GAN plc, based out of London, was fined the state maximum penalty of $2,000 for not properly implementing checks to make sure self-excluded and other prohibited players didn’t gamble with three separate operators — FanDuel, Parx, and Ocean.
NJ Online Gambling obtained more information on the violation through a public records request with the Garden State. The fine, along with an order to disgorge more than $20,000 in losses from the prohibited gamblers, was announced earlier this month.
According to the state Division of Gaming Enforcement, GAN was required to use what is called a “waterfall approach” to ensure self-excluded people with gambling addictions don’t gamble.
The first part of the waterfall approach, according to the notice of violation, is looking at a person’s full Social Security number to see if it matches one on the state’s list of prohibited players. The state’s list also has people on it without a full SSN, so an online gambling platform would then need to look at the last four digits and the person’s date of birth when cross-referencing with the list. There are also people on the list without any part of their SSN, and online gambling platforms are then required to cross-reference a potential patron’s last name and date of birth as the final check.
According to New Jersey, GAN didn’t do this and as a result some people slipped through the cracks.
On July 9, 2020, GAN informed the state that “only one of the three required checks [was] implemented.” According to the DGE, GAN “mistakenly believed that their system was in compliance” dating back to September 2019, when the DGE said it sent an email reminding operators of the process to check to make sure prohibited players don’t gamble.
Self-excluded player activity
An audit of activity on Parx, Ocean, and FanDuel revealed breaches related to the violation.
It was uncovered on Parx that three self-excluded people with gambling addictions had lost more than $2,000 combined on the platform.
Ocean’s audit found four self-excluded players lost nearly $4,000 combined.
The breach was most extensive at FanDuel, where 16 self-excluded players were found to have lost about $15,000 combined.
Separate from the dollar amount is any harm caused to self-excluded gamblers who were allowed to gain access to the gambling platforms.
New Jersey allows gamblers to self-exclude for a minimum of a year up to a lifetime self-ban.