Financial crime, and in particular, money laundering, loom large as problems for players in the gaming sector, from large multi-national betting companies to local RSL clubs.
The Australian financial crimes regulator, AUSTRAC, has recently taken strong action against Crown and Star and threatens the same against smaller businesses.
We work with gaming companies, casinos, pubs, clubs and RSLs to solve their compliance training problems.
Case Study: BlueBet
BlueBet needed a solution that highlighted the specific pieces of legislative instruments that applied in the jurisdictions in which they operate.
BlueBet is an ASX-listed sports wagering operator which uses a scalable, technology-based platform to facilitate online bets. Established in 2015, BlueBet has a rigorous set of corporate governance policies on topics ranging from anti-bribery to diversity, continuous disclosure, securities trading and whistleblowing.
The challenge for BlueBet in the current regulatory environment, with growing regulator focus across several jurisdictions, is to train and communicate its anti-money laundering policies and legal obligations to its rapidly growing workforce in Australia and the US, catering to the different jurisdictions, job roles and language levels. Previously it had relied on a PowerPoint-based workshop to ground its employees in the key concepts and requirements. As it expands, BlueBet recognises the need to provide its employees with an online training solution.
While the learning outcomes and language used to highlight the importance of complying with the relevant anti-money laundering legislation needed to differ between Australian and US audiences, the underlying principles reflected a unified vision of BlueBet’s strong commitment to fulfilling its regulatory obligations.
Everything from Know Your Customer due diligence to tipping off, suspicious matter reports (SMRs), Currency Transaction Reports (CTRs) and record keeping needed to be covered in these modules. And these technical concepts needed to be elaborated with references to local case studies of major breaches and penalties through short, sharp, targeted training that respected employees’ time. Above all, it needed to convey the seriousness of the subject matter and everyone’s role in ensuring that BlueBet maintains and complies with a robust anti-money laundering program to manage risk.
In line with BlueBet’s requirements, GRC Solutions developed a three-module training instance, with one module catering to US anti-money laundering regulations, another focusing on Australian anti-money laundering legislation and the third devoted to covering key concepts of responsible gambling.
The modules were developed using GRC Solutions’ proprietary Salt Adaptive authoring tool and output in SCORM 1.2, for uploading into our Salt Compliance Learning Management System (LMS). This hosted solution would enable BlueBet to track and report on learner completions in a secure environment. It would be deployed to approximately 70 learners in the first instance with the potential to scale up as BlueBet’s workforce continues to grow.
In effect, BlueBet relied on GRC Solutions to provide a ‘one-stop shop’ involving the development, scheduling, delivery, management and reporting of its anti-money laundering and responsible gambling training. Salt Adaptive’s pre-testing feature also enables learners to undergo a series of questions upfront whereby they can demonstrate proficiency in the key concepts and potentially bypass those parts of the lesson content with which they are already familiar. While BlueBet has not enacted this feature for its first year of training, Salt Adaptive enables them to activate it in future, effectively customising the training experience to the individual learner’s practical knowledge of the content at any one time.
The Roll Out
The training launched simultaneously in both Australia and the US, thereby ensuring that BlueBet could be assured that it was communicating its anti-money laundering compliance obligations to the whole of its workforce in one go.
BlueBet was able to roll out its training to its entire global workforce in one go. It was able to obtain records of its employees’ completion statuses instantly and rest secure in the knowledge that these statuses had been tracked and recorded for any future auditing purposes.
Moreover, it now has an online instance of legally accurate, up-to-date anti-money laundering training that it can build on as regulatory reforms, major case studies and general best practice in compliance continue to occur in the jurisdictions in which it operates. By using this training, BlueBet can work with GRC Solutions to continuously improve – and customise – its anti-money laundering and responsible gambling initiative.
On behalf of BlueBet, its Head of AML/CTF Compliance Brett Hereward expressed satisfaction and pleasure with GRC Solutions’ training solution, noting the following:
The AML/CTF legislation requires organisations to have an AML/CTF risk awareness training program enabling employees to gain an understanding of the obligations and importance of the AML/CTF laws and their application.
One of the challenges for an organisation like BlueBet, which rolls out this training organisation-wide, is ensuring that training is relevant, understandable and engaging for all staff. Through its consultation with GRC Solutions BlueBet was able to structure the training and assessment component in a way that all staff were able to engage with the training, learn from the training and understand the importance of their AML/CTF obligations.
This has been confirmed by the positive feedback from BlueBet staff about the training, its content and the user-friendly experience it provides.
GRC Solutions, through its course design expertise, took a standard PowerPoint presentation and elevated it to a comprehensive and engaging training program.
The client support and responsiveness [provided by GRC Solutions] was first-class and GRC Solutions understood the critical business need to get this training completed and meet the expectations of BlueBet.
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