Identity verification and monitoring

Why the check sits at redemption

The check sits where value leaves, not where an account opens. A free-to-play product that asks for identity documents at signup pays for it twice: in conversion, because most people who register will never redeem anything, and in risk, because it now holds identity documents for a population that mostly never transacted. Verifying at redemption puts the check at the moment it is actually for — the moment something of value is about to leave — and means the documents you hold belong to people who reached that point.

The consequence is worth planning for rather than discovering: your first redemption request is also your first verification, and it will arrive sooner after launch than most plans assume.

Who performs it, and who enforces it

The check is never ours. On the managed platform the gate is. You arrange verification with your own provider on either route, and we never perform a check, never see a document, and never decide whether a person is who they say they are. What the managed platform does is refuse to let a redemption proceed until verification is marked complete. On an API integration you hold the ledger, so you hold the gate too.

What you need before your first payout

Four things, none of which we supply, and all of which are easier to arrange before a player is waiting than after.

• A verification provider, contractedChosen, integrated and paid for, before the first redemption request rather than during it.
• A written policyWhat is checked, at what threshold, and what a pass requires. Written down, because it will be read back to you.
• A decision about failureWhat happens when a check fails or a name does not match the account. This is the case that generates the angriest support contact, and deciding it in advance produces a better answer than deciding it live.
• A recordOf the decision, the basis and the date. On the managed platform the redemption record is kept for you; on an API integration the record is yours to keep and yours to size.

What the gate is enforced against — thresholds, holds and the verification requirement — is set out on the redemption engine page.

Monitoring, and what it is for here

There is no monitoring system here, and it would be easy to imply there is. No rules engine watches for velocity, structuring or duplicate identities, and nothing fires an automated alert. What exists is people: we see activity across the platform, and when something looks wrong on your brand we tell you. On the managed platform the underlying activity is visible to you in the back office as well, so you are not dependent on us noticing.

That is a courtesy backstop, not a control, and the distinction matters more here than almost anywhere else on this site. If your compliance programme requires transaction monitoring, it requires a system you have chosen and can describe — not a supplier who is often looking. Ours is worth having and it is not the thing you point a regulator at.

If you are a player

Not legal advice

What your obligations are, and what a programme has to contain to meet them, depends on your structure and your states. This page describes who does what in the product, which is a different question from what you are required to do.