The internal regulatory framework to counter money laundering and the financing of terrorism is based on a unified approach and consists in a comprehensive system of policies and procedures for the entire corporate group. The Group Policy defines the structure and organisation of the Group AML Function, including responsibilities, roles and functions, as well as the general rules to be followed by all companies, whether Italian or foreign subsidiaries, to prevent money laundering and the financing of terrorism. The Policy is then broken down into individual, company-specific operating procedures and instructions, thereby taking into account the particularities and requirements of the relevant country. The AML Function is furthermore equipped with a series of separate operating manuals for the individual business areas, to be understood as guides in which the processes, tasks and operating methods for carrying out control activities are explained in detail. By monitoring the existing controls, the AML Function continuously ensures the suitability of the policies, procedures and controls in place, including after the introduction of substantial changes (e.g. regulatory changes, internationalisation process, new product launches).
It carries out due diligence activities, according to a risk-based approach and in compliance with the relevant regulatory obligations, by using special automated systems, developed in-house on the basis of specific sector know-how, as well as leveraging databases provided by external providers. These systems enable Sisal, among other activities, to carry out in-depth reputational screening of our players and the corporate entities managing the gaming retail network in order to verify - both during the initial contract preparation stage and on an ongoing basis - that the applicable reputational requirements are continuously fulfilled.
Our transaction monitoring, customer profiling and document storage are achieved thanks to systems developed in-house and 'customised' to the specificities of the gaming world. In particular, the Transaction Monitoring tool enables us to monitor gaming operations in order to pick up on anomalous behaviour and, where necessary and after careful assessment by the Function, to activate the suspicious transaction reporting process to be sent to the competent Authorities. In addition to these tools, the Function makes use of Watchlists (Sanctions, PEPs, bad news) from external providers to conduct pre-boarding and ongoing screening for both B2C and B2B relationships. The Function also performs affordability checks for the purpose of a more complete definition of the risk profile attributed to our counterparties.
At Sisal, being ahead of our time while constantly driving innovation is one of our hallmarks. Our increasing focus on emerging technologies such as artificial intelligence and machine learning are a testament to this commitment. We analyse these tools to assess how they can be integrated into our internal control system for anti-money laundering and countering the financing of terrorism. These next-generation technologies will help improve the effectiveness and accuracy of detecting anomalous behaviour and suspicious transactions, reducing the false-positive rate and optimising alert analysis.
Training is a fundamental part of the Function’s activities. Training is understood as a central element of the internal control system aimed at ensuring that adequate measures are in place to manage and mitigate money laundering and terrorist financing risks. Mandatory training is aimed at all employees (both new and existing) and contractors, including retail outlet staff, in order to increase awareness of money laundering and financing of terrorism risks and basic knowledge of anti-money laundering regulations, as well as informing them about internal procedures and how to recognise and deal with potential suspicious transactions or activities. In this way, Sisal fulfils its obligations pursuant to Legislative Decree 231/07. Training is delivered by means of e-learning and in-person classroom sessions, both during onboarding and on a continuous basis, in order to maintain the highest standards of training. The Group keeps track of and retains all documents relating to training, including attendance records, in line with regulatory requirements.
Another activity carried out by the Function is advising and supporting corporate functions in the context of cooperation, information and knowledge sharing with a view towards anti-money laundering.
In order to best respond to Sisal's internationalisation process, the Function operates by means of a periodic information flow to its local anti-money laundering counterparts in order to share methodologies, analytical practices and the Group's system of rules on anti-money laundering and countering the financing of terrorism.
The results of the Function's activities are shared with the Management and Strategic Supervision bodies pursuant to the anti-money laundering regulations, as well as with the internal board control bodies for the purpose of an overall representation of the corporate risk in the relevant area.
The Function complies with regulatory obligations by means of a system of operating procedures and instructions for both retail and headquarters staff. This system forms the basis of the verification and control activities of the function, which is subject to specific regular auditing by the Internal Audit Department.
The centre of this activity is the verification of customer identity (Know Your Customer), through the collection of customer identification data, on the basis of threshold values for gaming operations in the physical network provided for by the regulations and when registering for gaming accounts online. The verification of the documents allows the function to initiate the reputational screening and transaction monitoring activities as part of the control activities during onboarding and continued phases of the customer relationship. These checks also apply to operations at physical retail outlets, as an associated partner of Sisal.
- Countering the Financing of Terrorism & Reputational Risk
This control system makes it possible to identify potential risks associated with players and retail outlet operators through a careful evaluation of the information contained on the relevant parties in the anti-terrorism and reputational lists. These checks are an essential aspect in the identification of the potential financing of terrorism that enables the activation of the further control phases. If the alert is confirmed, Sisal proceeds with the required asset freezing process and the relevant disclosure to the competent Authorities. The collection of data makes it possible to associate each individual player and retail outlet with a risk rating according to the current 4-level scale adopted by the company.
- Enhanced Due diligence measures
Risk profiling is another essential element in the customer and retail outlet assessment process, as it allows Sisal to collect additional information for high-risk scenarios, in accordance with the regulations in force, such as in the case of Politically Exposed Persons, (PEPs) in order to carry out Enhanced Due Diligence. These additional checks are also linked with the analysis of game movements.
The level of risk is also linked with the checks carried out on game movements. The system in place enables Sisal to associate a specific level of risk to certain gaming activity according to threshold parameters. Higher risk levels are analysed individually by the Anti-Money Laundering Function in order to assess whether the circumstances warrant a suspicious transaction report.
The company retains customer information in accordance with the timeframes laid down by the regulations in force. The anti-money laundering department stores documentation relating to in-depth analyses for the maximum time allowed by the applicable regulations, ensuring that only authorised personnel have exclusive access to the information.
- Internal Whistleblowing Process
The company is equipped with an internal whistleblowing platform in compliance with applicable legislation. In addition, retail outlet staff may also send suspicious transaction reports through a specific channel directly to the Head of Suspicious Transactions, visible to only this person, who performs the appropriate checks and investigations, according to the disclosed information.
- Relations with Supervisory Authorities
The anti-money laundering function cooperates with the Authorities on investigations resulting from suspicious transaction reports, as well as in the case of any other form of support or requests for information from Law Enforcement Services.