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<0.5 → block. 5. Record & audit: store raw signals, timestamp, user ID hash and decision reasons for 12–24 months for audits. 6. Audit-ready reporting: exportable CSV/JSON reports for auditors showing decision traces. These steps map directly to eCOGRA-style expectations: documented logic, reproducible decisions and traceable logs — which is why certified operators win trust and face fewer regulatory headaches. ## Quick technical checklist (implement in 1–2 sprints) - Choose at least two independent geolocation sources (IP database + GPS or Wi‑Fi). - Define a confidence scoring model and threshold values (sample weights above). - Implement tamper-evident logging (signed records or append-only logs). - Add escalation rules (auto-KYC, manual review) mapped to score ranges. - Implement anti-proxy detection (WebRTC, VPN fingerprints). - Schedule periodic re-validation for active sessions (every 30–60 minutes on high-value actions). This checklist prepares you for audits and for an eCOGRA-style review, which we’ll cover in the sections ahead. ## Example mini-cases (realistic, short) Case A — Operator: small operator gets flagged by bank for high chargebacks from an unregulated region. They enable GPS checks and tighten session re-validation. Within a month, the number of flagged deposits from that region drops by 62% because many were VPN-mediated. This operational change is documented and later helps pass an independent audit. That leads directly into the next topic: evidence for auditors. Case B — Player-protection: a high-roller tries to split bets across accounts using mobile plus desktop with inconsistent signals. The operator’s confidence score drops below threshold and the system triggers manual KYC; the player’s accounts are paused pending review. The saved funds and documented review are critical for both compliance and dispute resolution. Both examples show why you need logs and policies that auditors can read, which is what eCOGRA validates next. ## eCOGRA: how audits look (what you’ll be asked) When eCOGRA or a similar lab audits you for operational compliance, expect requests for: - Architecture diagrams showing where geolocation sits in transaction flow. - Sample logs that show a decision chain for a set of transactions (redacted PII). - Thresholds and policy documents (who can override, SLA for manual reviews). - Test cases showing false-positive/negative rates for geolocation checks. Prepare those artifacts ahead of time; auditors appreciate reproducible samples. This preparation shortens audit time and increases your chance of a clean certification. ## Comparison table — geolocation approaches (pros/cons) | Approach | Accuracy (typical) | Cost | Spoofing risk | Best use | |---|---:|---:|---:|---| | IP-to-location DB | Medium | Low | Medium (VPNs) | Initial filter / scale | | GPS browser API | High (mobile) | Low | Low (requires consent) | High-confidence checks | | Wi‑Fi / SSID triangulation | High (urban) | Medium | Medium | When GPS unavailable | | Cell-tower / mobile operator | High | High | Low | Operator-level regulation | | Fingerprinting + heuristics | Medium | Medium | Medium/High | Supplementary signals | Review this table and pick at least two complementary approaches to reduce single-point failure; the next paragraph explains how to combine them for certification readiness. ## Where to see certified examples and vendor choices If you want to inspect how an integrated stack looks in the wild, certified operators document their pipelines and case studies in audit reports — these are often part of compliance bundles provided post-certification. For a practical starting point, review a certified operator’s integration notes and vendor choices to match them to your architecture; one live example of a vendor-integrated deployment is described in the operator sections on wantedwinn.com official, which shows how geolocation, KYC and payout controls are tied for audits. That recommended example leads us into vendor selection criteria next.

## Vendor selection criteria (what to ask before buying)

Ask vendors for measurable KPIs and test outputs: false-positive rate, latency, update cadence for IP DBs, percentage of sessions with successful GPS capture, and data retention policies. Require a demo that returns 50 sample decision traces and request a SLAs document showing Uptime, P99 latency and response format. These specifics are the same evidence auditors will want to see, which is why you should collect them during procurement.

Now that you know what to ask vendors, let’s focus on common pitfalls.

## Common mistakes and how to avoid them

– Mistake: Treating IP alone as source of truth. Fix: Require a second independent signal for high-risk actions.
– Mistake: Not versioning geolocation logic. Fix: Use semantic versioning for thresholds and log which version made each decision.
– Mistake: Throwing humans at every low-confidence case. Fix: Tune thresholds and create an automated KYC gate for mid-confidence levels.
– Mistake: Keeping logs only for 30 days. Fix: Keep signed logs for 12–24 months for audits and dispute resolution.
– Mistake: Ignoring player privacy laws. Fix: map geolocation processing against local privacy rules (consent for GPS) and document retention rules.

Avoiding these mistakes will make audits faster and reduce operational surprises, which we’ll close with actionable next steps.

## Implementation timeline (practical week-by-week plan)

Week 1 – Inventory current signals (IP DB, cookies, WebRTC), and choose an IP vendor and one active-check method.
Week 2 – Prototype confidence scoring and simple logging to an append-only store.
Week 3 – Add escalation flow: auto-KYC trigger, manual review queue, SLA.
Week 4 – Run internal tests (1,000 sessions with mixed locations), evaluate false positives, adjust thresholds.
Week 5 – Prepare audit artifacts (diagrams, sample logs, policy docs) and schedule pre-audit review.
Week 6 – Remediate findings and request certification / external audit.

Follow this plan and you’ll be audit-ready in roughly six weeks if development bandwidth exists.

## Mini-FAQ (3–5 quick questions)

Q: Can geolocation be bypassed?
A: Sometimes — VPNs, proxies and mobile tethering can mask IP. That’s why multi-signal approaches (GPS, Wi‑Fi) plus anti-proxy heuristics reduce bypass risk and increase confidence.

Q: Does eCOGRA certify geolocation?
A: eCOGRA audits operational controls that depend on geolocation (logs, decisions, KYC). They don’t issue a “geolocation stamp,” but they will evaluate whether your geolocation controls meet standards for fairness and player protection.

Q: How long should logs be retained for audits?
A: Keep detailed, signed decision logs for 12–24 months; shorter retention may hinder dispute resolution and regulatory inspections.

Q: What about privacy consent for GPS?
A: Always obtain explicit browser consent for GPS and record the consent timestamp. Map any personal data handling to local privacy laws.

Q: Who should own this project internally?
A: Cross-functional ownership—Product for UX consent flows, Security for detection/anti-proxy, Compliance for policy thresholds and Legal for data retention—works best.

## Quick Checklist (ready to copy into your sprint ticket)

– [ ] Two independent geolocation sources active.
– [ ] Confidence scoring model documented and versioned.
– [ ] Append-only logs with decision reason stored 12+ months.
– [ ] KYC escalation rules for mid-confidence cases.
– [ ] Vendor KPIs collected and demo traces secured.
– [ ] Privacy consent flow in place for GPS and stored with session.

These bullets are immediate tasks you can assign, and they lead directly into preparing evidence for certification.

## Responsible gaming & legal notice

18+ only. Geolocation, KYC and auditing are part of player protection—never use geolocation to harass or discriminate; use it to ensure compliance and player safety. If you feel that gambling is becoming a problem, use self-exclusion tools or contact local support services; operators should display clear help links and deposit limits.

## Sources

– Industry operator audit guidelines and eCOGRA published requirements (internal summaries; not linked here).
– Vendor whitepapers and geolocation provider datasheets (procurement materials).
– Practical engineering notes from compliance teams (anonymized case studies).

## About the author

Sophie Callaghan — iGaming product and compliance lead with 8+ years working across AU and EU markets. I’ve led geo/KYC integration projects, run internal audits, and prepared operators for external certification. I write practical playbooks that bridge product, engineering and compliance.

For hands-on examples of operator integrations and certificate-aligned policies, see an integrated operator example at wantedwinn.com official, which documents a live stack combining geolocation, KYC and payout controls. Use that as a working reference while you adapt the checklist above.

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