Here are my responses to all of Jennifer Larson's BS answers in the Gambling 911 interview:
Quote:
G911: Why not offer proof of solvency if Lock Poker is so financially sound? Why you do not have a 3rd party verify that player funds are segregated and safe?
Larson: The DOJ has shown repeatedly that it can and will seize players' funds and hold these for months - if not years - absent any valid legal basis to do so.
This situation makes it impossible for Lock to provide any independent, third party verification of the segregation and amount of player funds. We have spoken to a number of companies that provide such audit services, however, they are unable to state that if pressured by the US Government they will not disclose the details of the Lock accounts they audit. They have been frank and acknowledge that they want to be able to conduct business with US companies and admit that the threat of being "black listed" by the DOJ, even if informally, cannot justify their taking on Lock as a client. No other online gaming site has or can publicly open its "books".
Nobody ever demanded that the audit firm had to be US-based. It just has to be one that is trusted and respected. I believe there are even a few in Cyprus (you know, the place that Lock has never banked).
She is completely full of **** that she can't find a single respected audit service that would be able to keep both full confidentiality and wouldn't fear "blacklisting" of any sort by the US. (What does that even mean? How can the DOJ tell US companies which auditing firms they can do business with?)
So Jennifer really expects us to believe that not a single audit firm could handle the job? Riiiight.
Quote:
G911: Let’s clarify the player-to-player transfer issue. Many people have posted emails from Lock support stating that NO FUNDS FROM PLAYER TRANSFERS, OR WINNINGS DERIVED FROM TRANSFERS can be cashed out. We have since had Lock come out to try and clear up this issue but can you personally clarify the Lock Poker p2p transfer policy?
Larson: Through a detailed investigation over the past few weeks the Lock security team uncovered a large group of persons that were abusing the P2P transfer policy and creating a large network of mule accounts to move and withdraw funds without any play at all taking place.
Lock has introduced a new cash-out policy for transferred funds which requires a player to accumulate at least 15% in GGR on the funds received via P2P transfer before these funds are cashed out. Put simply, for every $100 of transferred funds to be withdrawn, $15 of rake or fees will need to be accumulated beforehand.
The policy change was put in place explicitly to put an end to money laundering via Lock's player transfers. Players withdrawing winnings are not affected. It is important to note that many sites have similar policies regarding cashing out P2P transferred funds or do not allow such transfers at all.
She does not explain why it took three weeks to decide upon and/or communicate this policy, all while this very issue was rapidly eroding the trust of the userbase.
She provides no evidence of this "abuse".
The story has since changed from "affiliate accounts" perpetrating the abuse to "a large network of mule accounts", presumably so they could justify why innocent, non-affiliate players were blamed. (Otherwise, the obvious question would be, "Why suspend normal accounts if only affiliates had the priority cashouts that allowed this 'abuse'?")
Still, the "mule accounts" story falls flat, because this would be incredibly easy to detect and thwart. If certain people really created a large number of fake accounts that were on the system simply to receive transfers with withdraw, Lock could quickly and easily thwart this tactic with an industry-standard playthrough policy.
Now, that's what they claim they ended up doing,
but they cannot explain why this simple change took three weeks, while players jumped ship in droves, nor can they explain why so many of the canceled cashouts were those by high-volume players, who would in no way resemble "mules". In reality, this is just a complete BS story to cover the truth: Simply put, Lock didn't have the money to pay anyone for 6 weeks.
Quote:
G911: What is the reason for the slow withdrawal times?
Larson: There are a number of reasons for slow withdrawals. As explained above, we uncovered a money laundering ring that created a network of mule accounts that were buying and cashing out players' bankrolls with no play. This caused a massive increase in withdrawals causing legitimate players' cash outs to be delayed. The other main reason is that Lock is one of the largest poker sites that continues to serve players in most States in the US. This means that all Lock payments processors must be discreet. Lock has a number of processors it can use to flow funds to players but are all subject to limits. So while Lock has all the players' funds to pay out it is limited in the ability to do so by the constraints of the system and the threat of the seizing of player funds. The E-comm team works constantly to find new, reputable payment processors to provide secure, fast options to our players. Our number one priority right now is reducing payout times over the next few weeks.
This is garbage. Lock could easily create two different bank accounts -- one for player funds belonging to US players, and one for player funds belonging to non-US players. They could keep clear and accurate records showing that the non-US account is only used to conduct financial transactions with non-US players.
Besides, this whole story doesn't make sense. Even if they are using third-party processors for non-US payments (which doesn't seem to be true, as they own their own payment processor, JDB Services), these processors would not be limited at all because they don't need to fly under the radar. That is, processing non-US payments is NOT illegal, so a processor doesn't have to worry about being caught by anyone. The only reason US payments are slow is because processors have to severely limit volume in order to avoid attracting attention. Non-US processors don't have any radar to fly under, and any processor that strictly works in the non-US market would never be busted by the US DOJ, as the DOJ always collects evidence of processing payments for Americans before seizing any accounts or making any arrests.
Quote:
G911: Does Lock Poker own the Revolution Network?
Larson: No. There has been a lot of confusion and misinformation about the ownership of Revolution Network. In the spring of 2012 Lock entered into negotiations to purchase selected assets from the Network. One of the conditions of the purchase was the rebranding of the Network and this step took place. Ultimately the proposed purchase was not completed and Lock never became the owner of the network. A Company completely independent of Lock made the purchase. The Network team does work very closely with Lock based on Lock being the largest room. We therefore have an impact on the overall direction and weigh in on the big decisions.
They purchased a minority share of the Cake Network, but intentionally misled everyone (until now) that they owned Revolution, so as to make themselves seem bigger and more trustworthy.
The lie about this was definitely intentional.
This article, detailing Lock's purchase of Revolution, was dated May 7, 2012:
http://www.pokernews.com/news/2012/0...oker-12601.htm
Guess what date Lock bought their minority share of Cake? May 7, 2012.
Coincidence?
Quote:
G911: There was some degree of controversy surrounding a recent event that took place in Porto, Portugal. It was the second Lock Poker company retreat and posting forum observers were quick to point out some of the more extravagant aspects of this trip such as accommodations in a historic palace and transportation offered by a fleet of limos, all the while payment delays continued. Tell us what really happened in Portugal. What was the reason for the trip and do customer deposits pay for such trips?
The Lock Gaming Group, which owns and operates the Lockpoker.eu and Lockcasino.eu sites, recently completed a 3 day retreat in Portugal. This was not publicized in advance or during the event in order to protect the privacy of the attendees which included Lock staff, consultants, members of the Lock Pro team and suppliers. This event was a combination of business meetings, strategy sessions and social gatherings. The Lock Retreats are annual and included in our budgets and paid for out of the company profits.
LOL @ "in our budgets" and "out of the company profits".
Uh huh.
If there was a public information blackout on the trip in order to "protect the privacy" of the trip at the time, why did Jennifer order people to keep silent about it for weeks after it was over?
I'll do part 2 later.