Tiltproof Incorporated Document No. Effective Date Revision Date Approval 5.15.3.

6 1/17/2008 SM

Collusion: Tournament Cases

1.0 Purpose:

This document establishes how to investigate collusion in tournaments.

2.0 Persons Affected:

1) Fraud Analysts

3.0 Forms, Checklists, Flowchart:

1) Printable version: \\tpfs1nw\workflow$\HANDBOOK-FRAUD\Print Versions\Fraud Handbook\5.15.3.6 Collusion Tournament Cases.doc

4.0 Policy:

1) When an account is paused for suspected involvement in collusion, the case should be resolved within 72 HOURS.  This includes account trapping, reimbursements, and emailing. 2) Only investigate hand histories (HHs) if the reported players have one or more of the following:  Serial relationship.  MAC relationship.  IP relationship.  Transfer history.  Shared processors.  Shared account information.  Address  Name  Similar account information.  Player 1 has their real name listed as Jane Doe and Player 2 has the registered email address <jdoe@hotmail.com>.  Players have participated in more than one tournament together. 3) A collusion investigation initially involves a review of the HHs of three

Tiltproof Incorporated tournaments where both players participated.  If three hands provide evidence of collusion, the player is confirmed guilty of collusion.  If no hands show evidence of collusion, the investigation is closed.  If two hands show evidence of collusion, the HHs of two more tournaments are reviewed.  If one hand shows evidence of collusion, the HHs of one more tournament is reviewed.  If the fourth tournament HHs reviewed show evidence of collusion, the HHs of a fifth tournament are reviewed. 4) Any exception to the number of tournaments reviewed must be approved by a Fraud TL.  Agent reviews the HHs of five tournaments, finds two hands showing collusion, and wishes to review the HHs of more tournaments as possible collusion is highly suspected 5) If a player uses multiple accounts in a multi table tournament, all funds in the accounts are seized and any tournament prizes are redistributed. 6) An investigation is closed if: a) The players participate in a high number of tournaments together but no collusion is found. b) A clear relationship is found between the players but there is insufficient evidence of collusion. 7) If a seizure exceeds $5,000, the Fraud and Investigations Manager must be contacted in person or by email before any action is taken. The player must not be paused, trapped or emailed. This document applies to all collusion investigations. If you are investigating a special case and feel an exception to this procedure is warranted, complete an Investigation Report and send it to <collusionreview@tiltproof.ca> and notify a Fraud TL or Manager.

8)

5.0 Procedure:

A) Handling Collusion Complaints 1) Investigate the following relationships between the players: a) Serial, MAC and IP relationships as per 2.4.2.9.8 Login Details Tab (Know101). b) Player transfer history as per 2.4.2.9.3 Transaction History Tab (Know101). c) Shared account information in WAT.  Address  Name  Email address d) Similar account information in WAT.

Tiltproof Incorporated  Player 1 has their real name listed as Jane Doe and Player 2 has the registered email address <jdoe@hotmail.com>. e) Participation in the same tournaments as per 2.4.9.36 Tournament Comparison Report. 2) Input the results of the investigation into the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls].  Plaintiff name and email: Player’s first name, last name and email address.  Suspect players: Player IDs suspected of collusion.  Open Date: Today’s date.  Closed Date: Leave blank.  Ownership: Your name.  Game: SNGs or MTTs.  Result/Response: Any important notes. B) No Relationship is Found – Closing an Investigation 1) Review the complainer’s email history to determine if it is their first concern about collusion between the suspected players as per 2.9.2. Customer History. 2) If it is the complainer’s first concern about collusion between the suspected players: a) Send them col.not.tour. b) Input the results of the investigation into the applicable columns in the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls].  Closed Date: Today’s date.  Result/Response: Add summary of case conclusion. 3) If it is not the first time the complainer has expressed concern about collusion between the suspected players, review tournament hands as per C) Relationship Found – Reviewing Tournament Hand Histories. C) Relationship Found - Reviewing Tournament Hand Histories 1) If a tournament number was provided by the player that complained or can be determined using the information provided, obtain the HHs as per 2.5.2.1 Running a Hand History Report. 2) If a tournament number was not provided and cannot be determined using the information provided: a) Send complainer col.need.info. b) If complainer does not reply, or is unable to provide more information, the case is closed. c) If complainer replies, obtain the HHs as per 2.5.2.1 Running a Hand History Report.

Tiltproof Incorporated 3) Review the HHs as per 2.5.2.2 Interpreting a Hand History. 4) If insufficient collusion is found: a) Notate the suspected offender’s accounts with “Col: Player cleared of collusion with player xxx. Current shared tournament count: xxx.”  The current shared tournament count is obtained from the Tournament Comparison Report as per 2.4.9.36 Tournament Comparison Report. b) If it is the complainer’s first concern about collusion between the suspected players, send them col.not.tour. c) If it is the complainer’s second concern about collusion between the suspected players, send them col.not.tour2. 5) If inconclusive evidence is found: a) Send the investigated players col.no.play. b) Notate accounts with “COL: Issued warning not to play in tournaments with Player XXX.” c) If it is the complainer’s first concern about collusion between the suspected players, send them col.not.tour. d) If it is the complainer’s second concern about collusion between the suspected players, send them col.not.tour2. e) Input the player’s information in Warned Player Follow Ups.xls in [S:\FTP_Fraud_Department\COLLUSION]. f) Save and close the spreadsheet. 6) Input the results of the investigation into the applicable columns in the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls]. Closed Date: Today’s date. Result/Response: Add summary of case conclusion. 7) Save and close the spreadsheet. 8) If you have questions about the case: a) Fill out Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] b) Save the spreadsheet. c) Attach the spreadsheet to an email and send it to <collusionreview@tiltproof.ca>. d) A Fraud TL will respond to your concerns within 72 hours for your reference D) Collusion Confirmed – Seizing or Redistributing Amounts Under $500 1) Fill out Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] and save it in your U: Drive for your own records. 2) Determine the offender’s serials as per 2.4.2.9.8 Login Details Tab

Tiltproof Incorporated (Know101). 3) Trap the offender’s accounts and serials as per 3.3.23 Trapped, Paused or Closed Accounts. 4) Notate the guilty accounts with “COL + TRAP: Player is guilty of collusion with Player XXX in H# XXX. Permanently banned from Full Tilt Poker.” Notate the innocent victims’ accounts with “COL: Player was victim of collusion between Player XXX and Player YYY in T#XXX. Compensated $xxx.” Send the offenders col.guilt. Send the complainer col.credit.tour. Send the innocent victims col.credit.tour2. Input any seizure or deposit requests in [S:\FTP_Fraud|Daily Reports\ (Month) Deps+Seizures Log.xls] for the current month. a) b) c) d) e) f) The current date. Type: Seizure/Deposit. Player ID of account. Amount. Fraud Analyst name. Email Required: Yes/No.

5) 6) 7) 8) 9)

g) h) i) j)

 A player will need to be sent an email when the seizure/deposit is complete if they have not been informed of the seizure/deposit, or if the status of their account will change. Item Actioned: Leave blank. Fraud Analyst: Leave blank. Email Sent: Leave blank. Additional Notes: The account notation in WAT. 10) Save and close the spreadsheet. E) Collusion Confirmed – Seizing or Redistributing Amounts Over $500 1) Determine the offender’s serials as per 2.4.2.9.8 Login Details Tab (Know101). 2) Trap accounts and serials as per 3.3.23 Trapped, Paused or Closed Accounts. 3) Send the offenders col.acc.review. 4) Fill out Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] and send an email to <collusionreview@tiltproof.ca> for a final decision on whether the players are guilty of collusion. 5) If Fraud Management informs the collusion is inconclusive, the investigation is closed. a) Untrap the accounts and serials as per 3.3.23 Trapped, Paused

Tiltproof Incorporated or Closed Accounts. b) Send the investigated players col.no.play. c) Notate accounts with “COL: Issued warning not to play in tournaments with Player XXX.” d) If it is the complainer’s first concern about collusion between the suspected players, send them col.not.tour. e) If it is the complainer’s second concern about collusion between the suspected players, send them col.not.tour2. f) Input the results of the investigation into the applicable columns in the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls].  Closed Date: Today’s date.  Result/Response: Add summary of case conclusion. g) Input the player’s information in Warned Player Follow Ups.xls in [S:\FTP_Fraud_Department\COLLUSION. h) Save and close both spreadsheets. If Fraud Management agrees there is sufficient evidence of collusion: Send the offenders col.guilt. Send the complainer col.credit.tour. Send the innocent victims col.credit.tour2. d) Notate the offender’s accounts with “COL + TRAP: Player is guilty of collusion with Player XXX in T#XXX. Permanently banned from Full Tilt Poker.” e) Notate the victim’s accounts with “COL: Player was victim of collusion between Player XXX and Player YYY in T#XXX. Compensated $xxx.” f) Complete the document [S:\FTP_Fraud|Daily Reports\ (Month) Deps+Seizures Log.xls] for the applicable month with: i) ii) iii) iv) v) vi) The current date. Type: Seizure/Deposit. Player ID of account. Amount. Fraud Analyst name. Email Required: Yes/No.

 A player will need to be sent an email when the seizure/deposit is complete if they have not been informed of the seizure/deposit, or if the status of their account will change. vii) Item Actioned: Leave blank. viii) Fraud Analyst: Leave blank. ix) Email Sent: Leave blank. x) Additional Notes: The account notations in WAT.

Tiltproof Incorporated Save and close the spreadsheet. 7) If you disagree with the initial decision from Fraud Management: a) Enter an explanation and any additional information in the Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] b) Save and close the spreadsheet. c) Send an email to <collusionreview@tiltproof.ca> requesting a second and final review of the case.

6.0 Definitions:

7.0 Revision History:

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