Manage fines and claims

1) Terms and scope

Penalty - monetary recovery from the regulator/supervisory authority or counterparty (under the contract).
Claim - a formal requirement for correction/compensation from the regulator, client, partner, payment provider, copyright holder, etc.
The goals of the process: minimizing the likelihood and size of sanctions, quick and correct settlement, prevention of repetitions.

2) Categories of fines and claims

Regulatory: violations of licenses, AML/KYC/sanctions, data protection/privacy, advertising and responsible play.
Contractual: SLA/uptime, data protection at vendors, violation of reporting/deadlines.
Payment: chargeback/card disputes, provider fines for fraud/returns.
Consumer: quality of service, erroneous write-offs, non-payment of winnings, disputes over bonuses.
Intellectual property and content: use of brand, games, media without rights.
Labor/HR: violations of local labor law and procedures.

3) Design tenets

Early Warning: detections and KRI before escalation to penalty.
Evidence by design: unchangeable magazines, WORM, hash receipts, chain of custody.
Single Voice: Single Position and Agreed Messages (Legal/PR).
Risk & Materiality: prioritization by financial/reputational effect and jurisdiction.
Preventive First: CAPAs with a focus on preventing replays.

4) RACI

(R — Responsible; A — Accountable; C — Consulted; I — Informed)

5) Claim/Penalty Management (SOP) Lifecycle

1. Registration: assign ID, category/jurisdiction, deadline for response, materiality (₽/€/$, reputation).
2. Copying and fact-checking: collect magazines, contracts, tickets, screencasts; freeze data (Legal Hold).
3. Assessment of risk and options: recognition/challenge, negotiations, restructuring, appeal.
4. Decision and strategy (Committee/Exes for High/Critical): line of defense/recognition and compensation.
5. Response/negotiations: letter, evidence package, damage/compensation calculation, schedule of actions.
6. Execution and CAPA: corrective/preventive actions, update of policies/controls.
7. Closing and verification: payment/cancellation/reduction confirmation, evidence in WORM, post-review.
8. Supervision 30-90 days: monitoring of repetitions, re-audit if necessary.

6) Severity classification and timing

7) Documents and evidence

Actual logs and audit trail: accesses, transactions, configuration changes.
Contractual grounds: SLA, DPA, licenses, specifications.
Communications: correspondence, call/meeting protocols, request ID.
Calculations: damage tables, compensation/penalty formulas, benchmarks.
CAPA/remediation: plans, statuses, implementation confirmations.
All artifacts are with hash receipts, storage chain and WORM storage.

8) Finance, reserves, insurance

Assessment of materiality: best/likely/worst case; NPV in installments.
Provisioning-Rules for recognizing reserves and disclosures.
Insurance: cyber/prof. responsibility - terms of notification, list of required materials, limits.
Negotiations on fines: discounts for voluntary execution, installments, SLA loans, offsets.

9) Payment disputes and chargeback

Deadlines of schemes (card/alternative): calendars and justification templates.
Evidence packages: confirmation of service provision, KYC, authorization logs/3DS, user behavior.
Fraud algorithms: false positive/negative metrics, revision of anti-fraud rules based on disputes.
Appeal showcase: statuses, win-rate for reasons, ROI from challenging vs write-off.

10) Customer complaints (Consumer complaints)

Front-line SOP: empathic response, identity verification, interim measures (block/limit/refand).
Mediation channels: Ombudsman, regulatory platforms, industrial arbitrations.
Compensation boundaries: goodwill payment scale, coupons, limits.
Trend monitoring: themes and root causes of → input into product/processes.

11) Interaction with regulators/providers

Single channel and numbering: official mail/portal, delivery confirmations.
Response format: numbered applications, calculation methodology, links to evidence.
Negotiations: transcript of agreements (owner, due, terms), without oral "gentleman" agreements.
Appeals/appeals: deadlines, additional evidence, external expertise.

12) CAPA and repetition prevention

Corrective: immediate fixes (config changes, revocation of rights, returns).
Preventive: policy updates/training, gates in CI/CD, JMA/detection rules, contract changes.
Compensatory measures: temporary limits, manual checks, additional monitoring.
Re-audit: stability check after 30-90 days.

13) Metrics and KRI

On-time Response:% of responses on time by category (target ≥ 98%).
Resolution SLA:% of cases closed on time (by severity).
Financial Impact: the amount of fines/compensation (QoQ, per 1 million turnover).
Win/Appeal Rate: share of successfully challenged claims/penalties.
Repeat Rate: proportion of repeated claims by topic/jurisdiction (↓ trend).
Chargeback Ratio: by providers/Payment Method, the goal is in the green zone of the schemes.
CAPA Effectiveness:% re-audit no repeats, KRI reduction after measures.
Time-to-Legal Hold: p95 minutes before data freezing (target ≤ 15 minutes).

14) Dashboards

Claims Pipeline: Intake → Review → Response → Negotiation → Closed/Appeal.
Regulatory Heatmap: by jurisdiction/topic/size.
Financial Exposure: Open and forecast amounts, reserves and insurance coverage.
Chargeback/Payments: ratio, reasons, win-rate, providers.
CAPA Linkage: measure statuses, waivers, deadlines, re-audit.
Consumer Sentiment: Complaint Topics, SLA Responses, Post-Settlement NPS.

15) Artifact patterns

15. 1 Response letter to regulator/counterparty

1. Reference to case number/contract and dates.
2. Brief summary of the position.
3. Calculation methodology and data sources.
4. Item answers, appendices (numbering).
5. Plan of measures and timing.
6. Contact person.

15. 2 Claim Card (GRC/ITSM)

ID, category, jurisdiction, deadline, materiality

Facts/Evidence, Owners, Status

Settlement options, settlements, risks

CAPA/waivers, re-audit plan

Committee Decisions/Exes

15. 3 Calculation of compensations/fines (structure)

Base (transactions/SLA/PII records) → methodology → ratios/limits → total → scenarios (best/likely/worst) → settlement proposal.

16) Vendor Management

Contractual clauses: the right to audit, limits on fines/credits, the procedure for exchanging evidence, mirror retention.
Escalation: credit notes, penalties, downgrade status, migration plan.
Offboarding: confirmation of data destruction, closing accesses, archiving correspondence and reports.

17) Antipatterns

Answers "from the head" without evidence and legal-review.
Missing deadlines and chaotic communication across multiple channels.
Unformed agreements by phone.
Calculations without method/verifiable sources.
CAPA without Preventive/compensatory measures and expiry dates.
The absence of Legal Hold and immutability is a dispute of evidence.
Ignoring complaint trends → system replays.

18) Maturity model (M0-M4)

M0 Hell-hoc: reactive responses, no registry, no metrics.
M1 Planned: registry, letter templates, basic SLAs.
M2 Manageable: dashboards, reserves, insurance, WORM-evidence.
M3 Integrated: link to CCM/AML/VRM/Payments, "audit-ready," cause analytics.
M4 Continuous Assurance: predictive KRIs, recommendation measures, automated evidence packages and negotiation scenarios.

19) Related wiki articles

Interaction with regulators and auditors

Remediation Plans (CAPAs)

Re-audits and follow-up

Continuous Compliance Monitoring (CCM)

Logging and Audit Trail

Storage of evidence and documentation

Due Diligence and Outsourcing Risks

Risk Management and Compliance Committee

Result

Penalty and claim management is not "firefighting" but an end-to-end process: early cues, discipline of evidence, a clear response and negotiation strategy, measurable CAPAs, and resilience control. This approach reduces costs, strengthens the company's position and prevents repeated violations.