How casinos check the sources of players' funds

Checking the Source of Funds (SoF) and the Source of Wealth (SoW) is a key part of the AML/CTF procedures of any licensed casino. The goal is to make sure that deposits and bets are made on "clean" money, commensurate with the player's profile, and the operator identifies suspicious transactions in time and informs the regulator.

Basic concepts and framework of compliance

KYC (Know Your Customer): identification of the player, verification of documents, address, age.

CDD/EDD (Customer/Enhanced Due Diligence): basic and in-depth verification of the client depending on the risk.

SoF vs SoW:

SoF is the direct source of the deposit (salary, business income, sale of an asset).
SoW - general welfare: how property/income is formed in principle.
Continuous monitoring: tracking activity, updating the risk profile, revising limits.
Lists and screening: sanctions, PEP, negative media, high-risk lists.

When SoF/SoW check is started (triggers)

1. Reaching deposit/interest thresholds for the period (e.g. total deposits above X for 24 hours/7 days/30 days).

2. Atypical behavior: a sharp increase in the amount of bets, frequent cashouts, multiple deposits at night, non-standard patterns of games.

3. Non-compliance with the profile: low declared income - high deposits; student with "adult" limits.

4. Geo/high-risk methods: cross-border, proxy/VPN, anonymous or fresh payment instruments.

5. Signals from external sources: negative media, coincidence on RAP/sanctions, alerts of payment partners.

What documents and data are requested from the player

Income/employment: salary certificate, employment contract, employer's letter, bank statements with incoming payments.

Self-employed/entrepreneurs: tax returns, account statements, contracts, invoices, accountant reports.

Other sources: contract of sale (real estate/auto), inheritance/gift documents, certificates of winning the lottery, etc.

Assets and savings (SoW): investment reports, brokerage statements, report on deposits/deposits, confirmation of business ownership.

Transaction confirmations: screen/deposit statement, matching the name of the cardholder/account with the player's account.

💡 Minimization principle: request exactly as much as necessary for a reliable conclusion, without overloading the player with unnecessary data.

How casinos evaluate documents (practice)

Authentication: watermarks, formats, name/address/date matching, IBAN/BSB/ABA validation.

Comparison of amounts and periods: regularity of salary, correspondence of account movements to the size of deposits.

Independent sources: public registers of companies, cadastral/tax statements (if permissible), employer inspections.

Red flags: falsified statements, "glued" PDF, unconfirmed large cash, contradictions in dates.

Risk scoring and decision matrix

Basic factors: geography, account age, payment method, amounts/frequency, game profile.

Dynamic signals: change of device/location, flow rate, unusual hours of activity.

Threshold levels:

Low risk: auto-app on basic checks.
Medium: selective SoF request, limits on deposits/withdrawals.
High: full EDD (SoF + SoW), time constraints, possible suspension until verification is complete.
Solutions: maintain the status quo, raise/lower limits, request additional documents, temporarily restrict operations, submit a report on suspicious activity.

Continuous transaction monitoring

Profiling: A benchmark of "normal" behavior for a given player and cohort.

Rules and ML: if-then hybrid + anomaly models; online learning for new patterns.

Risk events: frequent rate cancellations, instant cashouts after deposits, "cashing" behavior.

Alerts and queues: routing cases to compliance analysts, SLA parsing, feedback to the scoring system.

Responsible Play (RG) and "Accessibility" Policies

SoF/SoW checks are closely related to affordability. The operator matches deposits and activity with the player's real income/obligations, offers or enters:

deposit/rate limits, self-exclusion, temporary freeze, notifications/reminders when thresholds are reached.

Privacy and data storage

Minimization and purpose: only necessary information is collected and only for AML/RG purposes.

Security: encryption at rest and during transmission, access control, audit logs.

Shelf life: license and legal requirements, then safe removal/anonymization.

Transparency for the player: notifications about processing purposes, access/correction rights, communication channels with DPO/support.

Common operator errors

1. Late request for documents: they only apply when withdrawing, saving risk earlier.

2. Too general request: "send something," instead of a clear list.

3. Lack of communication SoF↔tranzaktsii: documents do not explain the specific amounts of deposits.

4. No continuous monitoring: one-time inspection without follow-up control.

5. Poor communication: lack of deadlines, statuses and understandable instructions for the player.

Casino checklist (practice of starting/updating the process)

1. Define thresholds and triggers (amounts/frequency/behavior).

2. Specify lists of documents by scenarios (hired, individual entrepreneur, invest income, asset sale, etc.).

3. Set up risk scoring (basic rules + ML, decision matrix).

4. Implement queues and SLAs for case processing, communication templates.

5. Screening POP/sanctions/negative media on onboarding and regularly.

6. Combine SoF with RG tools (limits, pauses, self-exclusion).

7. Ensure data privacy and security (encryption, roles, logs).

8. Conduct staff training and regular process audits.

9. Test UX: clear instructions, "received/under review/approved" statuses, communication channels.

10. Prepare regulatory reports and playbooks for SAR/suspicious transactions.

Mini-FAQ

How does SoF differ from SoW in simple terms?

SoF - where exactly this money for the deposit comes from. SoW - how do you generally have such funds/property.

Is SoW always needed?

No, it isn't. More often with high limits, prolonged activity and contradictions in the data.

Is it possible to replace paper documents with a "bank screen"?

Sometimes - yes, if it is valid, with visible details, amounts and dates. The risk office decides on the context.

What happens if the player does not provide documents?

The operator is obliged to limit operations (deposits/conclusions) and, if necessary, submit a report on suspicious activity.

How long does the check take?

Depends on the completeness of documents and risk: from hours to several days for complex cases.

Effective verification of sources of funds is not a one-time "loading of pieces of paper," but an end-to-end process: individual thresholds, clear lists of documents, risk scoring, continuous monitoring and competent communication. This approach simultaneously reduces AML risks, protects players and increases brand credibility, helping the operator stay in the legal field and build long-term relationships with the audience.