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Integrated third party risk and contract management in an international gaming operator

Challenge

A gaming operator with a presence in Europe and Latin America managed an extensive network of technology providers, payment methods, marketing, support, hosting, cyber security, customer care, etc.

It is a highly regulated sector, subject to stringent requirements in terms of

  • Prevention of fraud and money laundering.
  • Personal data protection and information security.
  • Responsible gambling and user protection.
  • Contractual compliance with regulators and strategic partners.
The operator needed:
  • Consistently assess and rate your suppliers in different risk domains (privacy, cybersecurity, criminal compliance, contractual, etc.).
  • Manage an international supply chain, with suppliers in several countries and documentation in multiple languages.
  • Review and improve contracts with its suppliers to ensure that identified risks were reflected in sufficient clauses, obligations and guarantees.
Manual evidence and contract review processes were very costly, slow and difficult to scale as business and regulatory complexity grew..

Approach

ECIX Tech deployed a service Legal Operations supply chain, combining the platform with an integrated eTPC with the specialised artificial intelligence of MIA Enterprise.

The approach was articulated along two main lines:

  1. Automated supplier evaluation and qualification (eTPC + MIA)
    • Centralisation of all suppliers and service lines at eTPCwith impact levels defined according to the criticality of the service (gaming platform, payments, support, etc.).
    • Design of evaluation forms advanced for different compliance domains (privacy, cybersecurity, legal person criminal, sectoral regulatory).
    • Use of MIA Enterprise to automatically analyse the responses and evidence provided by suppliers, even in multiple languages, generating:
      • A risk rating by domain.
      • A overall level of reliability per supplier.
    • Visualisation of the entire process in the rating panel eTPC, allowing for prioritisation of higher-risk suppliers and informed decision-making.
  2. Review and improvement of supplier contracts through AI
    • Application of the algorithms of MINE for the mass analysis of supplier contracts:
      • Identification of critical clauses (security, privacy, outsourcing, audits, responsibilities, incident reporting, jurisdiction, etc.).
      • Detection of contractual shortcomings or weaknesses based on the risks identified at each supplier and the applicable regulatory requirements.
    • Drawing up proposals for contractual improvement, aligning:
      • The actual supplier risk.
      • The compliance obligations arising from the gambling sector and international regulations.
    • Integration of the result into internal procurement and legal advice processes, facilitating improved model contracts and standard clauses by type of service and level of risk.
All of this operating in an environment multilingual and multistandardcombining documentation and communications in several working languages, without losing coherence in the evaluation criteria or in the legal-regulatory recommendations.

Results

The joint implementation of eTPC and MIA Enterpriseintegrated into an ongoing Legal Operations service, enabled the gambling operator:

  • Standardise supplier evaluation throughout its international supply chain, with homogeneous risk criteria by domain (privacy, cyber, criminal, regulatory).
  • Significantly reduce manual effort dedicated to reviewing questionnaires, evidence and documentation, and being able to manage a much larger number of suppliers with the same resources.
  • Detecting and correcting contractual weaknesses systematically, aligning each contract with the risk profile of the supplier and the regulatory requirements of the gaming sector in the different jurisdictions.
  • To have a consolidated and updated view of third party riskswith clear and traceable reporting for internal audits, regulators and strategic partners.
Overall, the project enabled the operator to move from a reactive and highly manual model to a proactive supply chain managementsupported by specialised AI and a compliance platform designed for critical and highly regulated sectors.

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