General Information About
Customer Identification and Verification Department
The Customer Identification and Verification Department serves as the organization’s primary frontline defense. This unit focuses on the "Identity Layer" of risk, ensuring that all users entering the platform are verified and that their data remains accurate and compliant throughout the entire customer lifecycle. The department’s mission is to monitor the player lifecycle - from initial deposits to high-level betting - to detect and mitigate financial, operational, and reputational risks.
Meet Our Team
Aram Zakaryan
Head of Corporate Risk Department
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Hrant Bakhshinyan
Head of Customer Identification and Verification Department
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Anik Hovhannisyan
KYC Operations Risk Team Lead
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Eva Marabyan
Methodology, Monitoring, and Reporting Team Lead
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Corporate Risk Department
The department consists of 3 teams:
- KYC Operations Risk Team
- Risk Analytics Team
- Methodology, Monitoring, and Reporting Team
1. KYC Operations Risk Team
General Information
The Customer Identification and Verification Department serves as the organization’s primary frontline defense. This unit focuses on the "Identity Layer" of risk, ensuring that all users entering the platform are verified and that their data remains accurate and compliant throughout the entire customer lifecycle. The department’s mission is to monitor the player lifecycle—from initial deposits to high-level betting—to detect and mitigate financial, operational, and reputational risks.
Main Functions
Operational Processing: Execution of core KYC tasks, including thorough document verification, continuous registration monitoring, and discrepancy analysis to ensure data integrity.
Infrastructure Oversight: Management of KYC tool performance and constant monitoring of system integrity to identify technical errors or workflow gaps.
Jurisdictional Compliance: Tracking evolving document requirements and expiration timelines to maintain compliance for all active licenses.
Job Responsibilities and Workflow
Verification Workflow: Managing the full player journey from registration to onboarding by reviewing IDs and Proof of Address (POA) using market-specific tools such as Sumsub, Signicat, MitID, and Bluem.
Fraud Detection: Active identification of "Identity Fraud" and "Group Registrations" to prevent platform abuse.
Support & Resolution: Reviewing Customer Service queries regarding account closures, limit settings, and necessary data corrections.
Escalation: Monitoring "Umbrella" multi-alerts and initiating Enhanced Due Diligence (EDD), which involves escalating suspicious profiles to the Analytics team for deeper review.
2. Risk Analytics Team
General Information The Risk Analytics Team is a data-driven unit that merges technical analysis with regulatory compliance. The mission is to monitor the player lifecycle—from initial deposits to high-level betting—to detect and mitigate financial, operational, and reputational risks.
Main Functions
Behavioral Monitoring: Tracking and reviewing player transactions and betting patterns to identify anomalies, AML (Anti-Money Laundering) triggers, and Responsible Gaming (RG) concerns.
Compliance Screening: Conducting PEP (Politically Exposed Persons) and Sanctions screening to ensure the platform remains free of prohibited actors.
Strategic Reporting: Preparing comprehensive Suspicious Activity Reports (SARs) and high-level investigative summaries for the FIU and MLRO.
Job Responsibilities and Workflow
Pattern Analysis: Investigating complex data patterns to identify systemic fraud, multi-accounting, and syndicate betting.
Forensic Investigation: Conducting deep-dive analyses into high-level risks, such as match-fixing or sophisticated money laundering schemes.
Decision Support: Providing strategic insights to the MLRO and performing CDD/EDD checks based on specific Compliance requirements.
Risk Mitigation: Applying targeted account restrictions based on deep-dive behavioral assessments and Compliance team instructions, followed by ongoing monitoring of those investigations.
3. Methodology, Monitoring, and Reporting Team
General Information
This function provides the structural and regulatory backbone of the department. This unit ensures that all monitoring tasks are executed in strict accordance with internal frameworks and that the collaboration between KYC and Analytics remains consistent and audit-ready.
Main Functions
Governance & Standardization: Establishing clear risk standards and ensuring that all monitoring processes are fully documented and optimized.
Regulatory Liaison: Collaborating with Legal, Compliance, BI, and Product teams to ensure platform functionality reflects current regulatory mandates.
Quality Assurance: Conducting daily audits of suspicious registrations and alert closures to identify gaps and propose corrective measures.
Job Responsibilities and Workflow
Policy & SOP Management: Developing and updating internal policies, methodologies, and Standard Operating Procedures (SOPs) to keep the company ahead of regulatory changes.
Data Validation: Acting as the final check for all departmental output to ensure that regular and ad-hoc reports (KPIs, SARs, and risk summaries) are accurate and consistent.
Operational Auditing: Performing real-time surveillance of the execution of behavioral triggers and alerts to ensure consistency across the entire team.
Team Development: Managing workload distribution, training programs, and performance evaluations to maintain high technical competency within the department.
Reports: Preparing detailed Monthly, Quarterly, or Yearly reports for each active market.
4. Software and Technical Applications
Both the KYC Operations Risk Team and the Methodology, Monitoring, and Reporting Team utilize the following ecosystem to maintain platform integrity:
- Workflow & Task Tracking: Jira.
- Risk Monitoring: Umbrella (used for managing multi-alerts and behavioral triggers).
- Verification Gateways: SumSub, TrueNarrative, BlueM, Legitimuz, Signicat, MitID.
- Information Validation: AGP, which is synchronized with the Backoffice to check and validate client data in real-time.
