Sonia Wasowska: “I am a firm believer in preventative education”

Sonia Wasowska is Crucial Compliance’s Regulatory Compliance Consultant. In this interview, part of our Safer Gambling Week coverage, Wasowska discusses several recent ideas that go hand-in-hand with responsible play, weighing the impact of anticipated regulation, factoring in consumer behavior, and discussing what some of the best ways forward is. Wasowska approaches the subject with sobering pragmatism that draws lessons from both regulatory, consumer, and business points of view. Read our full conversation with Wasowska below.

Q: Sonia, with Safer Gambling Week, can we touch on a topic that is something that Crucial Compliance is known for - how important are safer gambling and AML assessments for maintaining a healthy standard of responsible play?

At Crucial, we aim to meet the needs of the industry and regulators continuously working on solutions that incorporate best practices, research, and consumer impact, going beyond meeting regulatory requirements. Our risk management system together with the AML and Markers of Harm models specifically tuned to the businesses we work with is constantly evolving, building on client feedback and data analysis and feeding in academic developments.

Know Your Customer is applicable in both, commercial and compliance work, therefore activities impacting the customer ought to be coordinated. The customers' experience of the commercial and compliance activities will have a major effect on their interaction with the products and the business.

There are specific factors that impact customer outcomes:

1. Ongoing risk assessment of new products, journeys, communications, and regulatory horizon scanning outputs to ensure risks are identified and mitigated including appropriate communication and collaboration across the businesses.
2. Customer education is designed in line with commercial marketing strategies, and available research outputs, appropriately placed within the customer journey.
3. Timely identification of risks within the operations compliance program - appropriate triggers, both behavioral and financial, designed in line with the company risk assessments and policies, taking into account the customer demographics, and product risks to name a few. Here in particular, we have been working with businesses, researchers, and industry experts in an ongoing collaboration mode to deliver a marker of harm and AML model to facilitate a flexible, adaptable method of early identification.
4. Accessibility of all available information for decision-making. Operational challenges around backlogs and ensuring accounts raised for AML and SG assessments are processed and managed in a timely manner persist, are visible in regulatory cases, and are obvious to everyone who ever worked in operations. It becomes a vicious circle of chasing backlogs without the opportunity to restructure processes or maximize account processing. All these operational details play a vital role in communicating and supporting customers in a timely manner.
5. Automation vs manual activities. Long-term benefits of automation in the right places and facilitation of faster decision-making and communication can be achieved via technological solutions enabling the design of process maps and adaptation of actions to address customer engagement failures as well as monitor, measure, and adapt on the back of customer outcomes. It is an ongoing process that 3rd parties facilitating these solutions can make better by building on the multitude of client feedback and sharing that via the improvement to their core product.
6. Regulatory records are key to ensuring consistency of approach but also evolving compliance ops processes that have a direct impact on customers. Ensuring that all decision-making elements are captured in time, negative decision-making in particular, with a timestamp of all the available information serves not only the purpose of documentation of process implementation but also team development tool to better customer impact.
7. Facilitating customer outcomes via communications designed to specific needs and delivered via the best channel and timing. We usually get so focused on the workings of the whole compliance program from A to Z that we sometimes lose sight of the customer perspective. And all that behind-the-scenes work can manifest quite minimalistic and generic sets of customer-facing actions, limiting engagement but also retention rates.
8. Internal and external horizon scanning, innovation, and (look first point!)

Crucial consists of compliance professionals who have practical experience in all aspects of these challenges and when it comes to working on client-facing solutions, we build in ongoing client feedback as well as industry best practice and regulatory requirements. We are unique in the way that our integration process includes data analysis and particular emphasis on specifics like the risks associated with products, customer profiles, and jurisdictional fine-tuning. We work with our clients to ensure that the platform is easy to use and accommodates their needs from a regulatory but also operational optimization perspective.

Focusing the commercial acumen of the creative and data teams on the compliance challenges as well as enabling the compliance ops teams to focus on decision-making rather than struggling with system-related challenges has the potential to affect customer retention rates and create more sustainable business models.

Q: We have heard a lot of calls about the introduction of "mandatory checks." Where does Crucial Compliance stand and do you believe that those mechanisms are beneficial more so than detrimental? Or is perhaps the correct formula not discovered?

Businesses aim to strike a careful balance in delivering a risk-based approach to identifying AML-related risks and relevant checks and controls. Pending the regulatory changes, some businesses already perform non-intrusive financial vulnerability checks via existing third-party providers within their compliance programs. Open banking check providers started to emerge and engage with the industry, trialing solutions and measuring customer impact in both journeys.

Learning from current AML source of funds and source of wealth requests and response rates related to them, the main challenge is and will be consumer engagement and documentation provision. Customers disengage and begin their activities with another operator. In consideration of the challenges posed by an industry single-customer view solution, the pending requirements have the potential to deter an impatient player.

However, having listened to the accounts of individuals willing to share their lived experiences and the drive to gamble at the height of their struggles, it is likely that the individuals experiencing these challenges will persist in finding an outlet and start the journey with a different operator rather than provide documents or simply stop.

The impact of the regulatory changes on the horizon will depend on the final iteration of the requirements. We will be ready working with providers focusing on the engagement rates and able to be flexible in adapting to the industry needs and we will await the hopefully timely evaluation of the regulatory changes and further developments on the international regulatory landscape.

Q: Taking stock of the success of Safer Gambling Week so far, what do you think can be further improved to help consumers play more responsibly?

I am a firm believer in preventative education delivered via the customer journey and the innovation within safer gambling tools. Focusing on customer sustainability from a product design perspective as well as enabling access to all relevant information and tools for customers to make informed choices whilst enjoying their activities. Working closely with commercial teams to strike the balance is designing customer journeys in a way that engages the customer in the right way to enable enjoyment in a safe environment is key. Investing and innovating on the customer-facing side linking it with back office systems that promote easy and informed decision-making and operational delivery creates opportunities for more competitive businesses.

Gradient safer gambling messaging and in-account communication and personalising of the customer experience makes sense. So does building on the existing body of research and wider interaction and utilisation of that research together with experts in the delivery of these solutions. Collaborating with marketing teams to create messages with all that in mind can change the way customers interact with compliance-driven activities.

Also, I think, and this is a personal view, that the terminology we utilize needs consideration. We are all so much "in" the subject that we do not react to it as a bystander would. But when interacting with other industries, like financial services and social media, or simply individuals outside of the industry, it is quite interesting to witness and discuss their reactions to it.

Q: Has the changing regulatory landscape posed a challenge to ensuring that consumer protection is upheld or have the tweaks made it all the more possible today?

We are observing an emerging trend in many new jurisdictions testing the waters in adapting player protection codes via industry best practices, voluntary codes, and firmer requirements. We see more collaboration between regulators aiming to raise international standards, focusing not only on AML and TF risk and relevant global impact but also on sports integrity and safer gambling. The consumer choice aspect seems to be still observed together with spending freedoms and we see a less direct approach towards monitoring and intervention requirements. The strictly regulated markets are more prescriptive and one can argue that the emphasis on player protection is predetermined by licensing requirements leaving less of a choice in delivery methodologies. ESG is also gaining momentum in social responsibility, compliance, and governance programs within business structures and considerations and the compliance world is evolving to make consumer protection a more intrinsic feature.

Fundamentally, I think, the industry is working towards creating a good environment for the consumers to enable mutual better outcomes, and the regulatory developments and their impact on the landscape will be very interesting to watch, in particular how the impact will be evaluated and where regulation will evolve in the future.

Q: What would you like to see from Safer Gamlbing Week in the future that you believe will establish it as an even more impactful campaign?

I would welcome more collaboration and engagement from different departments, I would like to see a challenge posed to the commercial teams to work on compliance with the same approach their work with on commercial challenges. I have been lucky to work with some businesses where this is happening and has an invaluable positive impact. Compliance can be challenging from a perspective of the traditional positioning as the almost external, auditing, governing function within the business, however, the implications of the ‘rise of the regulators’ (probably only a few compliance people will give me a smile here, I expect it’s corny enough for an eye-roll) are that we have become more of a partner than unwillingly admitted nosy neighbor.

I would also love to see an emphasis on industry culture and how working in the gambling industry is perceived by other industries. I think we are in a place where regulations drive innovation, so it would be great to see experts in technology data and creative solutions voice their views on the right environment for our players. I think the terminology around the goal will evolve, I wonder whether we will find a better way to describe safer gambling without the related implied meanings aiming to build and expand engagement with a wider audience. Maybe wider collaboration with other industries on these shared challenges could support better outcomes via accessing more perspectives and diversity of solutions yet to be tapped into.

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