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Hi Michael729 - welcome to ThePOGG.com.

Email is an entirely secure means of submitting documents and is widely used across the industry.

What are the operator still waiting on you to provide?

Thanks,

ThePOGG

They are requiring me to send  a signed confirmation of winnings from several operators, casinos where they saw winnings on my account statement. This is of course not necessary since the winnings are already clearly visible in the original account statement.

Only a few casinos have responded to this request and mostly not understood the request or refused the request, one saying they would not be able to provide any such signed document: "I am afraid we are not able to provide you with a signed or stamped document. The link or casino name won't be shown..." So the kind of document requested seems impossible for me to obtain for most casinos.

Also, after several requests Twin finally provided me with this "Proof of Winnings" document from Twin - which in itself is already sufficient to show the winnings which I had later used for subsequent deposits to Twin.

Besides,  on September 30th I had already submitted all relevant documents which have been sufficient to all casinos to complete the "Source of Wealth" process. Also Twin confirmed that the final document submitted was verified at this point, leaving just a short questionnaire for me to fill out before closing the process. So I do not see the purpose of new document requests beyond the point where the process was already closed due to all relevant documents having been submitted.

At this point I have already submitted far more documents than to any MGA-licensed casino for the "Source of Wealth", so this does not seem in any way appropriate any longer. Every time I have submitted the requested "just one more document" etc. - yet new document(s) have been requested.

Like I mentioned, Twin confirmed this process to be closed when I submitted yet the questionnaire after the final document was verified. At this point I had already provided Twin with all necessary documents which have always been sufficient for "Source of Wealth".

Regarding their latest request, I am sure Twin is very aware of how other casinos would be responding to their request:

"Dear Xxxxx Xxxxxx,
 
I'm sorry but I'm afraid that I can't provide such document. I spent a decent amount of time trying to figure out a way to send some kind of proof to you but unfortunately it is beyound my powers as Data Protection Officer. I will be glad to help you in excersining your rights according the GDPR but it is not possible for me to issue the document you have requested."

I believe it is apparent that these document requests are not motivated by any regulatory requirements any longer, since I have completed the "Source of Wealth" inquiry much faster and with far less documents at other MGA-licensed casinos.

Hi Michael729,

Specifically which operators have you been required to provide letters from? Which operators have refused to provide this information?

While the operator are not under any obligation to issue such a written statement, they cannot refuse you access to the basic information about your account under the GDPR. As such you can submit a Subject Access Request, specifically requesting the transaction and play round history for your account and the operator have to provide this. You should then be able to provide this to Twin Casino to meet this requirement.

Thanks,

ThePOGG

Hi Michael729,

I'm following-up on the above?

Thanks,

ThePOGG

Hello again and my apologies for the delay in replying!

I just returned back home from a vacation, during which I had received another e-mail from Twin regarding a "photo holding ID" I had submitted after their request. They claimed that the details on the document are not readable in the photo. However the truth is that the photo is very good quality and every other casino has so far accepted this very same photo.

About all document requests in this case please understand that I have repeatedly submitted requested documents, only to always receive new requests. Starting in September this process has taken me an unreasonable time and work, yet my balance of 20.000 euros remains unpaid. I have seen plenty of these "Source of Funds" procedures since I play actively, and in most cases they seem totally appropriate and necessary to meet regulatory requirements. Very rarely does this turn into pure harassment and extorting personal information by keeping my funds as hostage. Regulation does not require any casino to know at which other casinos I play at, or what are my gaming habits at other casinos.

Further, please note that Twin had a very specific requirement: "proof of winnings, the accepted document in this instance is a signed confirmation of winnings from the operator". Twin was obviously fully aware that most casinos would never offer such a signed document, and even if some would - it could take a very long time.

In the meantime I did however receive exactly the kind of document Twin requested - from a single other casino. I submitted this to Twin along with the similar document from Twin, and already these documents cover the amount of deposits Twin said they need these documents for. 

So all should be now in order with the "proof of winnings" documents and Twin already confirmed that the documents had been received and checked. They just mentioned having yet "one slight issue" which should be "super easy to fix" and this was "the photo holding ID". I already sent them a high-definition photo so all should be OK now.

However, I have been repeatedly asked for just one more document after which my money will be paid - which has so far never happened as promised.

Hi Michael729,

While I understand your frustration, if the operator are unhappy  with the photo you sent in the simplist solution would be to take a new photo and resend it. 

Once you have done this let us know.

Thanks,

ThePOGG

Hi again!

It has been obvious since September that this has never been about any legitimate document requests but the refusal to pay my winnings. Delaying my pay-outs with totally unnecessary requests started after I refused to be pressured into playing more and losing my winnings.

And as I already mentioned above, I had already sent them yet another high-definition photo last week.

And the good news is that they finally confirmed last week that my verification should be now complete after I have submitted them once again ALL requested documents:

"Thank you, I am happy to see that the document looks fine and so the verification should be resolved tomorrow."

However, it is now Wednesday of the following week and not surprisingly my winnings have not still not been paid - nor have I even heard from them.

Like several times previously, again there was only the "one slight issue" which was "super easy to fix" and this was "the photo holding ID". Almost a week after I submitted it, they finally confirmed: "Thank you for the photo holding ID, this was verified."

Despite their previous message and just like every time before - this did not resolve anything and Twin does not seem to have any intention to pay my winnings:

"The security team have informed me that we are close to resolving this, the last remaining documents are the win from other casino confirmations."

Twin already knows that these other casinos have refused to deliver this document. Further, now they are demanding to have this document for even more casinos than previously.

Hi Michael729,

Have you submitted Subject Access Requests to the other casinos as directed previously?

Thanks,

ThePOGG

Hi and sorry for the delay, rarely does it take me very long to respond however I am not getting any e-mail notifications about these updates unless they are my own responses. It was again a surprise to see your new follow-up here when I checked today.

Anyway yes, as I have also repeatedly informed Twin - I indeed did request these documents from all the casinos the documents were requested for. When I did not hear back, I even follow-ups and kindly asked them to send me the document as soon as possible. And I detailed all requests according to the specific requirements given by Twin casino.

And like I also mentioned, I already submitted to Twin both documents I received - and I also quoted the kind of refusals I got from other casinos.

Further, as I was told - these documents were only required for the amount of deposits made to Twin - and the two documents I already submitted did cover my deposits to Twin - the endless new requests seem to have the sole purpose of delaying my pay-outs, and nothing else.

The amount of time and work this has taken from me already has been unprecedented - yet my withdrawals have still not been paid and every time I deliver the requested documents, I only get new requests which are getting impossible to fulfill.

As I already wrote in my initial complaint, I was promised payouts already in September after I had sent a number of documents and they only required one more to complete the process:

After the final document was sent and approved, on September 30th the "Source of Wealth" and "Source of Funds" process was finally completed: "The document was verified leaving just a short questionnaire for you to fill out before we close this process." .... "This should take a couple of minutes and then we can get to the good stuff, cashback and payments :)"

I accepted this, immediately filling and sending the questionnaire to complete the process in order to get my money. Yet the process was not closed as promised in September - my withdrawals were not paid then and they remain unpaid yet today.

Hi Michael729,

I'm afraid you have misunderstood.

A Subject Access Request is not simply 'asking nicely'. It is a formal request to be provided with all personal information on your account, and given that you are an EU citizen, the operator is not legally allowed to deny this request. You need to look up the process for submitting a SAR in your native country and submit these requests to the operators in question. I would advise you to explicitly state that you want a copy of your transaction history and account activity.

The operators in question are avoiding complying because you have not used the right legal terminology to force them to categorise your request as a SAR.

Thanks,

ThePOGG

Hi and thanks for explaining,

however I do not see how this would be relevant as this was not what Twin has even requested at any point. And even if Twin would request personal information like my full account history from other casinos, I have understood from multiple sources that I should never share such private information with third parties like Twin in the first place.

Twin made a very specific request about a signed document which is what they would accept, and like you wrote yourself - the casinos are not under any obligation to issue such a written statement. And like I have already stated, the other casinos did refuse to deliver such a document - so the request from Twin is impossible for me to fulfill. Also, the same information is already shown in the 6-month account statement I submitted to Twin a long time ago.

Further, Twin confirmed they need these "Proof of Winnings" signed documents for the amount to cover my deposits to Twin - and these documents I have already delivered to Twin.

Twin has repeatedly confirmed the process to be closed after I submit one more document, which I have repeatedly done. Are you suggesting this can be a never-ending process with new requests continuing for years - and that Twin can refuse to pay my money just by new document requests even if they have no right to have these documents?

At this point I am a bit confused about this complaint process as I don´t see any sign of progress so far.

You also never addressed the notification glitch, as I do not understand why I never get any notifications about your updates but only my own responses.

I only get these e-mails titled "ThePOGG.com - Your complaint has been updated" when I have made updates myself:

"Hello Michael729,

One of the complaints you have submitted to be reviewed by ThePOGG.com has been updated by admin. Please log in and respond."

Since I am definitely not the admin for your website, why do I keep getting these notifications only when I make the updates myself - and never any notifications of your updates?

It is useless for me to get an e-mail notifying me that I have made an update - it would be far more useful to hear about updates made by the admin.

Hi Michael729,

I understand that the operators in question have refused to provide a document in the format requested by Twin Casino. What I have suggested to you is an alternative approach that will allow you to provide the same information to allow you to meet the requests made by Twin Casino.

What you are asking us to do is to pressurise the operator to set aside the Source of Wealth requests they have made as in your opinion they are overly onerous. That is not the purpose of this service. We have offered you a solution that would allow you to comply with the request. If you do not want to do that there's nothing further that we can do to assist you.

Finally - we'll have someone look into the email issue you claim to have experienced. But to be clear, you are the sole person to have reported this issue this year - with over 1200 complaints managed under our new system. It seems more likely that your spam filters are catching to other notifications as these are sent out any time ANY user posts on your complaint thread.

Thanks,

ThePOGG

Hi and thanks for your follow-up,

do you suggest that I spend further time trying to obtain now documents that are different from what Twin has even requested? How would I be complying with their request by submitting them something different than what they requested?

Since the Source of Wealth procedure was closed in September, may I ask why you are now for calling these new requests "Source of Wealth requests"? Correct me if I am mistaken, but this simply looks like an attempt to justify the demands from Twin by painting these never-ending document requests as motivated by regulation?

Since this complaint process has now taken more than a month, may I ask if I understood correct that this complaint process has so far included only our exchange above and no other action by you?

About the notifications, I still only get notifications for comments submitted by myself - not any other notifications (even in the spam folder) for any other updates than my own comments.

Twin has still not paid my balance and their latest document requests are impossible to fulfill since the other casinos have refused to deliver the documents Twin is specifically demanding.

We have been repeatedly in a situation where Twin promised to pay my money after I submitted just one more document. However after I submitted this last document, instead of promised payment only new requests have followed. 

Besides your suggestion of starting to submit other kinds of documents than what Twin has even asked for - did I understand correct that there is currently nothing further that you can do to assist me? Does this mean this complaint process can be closed?

Quoting an e-mail from Twin October 16th with yet new document requests - this time about my gambling winnings:

"Here are some examples of acceptable documentation:
...
• Gambling winnings - Bank statement with payment of the gambling provider or official letter from the gambling provider with stamp and signature"

I submitted my account statement for 6 months with payments from multiple gambling providers - which was their acceptable documentation for my Gambling winnings.

Later I even went beyond this requirement by submitting yet two signed "Proof of Winnings" documents which more than covered my deposits to Twin to fulfill the regulatory requirements for "Source of Funds" or "Source of Wealth".

Please do not imply that I have not generously complied with the numerous document requests ever since September - until now when I have no more documents to possibly submit.

Hi Michael729,

You are entirely correct - we have not contacted the operator at this juncture. 

On the 17th of October I provided you with a recommendation as to how to resolve this issue. You have ignored this recommendation. That is your prerogative, but until such time as you have engage with the advice provided we will be taking no further action on this issue.

Thanks,

ThePOGG

This player has refused to engage with the advice we have provided them to resolve this matter. As such there is nothing further we can do to assist them.

I had been playing at Twin for a long time without issues, until I had a bigger win at the end of September and made withdrawals for a total of 20.000 euros which all remain now unpaid.
 
 It started out as a regular "Soure of Wealth" process like at any MGA-licensed casino. The requests however started to seem excessive and a bit unusual, for example for unrelated accounts or the account statements were requested without blacking out private and/or irrelevant information, which was quite suspicious. I however kept delivering documents to assist in meeting all regulatory requirements.
 
 After the final document was sent and approved, on September 30th the "Source of Wealth" and "Source of Funds" process was finally completed: "The document was verified leaving just a short questionnaire for you to fill out before we close this process." .... "This should take a couple of minutes and then we can get to the good stuff, cashback and payments :)" I accepted this, immediately filling and sending the questionnaire to complete the process in order to get my money.
 
 Despite the regulatory requirements having been finally now met, my withdrawals were still not paid. What followed were more arbitrary requests, with new requests appearing every time I had uploaded the previously requested documents. It became soon apparent there was no actual regulatory reason for any of the never-ending requests except to delay paying my withdrawals, and they did not seem to hide or deny this either.
 
 I however kept delivering new documents, like my face next to my Passport - and an account statement now for an even longer period, 6 months. In my account statement they saw my winnings from other casinos, so next they requested for several casinos a "proof of winnings, the accepted document in this instance is a signed confirmation of winnings from the operator". However I am unable to deliver documents which I am not able to obtain from casinos. Twin also disabled uploading any documents on my account page, making sure I am not even able to upload any documents. (I have told that I prefer uploading them securely onsite instead of e-mailing which is not considered safe)
 
 Twin surely knows that not all casinos offer the kind of documents they asked for, and that it can take at least several weeks to get any similar documents from most casinos. They also know I immediately requested for these documents and promised to deliver them once I have them - yet Twin has kept constantly sending me numerous e-mails asking for these documents, while of course understanding I do not yet have such documents. When I reply and ask for the reason for constantly asking me for documents I do not yet have, they always reply by asking me again to send them the documents.
 
 October 15th they sent me another e-mail asking for the documents and telling me my withdrawals had been cancelled and my account had been locked. I replied explaining that until they finally enable document uploading by opening slots for this on their website, I would not be able to upload documents in the first place. October 16th they replied and asked to "...upload them directly via your account" which was again only nonsense, as they had still not enabled my account for uploading documents - and had now even locked my account to make sure I could not upload anything.
 
 The documents I have provided clearly show the source of wealth for my deposits to Twin. Further, already my previous wins from Twin were sufficient to fund my new deposits to Twin - and to fulfill the "Source of Wealth" requirements in this case.
 
 Since I have already delivered all relevant documents and spent an exceptional amount of time complying to the requests - even after Twin had already confirmed they only needed the questionnaire to close the process - I expect my withdrawals to be paid without further delay.
 

Twin Casino - Unpaid winnings

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