Appendix A – Regulatory Risks

• Lack of appreciation and understanding of critical elements of a risk based control environment
• Lack of defined Board mandate and independent oversight of management
• No mechanism for reporting wrong doing
• Inadequately documented management policies and procedures to define and align accountability skills and competence
• Lack of understanding about expected ethical behavior
• Lack of transparency in decision making
  • Individual knowingly fails to comply

• Inappropriate advertising practices targets minors
• Advertising is false and misleadingly deceptive to attract the public
• Advertising deemed to promote excessive play
• Players allowed to play excessively
• Responsible gaming controls not designed into environment and product
• Players are unaware of risks to problem gambling and options to self-control

Prohibiting Access to Designated Groups

• Individuals prohibited from games of chance have access
• Selling product outside jurisdiction

• Inability to regulate all components
• Related parties winning at a higher relative percentage than the public
• Players have insufficient information to make an informed choice
• Game and system design lack integrity
• Game procedures are not followed
• Game and systems fail

• Compromising betting markets through activities such as insider betting or game manipulation 

• People are not safe
• Assets and customer information are not safe-guarded
• Unauthorized individuals have access to prohibited areas

• Gaming used as a vehicle for money laundering
• Gaming used as a vehicle for fraud or theft
• Internal theft is occurring
• Cheat at play materializes within the gaming environment