Mr. Green - updating supplier records

**Triple7** · 5 September 2017, 5:03 am

Date: 05/09/2017

Dear Sir/Madam,

RE: UPDATING OF SUPPLIER RECORDS

AtMr Green, we have always valued our working relationship and want to reassure you of how committed we are to continue providing you with the best service possible. To this end, and in line with other institutions, we are obliged to ensure that our records are up to date and accurate. We are referring particularly to the forthcoming "Fourth Anti Money Laundering Directive" that will apply to all online casino operators (enforced by local law on 26 June 2017) and the General Data Protection Regulation (Regulation (EU) 2016/679) that will also be enforced by 25 May 2018.

For all of us to continue operating within the law, we would like to ask you for your assistance in supplying us with the following necessary documents.

Per our records, your affiliate account is owned by an EU Registered Company for which you are kindly requested to provide us with the documents and information as listed below:

1) Authorisation letter - Appointing official representative/s to deal OBO the company & signed by representative/s
2) ID Card ?Colour copy, front and back of the official representative/s ID Card/s that signed the Authorisation Letter
3) Bank account details - Screenshot of Bank/Neteller/Skrill settlement account designated to receive funds (If e-Wallet receive commission)
4) Affiliate ID's - List of Affiliate ID's also linked to the above settlement account referenced in point 3.
(If you are not receiving your commissions to an EU Registered company, please contact your affiliate manager for information about what documents are required)

We would be grateful if you could provide us with the above documents at your earliest convenience, and in any case, no later than 30 days from the receipt of this letter. We are of course available to work with you to make this request as streamlined and as easy as possible. Should the above documentation not be provided, the company will regretfully but respectfully, reserve the right to reconsider our business relationship.

**allaboutthebets** · 5 September 2017, 9:38 am

Looks like this is getting a standard request now

**good4bonus** · 5 September 2017, 5:50 pm

Did not received anything until now

**Anthony** · 5 September 2017, 5:56 pm

I moved this thread into the Mr. Green forum.

**Progger** · 5 September 2017, 9:46 pm

What is the GDPR?

The European Parliament adopted the GDPR in April 2016, replacing an outdated data protection directive from 1995. It carries provisions that require businesses to protect the personal data and privacy of EU citizens for transactions that occur within EU member states. The GDPR also regulates the exportation of personal data outside the EU.

Which companies does the GDPR affect?

A presence in an EU country.
No presence in the EU, but it processes personal data of European residents.
More than 250 employees.
Fewer than 250 employees but its data processing impacts to the rights and freedoms of data subjects, is not occasional, or includes certain types of sensitive personal data*.That effectively means almost all companies. A PwC survey showed that 92 percent of U.S. companies consider GDPR a top data protection priority.

**LauraMrGreen** · 6 September 2017, 1:56 am

Hi guys,

I'm here if you need any clarification on any of this. We'll do as much as we possibly can on our side to make this as easy as it can be for everyone. If you need a template or anything for the authorisation letter, just let me know.

@good4bonus we have not contacted everyone just yet. We don't want anyone to wait a long time for a reply if we have high volume so we are staggering the requesting of documents.

Laura

**good4bonus** · 6 September 2017, 3:38 am

Originally Posted by LauraMrGreen

Hi guys,

I'm here if you need any clarification on any of this. We'll do as much as we possibly can on our side to make this as easy as it can be for everyone. If you need a template or anything for the authorisation letter, just let me know.

@good4bonus we have not contacted everyone just yet. We don't want anyone to wait a long time for a reply if we have high volume so we are staggering the requesting of documents.

Laura

i sent a pm with a doubt

**affy** · 12 September 2017, 8:38 am

Hi Laura,

Can you confirm that marketing/affiliate companies sending to same type of request to your company will receive all docs like all details of official representative (including copy ID) and all bankdetails of MrGreen?

You will understand that we would like to know who we work with too..... and if the commisson received is to be trusted and from a legit account..... MrGreen might be just a big moneylaundry operation not?

Thanks in advance

**allfreechips** · 12 September 2017, 8:45 am

I requested all financial investors and directors of Mr Green's documents requested of me so I may copy the process when I return mine. I have not yet received the documents?

**LauraMrGreen** · 12 September 2017, 5:46 pm

Hey guys,

Sorry for the delay in getting back to you. I've been travelling all day to the Betting on Sports Conference. My replies will be delayed all week with that in mind but I'll reply as soon as I can.

For us to stay in line with the new laws, we have to be able to prove that we know who we are sending money to from an AML perspective. As our affiliate partners are receiving money from us rather than sending to us, they don't have the same obligations from a Know Your Partner perspective. However, I hope the below links provide you with some details that you need.

https://www.mrg.se/en/board-of-directors
https://www.mrg.se/en/

@allfreechips, can you ping me over your details? This request didn't land on my desk. Did you send it to someone else on the team maybe? I'll follow up as best I can.

**Triple7** · 12 September 2017, 6:30 pm

Originally Posted by LauraMrGreen

they don't have the same obligations from a Know Your Partner perspective.

Mr. Green is a great brand, great program and has a great affiliate management team, but this kind of statements ......

We also pay taxes, have obligations to keep accounts and get from time to time tax controls. And then we also have to explain why we're not doing business with Mr. Green & co AB in Sweden, but with Admar Services Ltd from Gibraltar, why we do not charge VAT and why we get a payment from Worldpay instead of Admar. Hence, there's no need of copy of bank statements, but some diagram of the group would be very helpful.

**affy** · 13 September 2017, 1:58 am

Originally Posted by LauraMrGreen;865108[I

]... For us to stay in line with the new laws, we have to be able to prove that we know who we are sending money to from an AML perspective...[/I]

A company name and registration number suffices here. The tax and financial authorities will investigate further if there might be any suspicion.

There is no need for you ask (let alone to keep) ID's, authorisation letters and screenshots of bank accounts you send money to etc...

And, sorry don't want to sound sarcastic, but providing a simple link to board of directors etc. is a joke. Read Triple7's reply....

**Progger** · 14 September 2017, 2:03 am

Mrgreen get nothing for me...

Green have only to collect what needs to be collected and not more.With the registration u spend your name and adress - and this is enought.
Changing rules for your own benefit is one typical stratedy to close some inactive aff accounts.

Read the rule...

Regards

**LauraMrGreen** · 17 September 2017, 7:54 am

Hi guys,

I'm still away but will be back in the office on Tuesday.

Our lawyers and AML team have judged the current and upcoming laws and in their conclusion these are the documents that we need to be compliant. They will be different depending on if you're a registered company or an individual.

@Progger the last thing we want is to close accounts. Affiliate marketing is a huge part of our business and we only lose out if we stop working with valued partners.

I totally understand it's an inconvenience and the points asking us for the same. If anybody has any info requests from their accountants etc please do email them on to us and we'll do our best to help.

**FictionNet** · 17 September 2017, 10:55 am

Who at Mr Green will have access to our personal documentation? Will anyone else be given access to our docs?

Where are these documents stored? How do we know our private information will be looked after?

If anyone in the future buys Mr Green, I assume the new owner will have access to our docs too?

Many questions.

**affy** · 18 September 2017, 2:55 am

Originally Posted by LauraMrGreen

Hi guys,

I'm still away but will be back in the office on Tuesday.

Our lawyers and AML team have judged the current and upcoming laws and in their conclusion these are the documents that we need to be compliant. They will be different depending on if you're a registered company or an individual.

@Progger the last thing we want is to close accounts. Affiliate marketing is a huge part of our business and we only lose out if we stop working with valued partners.

I totally understand it's an inconvenience and the points asking us for the same. If anybody has any info requests from their accountants etc please do email them on to us and we'll do our best to help.

Funny that you choose not to reply to my or Triple7's comments:

".....We also pay taxes, have obligations to keep accounts and get from time to time tax controls. And then we also have to explain why we're not doing business with Mr. Green & co AB in Sweden, but with Admar Services Ltd from Gibraltar, why we do not charge VAT and why we get a payment from Worldpay instead of Admar. ....."

MrGreen (or Admar Services) is making up stories as there is NO need to request all those docs they are asking for. I agree that the UK Gambling Commission has some additional requirements for affiliate companies but this does not apply to EU or ROW in general.

IMHO it is a joke that MrGreen (Admar) is requesting all kind of paperwork from legit companies meanwhile themselves are hiding who is behind their own operation and why payments are processed via "other" companies.

If your lawyers and AML team are so convinced about the request it will be very easy for you to post the details of the "existing and upcoming" law here which state those requirements.

Second to that company and personal details are very confidential and sensitive. We all know that affiliate databases are hot in our industry and many times affiliate managers think* it is ok the "borrow" them when they move on in their "career". Another reason just to stick to company name and company registration number. This is enough for any authority should they want to start an investigation.

(*Let me make it very clear that I do not suspect MrGreen or Laura of any of this kind of actions by any means here)

**LauraMrGreen** · 19 September 2017, 6:15 am

Originally Posted by FictionNet

Who at Mr Green will have access to our personal documentation? Will anyone else be given access to our docs?

Where are these documents stored? How do we know our private information will be looked after?

If anyone in the future buys Mr Green, I assume the new owner will have access to our docs too?

Many questions.

We legally have to abide by data protection legislation on this and treat it as securely as we would (and do) with players. When you send docs, they're reviewed by our trained KYC team and stored on our secure server where only limited people who have gone through data protection training have access.

We're a publicly traded company (Nasdaq Stockholm) so have many owners, none of which have access to your docs.

**LauraMrGreen** · 19 September 2017, 6:45 am

Originally Posted by affy

Funny that you choose not to reply to my or Triple7's comments:

".....We also pay taxes, have obligations to keep accounts and get from time to time tax controls. And then we also have to explain why we're not doing business with Mr. Green & co AB in Sweden, but with Admar Services Ltd from Gibraltar, why we do not charge VAT and why we get a payment from Worldpay instead of Admar. ....."

MrGreen (or Admar Services) is making up stories as there is NO need to request all those docs they are asking for. I agree that the UK Gambling Commission has some additional requirements for affiliate companies but this does not apply to EU or ROW in general.

IMHO it is a joke that MrGreen (Admar) is requesting all kind of paperwork from legit companies meanwhile themselves are hiding who is behind their own operation and why payments are processed via "other" companies.

If your lawyers and AML team are so convinced about the request it will be very easy for you to post the details of the "existing and upcoming" law here which state those requirements.

Second to that company and personal details are very confidential and sensitive. We all know that affiliate databases are hot in our industry and many times affiliate managers think* it is ok the "borrow" them when they move on in their "career". Another reason just to stick to company name and company registration number. This is enough for any authority should they want to start an investigation.

(*Let me make it very clear that I do not suspect MrGreen or Laura of any of this kind of actions by any means here)

Mr Green & Co AB (publ) is the parent company of the Mr Green Group. Admar Services is under that.
Worldpay is the payment processor that we use (you might receive your commission payments through Worldpay from other providers too).

The laws that we are working to make sure we're all compliant with are the Fourth Anti Money Laundering Directive and the upcoming General Data Protection Regulation (GDPR). All remote gaming operators must ensure compliance with their legal obligations including the carrying out of due diligence checks on business partners such as affiliates.As a listed company, our board is insisting on these documentation checks and we are limited in how far we can proceed without doing these checks.

At no stage are we suggesting that anyone we work with is not a legitimate operation. We have to make sure that we can prove that we checked that thoroughly under the anti money laundering laws though.

In regards to the sensitive information, please see my response to FictionNet. If you've been asked to send docs and feel uncomfortable sending them to the secure and limited access email address group then please reach out to your account manager and we can find some other way for you to send them maybe to just one person. I know you're not suggesting that me or the guys are trying to steal your sensitive information but we'll do as much as we can to make you feel more comfortable with the whole situation if you need to send us documents.

**eenzoo** · 19 September 2017, 8:01 am

... tactics! With the knowledge about the aversion against that kind of request´s among affiliates, it could be a productive tactic to count on hundreds of closed accounts and saved money.

**LauraMrGreen** · 19 September 2017, 8:22 am

Originally Posted by eenzoo

... tactics! With the knowledge about the aversion against that kind of request´s among affiliates, it could be a productive tactic to count on hundreds of closed accounts and saved money.

No, it's absolutely not. We don't want to close accounts. We want to abide by the law. Obviously I can't speak for other operators but I would be very surprised if you don't see "know your partner" processes being rolled out in the coming months by most of our competitors.

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