 8:26 am.
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  15. #48
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    I was about to post that BGO have already ripped off affiliates by retroactively changing commission rates a few years ago but Shay beat me to it. So none of this should be any surprise to anyone.

    Quote Originally Posted by casinoFM View Post
    I only promote operators where i know people personally working for. I try to keep a professional, friendly and honest business relationship with them and communicate regularly (which is quite easy here in Malta, since u bump into these guys anyways quite often ). In case I wouldn't be happy with one of their decisions, first of all I would either meet up with them in person or at least discuss this via skype on the phone. But immediately posting the whole (?) story here on GPWA and a bad review on my own sites(although the quality of the product BGO didn't change at all) is immature. My 11 years old niece would do that, but from a business partner I personally would expect better
    With all due respect this philosophy is pretty naive. I have been at this for over a decade now and have learned many things. Some of the most important are that affiliate managers are not my friends, affiliate programs are not my business partners, and that I am most certainly not a casino promoter. The success of casinos and their employees is not my concern, nor ultimately is my success their concern no matter what they claim. What is my concern is giving players good advice so they can make informed and safe decisions with their money. So you better believe that if a program rips me off, it demonstrates quite clearly that they cannot be trusted, therefore players should be warned. Don't make the mistake of thinking you have a special relationship with any of these people you think are your friends. You're bent over just waiting to be shafted. Stay at this long enough and it will happen sooner or later, believe me.

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    Quote Originally Posted by nwalker View Post

    1.3 While the advice focuses primarily on the relationship between operators and their customers, and the money laundering risks presented by transactions with customers,operators should also give due consideration to the money laundering risks posed by their business-to-business relationships, including any third parties they contract with.
    Money laundering is attempting to put dirty money in to get clean money out, so the above point should not apply to affiliates.

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    Quote Originally Posted by DaftDog View Post
    Money laundering is attempting to put dirty money in to get clean money out, so the above point should not apply to affiliates.
    Exactly!


    For people in this thread, who seem unable to grasp the correct meaning of "money laundering"... Programs pay affiliates, not the other way around. Hence, it's not the money affiliates receive. But instead, it's the source of where this money originates from.

    And where does this money leave from? The affiliate programs.
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    Quote Originally Posted by AussieDave View Post
    Exactly!


    For people in this thread, who seem unable to grasp the correct meaning of "money laundering"... Programs pay affiliates, not the other way around. Hence, it's not the money affiliates receive. But instead, it's the source of where this money originates from.

    And where does this money leave from? The affiliate programs.
    I think we understand the term Money Laundering. However it doesn't matter what you or anyone else thinks, if a program wants affiliates to go through some process, however they wish to dress it up, affiliates can either suck it up or move on.

    If the UKGC is giving out advice, then some programs will follow it.

    I'm not saying that's right, but that's the reality of working as an igaming affiliate.
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  23. #52
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    Quote Originally Posted by Muppet View Post
    With all due respect this philosophy is pretty naive.
    https://andrewgoutman.com/rolling-st...-klein-battle/

    (February 24, 2015) After countless lawsuits, verdicts and settlements (26 in all counting the Beatles), as each party licked its wounds and counted casualties in terms of lost property, wasted time and treasure, perhaps it was the Stones’ guitarist Keith Richards who summed up the battle best: it was “the price of an education.”

    And a severe price it was for the Rolling Stones.
    @Muppet - It's pointless wasting your breath, it seems casinoFM knows everything. No point trying to help someone like this.

    At some point (likely sooner than later), one of his buddy business alliances will do a 'Rolling Stones' on him. Only then will he understand what we've been trying to explain. Maybe that will make him realize... It doesn't matter who you know, because when greed and money combine, those calling the shots, don't care about anyone other than themselves.
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    Quote Originally Posted by AussieDave View Post
    Exactly!


    For people in this thread, who seem unable to grasp the correct meaning of "money laundering"... Programs pay affiliates, not the other way around. Hence, it's not the money affiliates receive. But instead, it's the source of where this money originates from.

    And where does this money leave from? The affiliate programs.

    An affiliate website can easily be used to launder some money.

    But I find it pathetic if companies, whose owners cannot even be traced with the Offshoreleaks page are asking me to show who I am. While if I ask them the same, they do not answer.

    I do not work with the "buddies" of BDO, but usually, I have not a contract with the casino itself, but with some postbox company in Curacao, Belize, BVI, etc. So I do not see what UKGC has to do with it if it's not about UK traffic...

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    It's not just the programs .... it's the money remitters themselves.

    Just received notification from Casino REwards today that their payment processor wants company extract details and an ID for every transaction that goes offshore for more than $1000 (don't know if that's US, NZ or AU).

    That's clearly related to the extract I quoted above (or page 2) ... on AML and there is no wiggle room.
    Provide Identification or DO NOT GET PAID IN CASH.

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    Quote Originally Posted by Triple7 View Post
    An affiliate website can easily be used to launder some money.
    The local fish n chips shop (or business dealing in cash) could be front for a drug-dealer. Hence, that dirty money (cash) gets injected into said shop, and that money is declared as income. The owner pays tax on it, and the money comes out clean.

    It's why they call it "money laundering"

    Reiterating: it's the original source of funds. In this case...money being sent to affiliates. The program needs to provide information where this money originated from. The affiliate doesn't have to prove jack-squat, to the aff program.

    The onus is the program to prove this money is not garnished from illegal gains.

    Edit: Stated in this thread, and others like it, no program would supply ID docs to affiliates. Even if affiliates Country's B2B Laws required it. As I and others have said, these KYC and other BS, programs throw at affiliates, is nothing more than an excuse to pillage and commission-**** affiliates.
    Last edited by AussieDave; 10 April 2019 at 5:34 am. Reason: Edit:
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    Just as an aside.

    My Bank - HSBC, sent me a letter just before xmas, saying that i had to provide information on where the money in my Business Bank Account came from. If I didn't comply they would close my account on the 1st Feb and return my balance to me.

    Of course i complied. I had to state where the funds came from, the countries where i had business relationships with and the %. They went through my transactions and I had to explain line items - why i transfer money between accounts etc. I felt completely exposed, as without a business account I couldn't operate and given the source of funds I was worried i'd get shut down. Fortunately everything was ok and i've been able to keep my business account.

    However there was a real possibility that i would have had to get info from the Affiliate Programs to provide the proof.

    So I'm better off working with the ones that have compliance teams and are regulated as I'll be better able to get that info (hopefully). Working with unregulated progs is now more of a risk for my business if i can't prove to my business partners in this case my Bank where my funds come from.

    I'm based in the UK btw and have a UK registered business. It may be different for where you are, but they are the challenges I face in operating my business.

    As for the progs I work with, I have to do a risk assessment each time I think about working with someone new - and you know what, I'm still going to get screwed over by someone - that's why i spread my risk so when I do get screwed it won't have a big impact.
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    Quote Originally Posted by nwalker View Post
    I think we understand the term Money Laundering.
    I'm sure you do, my comment was not aimed at you, so nothing personal. I thought it best to resort to basics so some people could understand that affiliates are not the source of potential money laundering.

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    Quote Originally Posted by DaftDog View Post
    I'm sure you do, my comment was not aimed at you, so nothing personal. I thought it best to resort to basics so some people could understand that affiliates are not the source of potential money laundering.
    No problem, I didn't take it any way

    It's a difficult situation, while the letter of the law, requirement or language is very clear, the application of it is not being consistently applied by operators. The additional "guidance" provided by the UKGC however well intentioned adds another layer that leads to further confusion.

    I mention the UKGC only because I do business with operators bound by their rules. - They may not apply or are different elsewhere - which again is more confusing.
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    Quote Originally Posted by AussieDave View Post
    Exactly!
    Quote Originally Posted by AussieDave View Post


    For people in this thread, who seem unable to grasp the correct meaning of "money laundering"... Programs pay affiliates, not the other way around. Hence, it's not the money affiliates receive. But instead, it's the source of where this money originates from.

    And where does this money leave from? The affiliate programs.
    I can think of a lot of constructions involving iGaming affiliation in order to commit money laundering. And believe me or not, it happened and it is still happening. Here is an example which was working several years ago (shouldnt work today unless the operator is completely stupid). A fraudster managed to obtain fraudulently lets say 35 Romanian ID sets (id cards, photo id, proof of address) and creates accounts using his affiliate link, deposits with anonymous payment methods and cashs out. To not raise any concerns he fakes legit player and affiliate account activity as well. In case the funds he is using is coming eg from criminal source, the winnings of his fake accounts plus the affiliate commission he receives is clean. Long story short: The fraudster managed in this example to hide the origin of the funds going to his affiliate account. And this is called money laundering.

    Please understand that i dont want to give more recent examples for money laundering using or involving affiliate accounts. This forum shouldnt be about unlawful practises to commit money laundering.

    Besides money laundering, also fraud is something Affiliates can simply not ignore. There are thousands of affiliates out there defrauding operators and other affiliates (hacking, content theft, identity theft, Spam). Happened to me as well. I contacted the affiliates the clowns who had copied my site were trying to send traffic to, and the affiliate teams of the casinos involved shut those affiliate accounts down.

    In case Affiliates do not operate established businesses, a KYC might be one potential way to add another layer of security. Many operators use the KYC check to perform anti fraud checks.

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    Its called due dilligence for partners, contractors or whoever you gonna work with or sell something

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