Player Financial Inclusion Check

Check player financial availability (Affordability)

1) Purpose and area

Ensure that the game matches the player's financial capabilities, reducing the risk of harm and complying with licensing requirements. Affordability complements RG and AML: we assess a player's ability to bear the costs of the game without prejudice (not to be confused with checking the origin of funds, although cases often overlap).

Coverage: Product (Web/Mobile), Wallet/PSP, Risk/RG, CS, Compliance/Legal/DPO, Game Providers, Reporting.

2) Principles

Proportionality: the depth of verification corresponds to the level of risk and the market.
Minimum necessary information: we ask only what is needed to solve.
Transparency and respect: clear reasons for the request and expected documents/deadlines.
Without tipping-off AML: in the wording, we avoid hints of suspicion.
Provability: all steps and solutions are fixed, artifacts are filed.
Privacy-by-design: GDPR/local analogues, storage and RBAC access.

3) Roles and RACI

Affordability Owner (RG Lead/Risk Lead) - policy, thresholds, escalation. (A)

Risk Analysts (1st/2nd lines) - verification, request for evidence, decision. (R)

CS/CRM - communications, player support, SLA responses. (R)

Payments/Finance - block/limit of deposits/withdrawals at the time of verification. (R)

Compliance/Legal/DPO - compliance with markets, privacy, templates. (C)

Data/Engineering - events/logs, integrations (banking APIs, verifiers). (R)

Internal Audit is an independent assessment of practices and samples. (C)

Exec Sponsor (COO/CEO) - resources, "tone from the top." (I/A)

4) Triggers to start checking (skeleton)

Financial:

Large one-time deposit (market threshold).
Rapid growth in deposits/losses over a short period.
Frequent cancellation of conclusions; transition to "borrowed" payment methods.

Behavioral/Marker:

Night/long sessions, rate acceleration, multiple RCs without interruption.
Player reports of financial difficulties.

Regulatory/Profile:

Achievement of thresholds requiring EDD/affordability by market/license.
Increased risk class (RG/AML rates).

5) Data and evidence (levels)

Level A - Easy check (minimum):

Self-declaration of entertainment/revenue budget (form in product).
Consolidated bank/fintech statements (without unnecessary details) or income statement.
Confirmation of employment/status (at the request of the market).

Level B - Standard:

90-day bank statements (omitted fields).
Income documents: employer certificate, tax form, contract/invoices (for self-employed).
Declaration of expenses by main categories (housing/loans/alimony).

Level C - Advanced (EDD/SoW if required):

Confirmation of the source of funds/assets (sale of property, dividends, etc.).
Open banking API (open banking) - aggregated solvency metrics (with consent and admissibility).
Add. documents at the request of the market/regulator.

💡 We always act according to the data minimization principle: we do not store unnecessary things, we mask unused ones.

6) Evaluation and thresholds

Net Disposable Income (NDI): estimated "free" income after basic expenses.
Affordable Loss/Budget: NDI share allowed for entertainment (internal policy + local norms).

Solution classes:

Green - no restrictions or soft budget.
Amber - limits on deposits/losses, monitoring.
Red - waiver/hard limits/timeout/SE.

Example of a scale (illustratively, validate by market):

Loss> X% estimated NDI in 30 days → Amber.
Losses> Y% NDI or toxic markers → Red.

7) Process (signal to decision)

Step 1 - Signal and pre-scoping. Collecting facts (amounts/time, RG markers), assigning priority (S1.. S3), fixing in the case system.
Step 2 - Request evidence. Level selection (A/B/C), understandable list of documents, deadline (usually 7-14 days), temporary limit/pause if necessary.
Step 3 - Analysis. Calculation of NDI/budget, verification of the sustainability of income/expenses, cross-verification with behavior.
Step 4 - Solution. Green/Amber/Red, setting limits/locks, timeline for revision.
Step 5 - Communication. Neutral texts without pressure, without AML subtext.
Step 6 - Documentation. Artifacts, calculations, rationale, links to policies/local norms.
Step 7 - Revision. Review again after N days or when risks change.

8) UX and correct texts

Document Request (Neutral):

💡 We want to make sure the costs of the game remain comfortable for you. Please upload brief income/budget confirmations (list within). This will help you find the right limits.

Time limit for verification period:

💡 We will limit deposits for the duration of the review. This is a standard security measure. You will be notified when the review is complete.

Amber solution:

💡 Based on our review, we've set deposit/loss limits to keep your spending within budget. You can review them after [date].

Red solution:

💡 We will temporarily restrict access to the game to avoid possible harm. You can request a review after [date] or provide new documents.

Avoid statements about suspicions/AML; use neutral "security/cost comfort checks."

9) Interaction with RG and AML

RG: Harm markers reinforce affordability priority, decisions → limits/timeouts/SE.
AML: if the risk of the origin of funds pops up in the affordability process, open a parallel AML case (without tipping-off in affordability communications).
Payments: block of repeated deposits/marketing at the time of verification.

10) Privacy, rights and retention

Basis of processing: legal duty/legitimate interest (player retention and license compliance).
Minimization and masking: collecting only what is needed, EXIF is removed, sensitive fields are closed.
Access: RBAC/ABAC, read/change logs, WORM store of artifacts.
Retention: usually 5-7 years or by market/license; after expiration - safe removal.
Rights of subjects: DSAR through DPO; not to disclose anti-fraud/scoring techniques and data of third parties.

11) Dashboard and metrics

Time-to-Decision (TTD): median from signal to decision.
Completion Rate:% of cases with received documents on time.
Amber/Red Rate: Solution Shares by Segment/Market.
Repeat Harm Markers: Harm markers in the 30/90 days after the decision.
Limit Uptake/Adherence: proportion of compliance with limits.
Complaints & Resolution: complaints/closure period.
Data Severity:% of cases where the minimum set of evidence is collected.
Auditability: Share of cases with a complete package of artifacts and NDI calculation.

12) Checklists

Before you run the policy

Market thresholds agreed with Legal/Compliance.
Letter templates are localized and tested for neutrality.
Integrations with document storage, open-banking (where available), case system.
EXIF masking/deletion procedures, format validation.
CS/FAQ scripts prepared; training completed.

In operations

Each case has priority, a list of required documents and a deadline.
Time limits/locks are activated automatically.
Decisions are documented with calculations and policy references.
Adjacent RG/AML/marketing suppression flags are enabled.

Audit and Improvement

Quarterly sampling of cases (≥ 30) for completeness/consistency of solutions.
Checking the event log with the wallet/GL.
CAPA for Recurring Comments.

13) Templates (quick inserts)

A) List of documents (level B)

💡 Please provide: (1) 90 day statements (can hide unrelated transactions), (2) proof of income (reference/contract/form), (3) if available - proof of regular expenses (mortgage/rent).

B) Deadline Reminder

💡 We remind you to request Financial Inclusion Check documents. The deadline is [date]. If clarification is needed, please reply to this message.

C) Limit Solution

💡 Based on the results of the check, there is a daily deposit limit of € X and a monthly loss limit of € Y until [revision date]. This will help keep costs within your budget.

D) Undocumented closing

💡 We have not received the documents by [date]. To avoid possible harm, we will limit deposits/play. You can submit documents for revision.

14) Technical implementation (skeleton)

События: `affordability_triggered`, `docs_requested`, `docs_received`, `affordability_decision{green|amber|red}`, `rg_limits_set`, `marketing_suppressed`.
API кейс-системы: `POST /affordability/case`, `PATCH /case/{id}/status`, `POST /case/{id}/decision`.
Document storage: at-rest encryption; automatic masking, EXIF-stripping; checksums and WORM logs.
Rules (policy engine): thresholds by market, SLA, auto limits for the period of verification.
Reporting: CSV/JSON uploads with units without PII.

15) Frequent mistakes and how to avoid them

Excessive document requests. → A/B/C levels, minimization, explain "why."

Delays without temporary measures. → Autolimits when opening the case.
Fuzzy texts. → Ready-made templates, testing for clarity.
Mixing with AML in letters. → Neutral wording, separate AML case if necessary.
No calculation. → Standardize the NDI/budget method and store the calculation.
Incomplete synchronization. → Connect solutions to CRM/PSP/game providers (suppress/blocks).

16) Regional profiles (frame for filling)

For each market, fix: mandatory thresholds, data sources, open-banking admissibility, response times, reporting formats, storage/localization requirements.


Profile [Market]
Thresholds:...
Sources: self-declaration     banking API      docs
Terms: ack ≤...; decision ≤ …
Solutions: green/amber/red - parameters
Reporting: Frequency/Format
Privacy: local requirements

17) 30-day implementation plan

Week 1

1. Approve affordability policy and market thresholds.
2. Agree on communication templates (RU/EN + locales) and FAQ.
3. Specify events/data model and integration (cases, storage, open-banking where available).

Week 2

4. Implement case flow, auto limits for the period of verification, loading/masking of documents.
5. Enable marketing suppression/PSP when the case is active.
6. Train Risk/CS; release 1-pages and macros.

Week 3

7. Pilot (5-10%): TTD/Completion/Complaints measurement, manual revision of decisions.
8. Make adjustments to thresholds/texts, debug integrations.

Week 4

9. Full release; daily KPI monitoring and selective reviews.
10. Report to management; CAPA for failures and complaints.
11. Plan v1. 1: expand market profiles, add open-banking/scoring, automatic NDI calculation.

Related sections:

Responsible play and limits
Self-exclusion and account blocking
Reality Checks and Game Reminders
Incident Playbooks and Scripts (RG/AML)
AML and Employee Training/Compliance Awareness
Notices of Violations and Reporting Deadlines
Regulatory reports and data formats
Internal Audit and External Audit/Audit Checklists

Player Financial Inclusion Check

Check player financial availability (Affordability)

In operations

Audit and Improvement

B) Deadline Reminder

C) Limit Solution

D) Undocumented closing

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