The recently passed Unlawful Internet Gambling Enforcement Act requires financial institutions, money service companies, and Internet Service Providers, among others, to adopt increased due diligence measures to avoid supporting unlawful Internet gambling businesses. Of course, Internet gambling concerns themselves are also directly governed by the Act and must build in new due diligence and technical functionality to avoid processing unlawful Internet gambling transactions.
Among the new due diligence requirements that the Act mandates is a “third-party certification that the commercial customer’s systems for engaging in the Internet gambling business are reasonably designed to ensure that the business remains within lawful limits.”
Stroz Friedberg has the perfect team and methodology to render such certifications. Our unique combination of former Department of Justice prosecutors and agents, former Federal Trade Commission regulators, and technical staff with highly specialized knowledge of Internet, fraud detection, payer authentication, and geo-location technologies can provide assurance to all parties that:
- geo-location filtering, age verification, and payer authentication applications are fully integrated and functioning properly, and
- anti-illegal Internet gambling policies are effective and up-to-date.
Where compliance gaps may be found, Stroz Friedberg can help its clients with the technical and policy solutions to close them.
Stroz Friedberg’s methodology for assessing the effectiveness of geo-location, age verification, and payer authentication technologies is two-pronged. On the behavioral front, we initiate gaming transactions from test computers, change the states we emanate from and the information we self-report to the site, and then forensically observe and record how the subject site reacts. We record and analyze all the bits and bytes, known as packet traffic, that flow between our test machine and the site, looking for clues as to why filters may not be blocking unauthorized traffic. With the same mission in mind, on the application front, we analyze the source code underlying the web pages and applications. Often, we can suggest source code and integration modifications to the application developer to increase the effectiveness of the filtering.
Our Internet gambling certification methodology is part of Stroz Friedberg’s broader abilities and experience in testing and verifying that deployed technologies produce the compliance required by a wide range of laws, regulations, orders, and agreements, including those related to Sarbanes Oxley, Gramm-Leach-Bliley, Payment Card Industry Data Security Standards, and data retention and recycling. Because of our reputation for honesty, neutrality, and technical excellence, our compliance certifications and opinions carry considerable weight.