IN-DEPTH 5 July 2016
New security and compliance consultancy Extrayard
Is there a more reliable person to count on in the industry when it comes to security and compliance than a former Met head honcho? Paul Sculpher meets Extrayard Security Managing Director Roy Ramm to find out
By Paul Sculpher
There’s a new provider offering compliance and security consultancy services to gaming operators. The man behind the firm, Extrayard, is Roy Ramm, a familiar name to many in the industry and a man aiming to address the very real concerns apparent at present.
Anyone who knows Ramm will have heard one of the colourful stories from his past, which are always incredibly entertaining and insightful in equal measure, as they shine a light on a vast array of professional experiences from a varied, glittering career.
Ramm was previously a senior Metropolitan Police Detective, leading some of Scotland Yard’s most iconic and demanding departments. By the end of his career in London’s Metropolitan Police he had commanded the Serious and Organised Crimes Branch, The Fraud Squad, the Undercover Policing Unit, the world famous Flying Squad, led hostage rescue operations in six countries and run serious crime investigations in London. Next came decades with casinos operator London Clubs (later Caesars Entertainment UK) as governance and public affairs director, looking after security, compliance and regulatory relations for the group’s casino operations in the UK, Africa and the Middle East. Now, with Extrayard, Ramm is aiming to lean on that experience to deliver a unique support package to the wider gambling sector.
Extrayard’s mission is to help operators in any sector and of any size proactively formulate policies and procedures to protect their businesses, to give them continuing confidence that they are safe and compliant, and to help minimising harm when things do go wrong. “It’s about starting it right, keeping it right and putting it right,” Ramm explains.
The operational imperative is to build a successful business, offering customers great experiences. However, sometimes businesses can become so absorbed in commercial challenges that other issues like regulatory compliance and asset protection suffer.
From a regulatory and compliance perspective, Ramm believes there are only two things that really matter to regulators right now; money laundering and social responsibility. Recent events with Paddy Power, Rank and other operators would tend to underline that this is where the regulatory focus lies.
“Operators who don’t acknowledge the measures necessary to be compliant from both an AML and from a responsible gambling perspective are putting their licences and their businesses in jeopardy. You only have to look at the public statements the UK regulator has demanded from UK licensed operators to see the regulator’s direction of travel. There is an increasingly strict AML requirement to know who we are doing business with and where their funds come from. This will be extended by the 4th EU Directive”.
Ramm is also aware of the responsible gambling onus operators are under. “However customers fund their gambling, operators are now expected to monitor how customers are behaving to minimise the risks associated with gambling excessively. This puts enormous pressure on operators, large and small, both in the real world and online,” he explains.
Adapting to this modern age of new compliance is where Ramm believes Extrayard has a role in the industry. For smaller operators who can’t support in-house service, Extrayard offers bespoke compliance plans and support. For larger companies with in-house compliance functions, Extrayard offers probing and exacting audits that challenge the procedures mirroring the way a regulator might investigate such a business.
According to Ramm, there’s a real risk in larger operations, with their own in-house teams, that familiarity can lead to some softening of the rigour required to ensure compliance, and the commercial imperative can challenge any department’s commitment to focus on non-revenue earning matters. An independent third party engaged in a one-off or ongoing audit process can “reset” the mindset of organisations in this context.
The other speciality where an outside agency can help operators is in revenue protection, because as gambling operations become more complicated, there are more and more ways for dishonest individuals to prosper. Ramm leans on his time in the police force when facing these issues.
“Loyalty schemes, on a big enough scale, become opportunities for theft of significant amounts of value. The take-up of the scheme in one operation we investigated seemed almost too good to be true, and it was.”
An enquiry revealed that a trusted and respected member of staff was discovered by management to have loaded a player’s reward account with points unjustified by the level of play. At the time the discrepancy was accepted as an “honest mistake”, and that might have been the end of it, except that years of policing experience and a detailed knowledge of the industry led Ramm and his team to look deeper, revealing that a systemic failure had been exploited by a corrupt network involving trusted staff and several friends and family members posing as customers, all of whom were benefitting from the criminal misappropriation of valuable points. The enquiry led to criminal convictions, asset recovery and revised procedures.
It is clear that an in-house team may not always be enough to protect operators from the serious challenges presented by theft, responsible gambling matters and, latterly, the new AML regulations. A fresh pair of eyes with a vast amount of experience could give operators some comfort that their in-house teams will not drop their guard in an environment where inattention can lead to action by the regulator and material loss of assets.