Considerations for sports book operators in achieving compliance and risk mitigation across legal and regulatory concerns and conflicts include: • Dedicating appropriate resources to understanding player profiles and behaviors, including sources of funds, associations, and suspicious betting activity; • Leveraging technology to enhance risk and legal controls, especially for online operators; • Identifying and preventing real-money sports pool betting; • Benchmarking compliance programs with more mature industry peers, such as operators in the United Kingdom; • Prohibiting undocumented proxy betting; • Conducting enhanced due diligence on high value or volume accounts; • Limiting cross-border and third-party transactions (i.e., transfers, bank wires, etc.) for reasons not supported by legal gaming activity; • Maintain proactive relationships with appropriate regulatory and legal entities (e.g., FinCEN and SEC); and • Conducting regular, risk-focused audits of compliance controls.
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