- Date:2018
- Client:Luckbox
- Discipline:Initial coin offering, egaming, esports
Luckbox - Initial coin offering & eGaming license
Launch ProjectPROJECT BRIEF
Sucessfully apply for an OGRA gambling license and conduct a regulatory compliant Initial Coin Offering simultaneously, a task never achieved before. Fiat and crypto betting lines to be included under the single license and create a player funds protection solution that would simultaneously protect fiat and crypto deposits under the same governance rules. In addition, to support with establishing operations, recruiting staff, training and creating governance policies and procedures to meet regulatory need, while remaining practical for the needs fo the business.
Simultaneous ICO and OGRA Application
Due to timelines of the intended ICO and the OGRA licensing process, we created a unique regulatory solution whereby we utilised a PPM and DBA registration and conducting an ICO, with a sister company applying for the OGRA license with a pre-agreed funding scenario. We then assisted designing a KYC Matrix that would satisfy the requirements of both the Financial Services Authority/Designated Business requirements, and the Gambling Supervision Commission, while being flexible enough to be acceptable to the crypto community who, certainly at the time, were largely unaware of KYC, or why an ICO would look to collect such information/documentation. All matters were executed successfully with our assistance throughout.
Player protection
Under OGRA, licensees must at all times ensure that player protection arrangements cover in value the number of money players has in their accounts plus any monies owed to them (e.g. unpaid winnings). Operators may utilise a number of protection mechanisms if desired, so long as the amount of money they can yield at any given time, matches or exceeds the value of player funds recorded on the operators’ systems. We repurposed a somewhat forgotten mechanism to protect player funds, in whatever form that takes under common governance rules effectively replicating a traditional bank signatory mandate into a blockchain model.
Establishing operations
Post funding and license, we assisted in recruiting key compliance staff and provided training in the fields of corporate governance, risk assessment and mitigation and regulatory affairs. We created governance policies and procedures that protected the business, met regulations, but could also be workable on a day-to-day basis for those who much comply with them. The consideration of regulatory need and needs of the business versus the ability of those practising the implementation of those procedures from a practical level is often forgotten, yet we have managed to satisfy the needs of each stakeholder. We have stepped into various areas of the business to provide additional bandwidth when required also.
WHAT LUCKBOX HAD TO SAY:
Of all the countless decisions involved since we started building the company, through obtaining our OGRA licence, building and launching the product and beyond; the decision to work with SolutionsHub ranks among the very best. Lee and his team have calmly and expertly guided Luckbox throughout our entire journey.