September 20, 2023 | 4 min

“Every day, we are combating money laundering and fraud”

Mirjam de Jaeger
Head of Fraud & Payments

Thousands of players take part every day in TOTO’s online games of chance. This is where our social role and the responsibility for implementing gaming policy comes into play. It’s our job to protect our players and prevent gaming addiction, along with fighting fraud and crime. Mirjam de Jaeger, Head of Fraud & Payments, talks about how she and her team of 15 committed experts combat money laundering and fraud by monitoring and analysing game play.


Head of Fraud & Payments

Mirjam sets strategy for the future, outlines policy, evaluates processes, closely monitors developments and works on developing her team. She’s keen to share how she regards her job: “I’m really happy with my role. I get a lot of satisfaction from developing initiatives and successfully implementing them. I also appreciate the freedom I’m given in implementing my tasks. That’s a real bonus for me.”


Launching TOTO Sport & TOTO Casino

Back to 2 October 2021. A very special day for Nederlandse Loterij when TOTO Sport’s and TOTO Casino’s online games of chance were launched online. And special for the Fraud & Payments team too because it saw the simultaneous go-live for the in-house developed software for detecting money laundering and fraud. This new form of gaming also required Nederlandse Loterij to comply with strict laws and regulations, such as the Money Laundering and Terrorist Financing (Prevention) Act (Wwft).

Mirjam elucidates: “With our lotteries, we don’t have to comply with this law, but with online gaming we do. So this became a new focus area for us. As of 2 October, we were able to conduct our own analysis for detecting money laundering and fraud. We weren’t exactly sure what to expect, but once live we got to see a lot of transactions and significant amounts of money. It was quite impressive. And it was of course great to see that our software worked so well.” On being asked how she reflects on that period, Mirjam replies: “I’m really proud that we’ve put a product in place that allows us to do our job well.”

“Since October 2021, we've been able to conduct our own analysis for detecting money laundering and fraud.”

Mirjam de Jaeger
Head of Fraud & Payments


A glimpse of the Department

“The fact that we manage to adhere strictly to the laws and regulations is entirely due to our dedicated team. Without our specialists, the risks are too great. Our analysts, expert leads and product manager implement our gaming policy with painstaking accuracy. The Know-Your-Customer analysts are responsible for the registration of players and daily payments. In addition to them, we have analysts who investigate fraud and money laundering risks through thorough analysis of play files.”

Mirjam explains their methodology: “The Wwft obliges us to run a check on every new player. In addition, we closely monitor players’ behaviour and make risk appraisals. Risk assessments are carried out on a continuous basis. If one of the checks highlights a player, then an investigation is initiated. As soon this suggests that a player forms a high money-laundering risk, we notify the FIU.”

Of course, a pleasant working environment is not merely about the content of your work, but also about the people working alongside you. “We regularly organise outings, such as a sports day, drinks or a beach activity for our professional and diverse team. We’re also working on our team’s structure since our department is still relatively new. What does that mean? Extra space for developing yourself and introducing your own ideas.”

Would you like to know more about the kind of organisation that Nederlandse Loterij is? Read about it here!


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