In this episode, we break down the licensing process, the role of key regulators (AGCO, iGO, FINTRAC), and essential strategies for compliance and AML.

Guest: Mondiu Jaiyesimi, Senior Manager of AML Regulatory Compliance and Forensics at MNP

The iGaming Show, presented by Paramount Commerce, is a podcast that will analyse gaming industry trends with experts from various gaming organizations.

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Full episode transcript:

Varad Mehta: Hello everyone, and welcome to the 20th episode of the iGaming Show presented by Paramount Commerce. I’m your host, Varad Mehta and in this podcast, we analyse gaming industry trends with experts from various gaming organisations. In today’s episode,we’ll explore the importance of AML and compliance in a regulated iGaming market with Mondiu Jaiyesimi the Senior Manager of AML Regulatory Compliance and Forensics at MNP. So without further ado, let’s get the show rolling. Okay, so Mondiu, how we always begin this podcast is by asking you a few fun questions. So first of all, I have to ask Kilonshele

Mondiu Jaiyesimi: How did you get that question?

VM: I just wanted to ask you, Kilonshele.

MJ: That’s really funny. How would you want me to respond?

VM: How would you respond? If there was a one way you could respond back to Kilonshele would be the correct way to say it? “All good.”

MJ: Yeah, all good. In English, all good. In Yoruba language, you can say (speaking in Yoruba)

VM: Okay, love it. So that is Yoruba lessons for people who just tuned into the episode. Technically, not my first fun question, but this is the first one that I had for you on a deeper level. You lived in Nigeria. You lived in the United Kingdom and Canada. So in each country, what are some important lessons you learned that really shaped you as a person?

MJ: Oh, wow. That’s a good question. Wow. How do you start? I mean, growing up in Nigeria, I completed my first degree in Nigeria. I attended a British-style boarding school. It’s a grammar school. It’s a boys-only school and really shaped my mentality in terms of discipline and perseverance and that thinking of knowing you can really do anything if you put your heart to it. It was a critical step in my development and shaped me to the person I am today. And then in England, yeah, England just made everything make more sense. So England was, it was almost perfect because the way I envisioned Nigeria, England was like an advanced Nigeria, if I can put it that way. I didn’t experience a lot of cultural differences, maybe because our educational curriculum, British, the schools I went to and everything, it was all British curriculum. So the culture wasn’t different either in terms of the way people spoke, the things we had learnt before. But one thing I really liked was how polite people were at the time, because I arrived in England in 2010, so people were really polite, and I lived in Guilford, schooled at the University of Surrey.

So it was quite interesting. And then Canada is different. Canada is North America. So there’s a lot of cultural nuances that you have to learn. I understood pretty quickly that this is a completely different ball game. But I met a lot of nice people as well as I started walking my way through the Canadian system. I would say the similarities that I found, it’s like people are nice. Canadians generally can consider Canadians to be nice. So I thought that was fun. And professionally, I think Canada helped shape my professional, the way I view my professional journeyshaped it shaped the a lot quicker for me than when I was in the UK.

VM: Wonderful. Thank you for sharing Mondiu. Thank you so much.

MJ: You’re welcome.

VM: And now going to the topic of discussion, something that is so important and not too much talked about, which is AML and compliance. And for iGaming operators moving into a regulated market, what are some basic things they need to understand? So my first question for you, Mondiu, would be, what are some of the biggest challenges right now that operators are facing when they’re applying for an iGaming license in a regulated space like Ontario?

MJ: Well, that’s a loaded question. So for you to obtain a licence, you have to go through the AGCO and iGO (iGaming Ontario). So a couple of things to understand. So the AGCO regulates iGaming in Ontario, and iGO manages all the operators. So that’s a key distinction between the two. But for you to get a licence, you have to go through iGO and the AGCO. So the iGO market was established in 2021, but the go-live, and what the go-live means operators that came into the Ontario market were able to go live on April 4th, 2022. So right now, we have about 50 operators and 84 gaming sites. So now, challenges that you can facecoming in, you have to be prepared because iGO maintains a strictand rigorous AML programme, and they follow the criminal codein Canada and the process Crimes of Crime, Money Laundering, and Terrorist Financing Act. So they are going to ensure that you comply with those obligations based on their policies and procedures, the AML policies and procedures, AML policy and their regulatory obligations that they follow. So a couple of things to put into consideration is that you have to be ready. So there are a couple of attestations that you have to that you have to have in handy. Those attestations include your training attestation. So first of all, you have to develop an AML programme. So that AML programme will include building your policies and procedures, risk assessment, and training. So that training has to go through an attestation. So you have to confirm that all your staff members have been trained. So that can be challenging if you’re not used to the Canadian AML landscape. Policies and procedures and risk assessment, you would pretty much complete a risk assessment attestation based on your business, based on who the players are going to be, the markets that you’re going to be operating in, and a few other factors to consider. And after that, you would have to go through what’s called a data and systems readiness attestation to confirm that your data and systems, your AML systems are ready and compliant with AML obligations. Those are a couple of things for you to consider. And then, of course, your staff or anyone that’s going to be responsible for accessing reporting tools. So we have what’s called a FWR. So that’s the FINTRAC Web Reporting tool. iGO would expect you to actually access that as well, and then you’ll be able to confirm that your staff or yourself as the compliance person can access it. Those are some of the things to consider, and they all come with their own challenges as well.

VM: And you mentioned AGCO and you mentioned iGO. But can you, Mondiu, also explain in simple terms how AGCO, iGO, and as you mentioned, FINTRAC at the end, how they work together to regulate Ontario’s gaming space?

MJ: Okay. So AGCO is the regulator. So AGCO is the licenced provider, if I can put it that way, for any iGaming operator that’s coming into the market. So AGCO should be considered as the regulator of the Ontario regulated market. And iGO is responsible for ensuring that each operator complies with regulatory obligations and they manage their operations as well. So before you are confirmed as an operator you have to sign an operating agreement with iGO, and then you have to obtain a licence with AGCO. Look at AGCO as the regulator that oversees compliance, and IGO is the subsidiary of AGCO that manages any entity or operator that deals in IGM in Ontario. Did that distinction make sense to you?

VM: Yes, that’s perfectly explained. And what role does FINTRAC claim on do in all of this?

MJ: So FINTRAC is the Canadian FIU. So what that means is the Financial Intelligence Unit of Canada, and it’s also so the enforcer of the Process of Crime, Money Laundering, and Terrorist Financing Act, the PCMLTFA. So FINTRAC regulates iGO because iGO is a reporting entity. So the operators are not reporting entities. So the operators do not report to FINTRAC directly. iGO reports to FINTRAC directly. And FINTRAC, under the PCMLTFA, categorises the Section 5 of the PCMLTFA categories reporting entities based on sectors. So the sector that the IGO falls under will be casinos. So all the regulatory obligations, the associated regulations, the PCMLTFA relating to casinos will apply to IGO, and FINTRAC will come in for an examination. FINTRAC can fine iGO if they find iGO to be non-compliant with regulatory obligations, and they can also provide support for them as well. Does that make sense?

VM: That’s a really good breakdown that you provided. I think it helps us envision what each player does within the regulated space. My next question, Mondiu, would be that even when I look at certain industry events right now, when it’s linked to iGaming, you see a lot of conversations about AML, which is Anti-Money Laundering. It’s a core piece that’s being spoken about within the industry. Can you perhaps share why it’s one of the most spoken about topics, and what are some key considerations that operators should know about AML and how they can be best compliant within a regulated space such as Ontario?

MJ: Okay, that’s a good question. So the reason anti-model laundering and anti-terrorist financing is important, I would say, is that it is crucial to protect the integrity of Canada’s financial framework and financial landscape. And gaming is one of the industries that is seen as potentially vulnerable to money laundering and terrorist financing. And I would say casinos and gaming in particular. So not just those industries. You would also have to consider the fact that we have more sectors that are vulnerable, however, it’s the government’s responsibility to ensure that…So when I say government, I mean in track, to ensure that any industry or sector that is vulnerable to money laundering or terrorist financing is identified, and there are risk-mitigating measures that are put in place. So one of those ways is to ensure that they are a reporting entity or they are regulated by the government,and they are subject to scrutiny, like examinations, and they also have to follow regulatory obligations. So for the key things to consider, if you are an igaming operator, you have to ensure you’ve appointed somebody to oversee your AML programme, so that would be a compliance officer. I don’t think I would even listen to you if you don’t have that in, and you also need an AML programme for you to receive your licence from AGCO and sign that operating agreement with iGO. So it’s absolutely crucial to have one in place. You would follow the policies and procedures and risk assessment guidelines that will be provided to you by iGO. And then, of course, you have to train. iGO provides you with the opportunity to use your own risk assessment, your own players. There are risk assessment considerations and methodology, but if not, you get to use iGOs. And then, of course, you also have to audit your AML programme on a periodic basis. So I think after four years, if you do it internally, after four years, you have to go out and do it independently. Those are the key considerations, but I can talk more about operating effectiveness as well and some of the issues that you can face.

VM: Yes, please. And even if you can mix it up with – because you’re an AML and compliance expert, we’ll also like to mix in compliance there. It’s something that we don’t talk about often, but it has such an important… It’s such an important backbone of the industry. So for operators, what are the best practises in maintaining regulatory compliance over time? And what role would someone like you would play in that space?

MJ: So we provide support to a lot of iGaming operators and any reporting entity that has to comply with FINTRAC’s guidelines. So where we come in, it ranges from if you need to audit your AML programme because it isa regulatory obligation for you to get that programme reviewed periodically, at least once every two years, and then if you’ve done it internally for four years, you have to get it done externally. So we provide that support as well. If you do not have adequate experiencewithin your compliance function, which is a common thing,it’s a common issue that we face, you can externally source professionalswho understand the regulatory requirements, the PCMLTFA,iGOs, AML/ATF policies and procedures and requirements, reporting obligations,you can hire somebody to provide you with that support, and it couldbe on an advisory level as well. If you go through an examination or review and you need to perform what’s called remediation validation, say you’ve provided, you’ve remediated all the issues found by iGO or any other regulatory body, we can help you provide that level ofvalidation mission and also report to any external party that mightbe looking for that. We also help with reporting with some additional level of quality assurance. But if you’re struggling to report to iGO, because as an operator, you can’t report directly to FINTRAC. You have to go through iGO. Even if you’re going to be using the FWRtool, you don’t have filing privileges, but you can impute the data and send it directly to iGO via FWR, we can provide that support to you as well. Those are some of the few service offerings that we’ve provided in this space.

VM: Yeah, and next question would be, what role does technology play in strengthening AML compliance for iGaming operators?

MJ: A lot. Technology plays a key role in ensuringthat iGaming operators can meet their regulatory obligations in in a reasonableway, because I think one of the first thingsto consider is your ongoing monitoring requirement as an iGaming operatorbecause you’re required to monitor your players’ activities and to ensurethat their KYC, their know your client or know your player data is up to date. So think about transactions, wadering activity in thousands, hundreds of thousands. If you are a big operator, how would you monitor those transactions? You can’t do them manually. This is where technology comes in. From a transaction monitoring perspective, you want to get in automated tools for monitoring transactions and flagging transactions that might be deemed to be potentially suspicious. There’s several tools that have artificial intelligence, machine learning, capability capabilities that can help you identify red flags or typologies like structuring, for instance. You can create a role that will be able to identify that for you. So iGaming it does rely on your transaction monitoring tools. There’s several tools that you can leverage, but it’s really, really important to have one that can provide you with really good quality alerts or transaction monitoring cases that you can adjudicate. And iGO will be looking into your tool as well to ensure it makes sense and it can be tested. So that’s transaction monitoring. Name screening also comes into play. Technology can help you really consolidate those risk factors that you’re worried about, like politically exposed persons, sanctions, negative news, there are watch lists, so you and you can have a tool that would scan your entire player databaseor that would screen a player’s name at onboarding and provide you with results. So it’s really critical if you have a tool, several tools out there that have that case management capability. So they can do name screening, and they can also do transaction monitoring, and it has the case management capability that allows you to create a case or create an alert. And then details of the adjudication will be provided, and there will be a clear audit trail, and everyone can actually see it. Another key role that technology plays is in reporting. So because you have all these transactions you have to report Casino Disbursement Reports to FINTRAC, for instance, via iGO, you need to be able to comply with the 24-hour rule. 24-hour rule comes in when you have multiple disbursement that total up to 10,000 within 24 hours. How do you track that? Manually, it could be impossible. You need to have systems in place that can do that for you automatically. So really smart systems can identify players and transactions within a defined time frame, and they will flag reportable transactions for you to then aggregate, validate, and then send off. Those are really key. And then you put all these competencies together and all these models together, you also have to be able to test. So iGO is particularly looking for the testing or model validation competencies right now. So during your effectiveness review, they will expect you to demonstrate how you are going to test, who is going to do the testing, and how you’re going to present the results just to ensure that those models or the systems are working as intended. So that’s the role that technology is playing now.

VM: Such a great breakdown you gave Mondiu and my last question would be, as you’re an industry expert, and even getting your expertise through AMLand compliance, are you or do you anticipate anyregulatory changes that could impact licencing or compliance or even anychanges you might be expecting within AML in Ontario’s iGaming market, and potentially there’s hopefully going to be more regulated markets. So do you anticipate any changes within this year or next year?

MJ: No. I mean, with respect to iGaming, we don’t anticipate anything major. I think the biggest change that’s currently affecting of the argument operators now is the cyber incident that FINTRAC suffered last year. So it really affected the ability of argument operators to report, and it also affected iGO. So there’s been some backlog, but I think it’s been resolved now, so we have to keep an eye on that. And then a couple of reports. So we moved from Gen1 reports to Gen2. So there’s been significant changes to the report format or the reports that go to FINTRAC. But FINTRAC has done a very good job in giving everybody time to get used to it. So iGO has gone through that as well to ensure everyone’s ready to report. Another one is the sanctions evasion. So sanctions, regulatory compliance is now housed within FINTRAC’s point of view. So FINTRAC expects IGO to report any sanctions evasion issues. So what that means is when operators find something that relates to sanctions evasion. They have to file an STR, a suspicious transaction report, and they have to send that to iGO, and iGO subsequently forward that disclosure to FINTRAC. So that’s quite significant. What has also changed is the terrorist property report, like I mentioned before, they’ve scrapped that term. It’s now called listed person or entity property report which is also significant. And iGO I think they went through a couple of changes within their circle relating to operators in terms of reporting and some of the other things that they might need from them. But this happens once you become an approved operator within the Ontario market.

VM: I love it.Thank you. I really want to thank you, Mondiu, because this is one of those topics that is less spoken about, but it is such an important part of the regulated iGaming market, and especially understanding AML could be seen as a little challenging, could be intimidating. But I’m so happy that at each moment, you broke it down so nicely for us and also helped me with Yoruba, and I promise I’m going to practise it more. And whenever we do an episode next time, the entire fun question part will be in Yoruba.

MJ: No worries. No problems. 

VM: Thank you so much.

MJ: You’re welcome. Thank you for having me.

VM: AML and compliance play a vital role in a regulated iGaming market as they help in preventing fraud, protecting players, and ensuring industry integrity. I want to thank Mondiu Jaiyesimi, the Senior Manager of AML Regulatory Compliance and Forensics at MNP, for joining us today and providing his expertise. If you have any questions for us or Mondiu, then please do comment them down below. Please don’t forget to like and share our episode and also subscribe to our YouTube channel. For the episode transcript and more amazing content, please visit our website at paramountcommerce.com. Thank you so much for tuning into The iGaming Show. I’m your host, Varad Mehta until next time, keep gaming.