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*Online Gambling Risk Management Strategies
*Online Gambling Risk Management Software
The investigation into a huge cyberattack on JP Morgan Chase last year has exposed one of the largest computer hacking and fraud schemes to date. According to U.S. prosecutors, Gery Shalon, Joshua Samuel Aaron and Ziv Orenstein, all from Israel, hacked a total of 12 companies to expose the personal information of more than 100 million people, netting hundreds of millions of dollars in profit. The men face 23 criminal counts, including wire fraud, computer hacking, illegal internet gambling and money laundering, with alleged crimes targeting 12 companies, including nine financial services companies and media outlets including the Wall Street Journal. Investigators say their massive criminal empire used 75 shell companies that employed hundreds of people, and hacked seven major banks, ran an online casino, laundered money around the world and set up an illegal Bitcoin trading operation.
“It is hacking in support of a diversified criminal conglomerate,” said Preet Bharara, U.S. attorney for the Southern District of New York. “In short, it is hacking as a business model.”
In addition to the hack of JP Morgan, which U.S. Attorney General Loretta Lynch called “the largest theft of customer data from a U.S. financial institution” and exposed the personal information of 83 million customers, the criminals also attacked E*Trade Financial Corp., TD Ameritrade, Scottrade Inc., Fidelity Investments and News Corp’s Dow Jones, which publishes the Wall Street Journal. The breaches date as far back as 2007.
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“By any measure, the data breaches at these firms were breathtaking in scope and in size,” Bharara said. “This showcases a brave new world of hacking for profit.”
Breaking into these financial institutions gave the attackers information to target specific people, and gave them extra insight into the stock market. According to the indictment, they used the customer data to contact individuals and push them to buy stocks in order to manipulate their prices. In addition to the pump-and-dump scheme, sometimes the defendants reportedly engineered mergers with shell companies to create publicly traded stocks that could be manipulated. Bharara called the scheme “securities fraud on cyber steroids.”
Beginning in 2012, in addition to disguising payments and constantly obtaining new bank accounts, the men further tried to evade detection by hacking into a company that assessed merchant risk for credit-card issuers. The breach allowed the defendants to read employees’ emails and figure out how to sidestep the company’s efforts to monitor illegal payments, according to the indictment.
The defendants are also accused of operating at least 12 illegal internet casinos, even launching cyberattacks against rival gambling businesses to review executives’ email and gain a competitive edge. Shalon hacked competitors’ customer databases and directed denial of service attacks to shut down their businesses.
Several compliance officers may soon feel the heat as well: the investigation found that, in operating the online casinos and illegal pharmaceutical payment processing enterprises, the co-conspirators deceived financial institutions into processing and authorizing payments between the casino companies and others. “They colluded with corrupt international bank officials who willfully ignored its criminal nature in order to profit from, as a co-conspirator described it to Shalon, their payment processing ‘casino/software/pharmaceutical cocktail’,” the indictment charges.
According to prosecutors, the case illustrates the growing power of criminals and their tools, and makes such crimes particularly difficult to solve. But it may also highlight one key resource to do so: self-reporting to law enforcement. Officials credited JP Morgan’s early cooperation for helping to uncover the network of criminal activity. The firm came forward early on to share information with the government, a move many forensic investigators encourage. This case provides one of the clearest examples of why: hackers frequently use the same schemes to target a swath of companies in a given industry. While many companies worry about the reputational and regulatory risks of disclosing a breach to law enforcement, as hackers grow more sophisticated in their techniques and complex in their operations, it may prove an ever more critical step in the breach response and investigation process.
“Shalon, Aaron, and their co-conspirators allegedly robbed victim companies, often for months at a time, stealing the contact information of tens of millions of customers,” said FBI Assistant Director-in-Charge Diego Rodriguez. “They cloaked themselves in secrecy, but their methods rivaled those of the traditional masked robber. Today’s indictment sheds light on an increasingly complex threat. But just as criminals continue to develop relationships with one another in order to advance their objectives, the law enforcement community has developed a collaborative approach to fighting these types of crimes.”
People gamble all the time, but we don’t think of it that way.
We think we are making decisions, not gambling — and often don’t see it as taking risk either. But we are.
The key is whether we are making what we consider a “sure bet,” where we believe the outcomes of our decisions are more likely than not to be (net) favorable, considering both the upside and downside — especially compared to the alternatives.
Related Article: Effective Risk Management Starts With Better Decision-MakingQuality Information Informs Quality Decisions
For example, when I quit my job with Coopers & Lybrand in the UK and decided to move to the US, I was gambling.
*I had no assurance I would get a job in the US (although I was fairly confident), and certainly had no assurance it would be a job I would want. As it happened, while I wanted to move back to Atlanta, the job I was offered was in Los Angeles.
*I didn’t think I had a future in my current position. As it happened, I had been tagged as potential partner material.
*I was also gambling that I would enjoy life in the US. I had spent nine months in the US and had made many friends, but would I be happy in this foreign country? Would I miss the safety of being close to my family in England?I made what I considered to be an intelligent and informed decision. As it happened, my assessment of the facts was partially incorrect (I probably did have a future if I had stayed), but it turned out well for me.

Every time after that, when I took a new job I was gambling.
*In most cases, my old job was disappearing due to downsizing or an acquisition. But in some cases, I had been offered a position with the acquiring company. My assessment was it was better to leave than stay.
*While I had done as much research as I could on my new company, I didn’t have certainty about its prospects or the people I would work with. In one case, nothing was as it appeared during the hiring process — but that’s another story.Again, I made what I considered an intelligent and informed decision but had no certainty it would turn out well.

When we gamble, whether we call it making a decision or taking a risk, it is crucial that we try to do so intelligently and with all the quality information we can obtain.
When I was in college I played poker with a lot of success. But I didn’t consider it gambling as I knew I was one of only two players at the table who knew what they were doing. I was taking risk, but my assessment was I was far more likely to win than lose and my potential loss was smaller than my potential gain.
Quality information informs and enables quality decisions.
The military planners deciding whether to send troops to rescue hostages in Iran (under Carter) or to capture Al Qaeda leaders (under Obama), would have had to assess:
*The likelihood of loss of personnel and equipment. There was a range of possible levels of loss, from the embarrassment of a failed mission to the loss of the whole team. Each level of loss had its own likelihood.
*The likelihood of success. That also was a range, from partial (such as rescuing a few hostages) to full (bringing them all home). Each level of success had its own likelihood.
*The possibility that their assessments of loss and success were incorrect.
*Whether the likelihood of success warranted taking the risk of failure. That was the gamble they made.
*Were they gambling when they decided to go ahead? There was no certainty about either the potential and likelihood of loss or the potential and likelihood of success.
Related Article: Transforming Risk Management in 2019 and BeyondImplications for Risk Practitioners
What does this mean for the risk practitioner?
Their job is to help the decision-makers make informed decisions and take risks with the knowledge that they are more likely to succeed than fail. After all, it is only by taking risks that any organization can achieve its objectives and succeed.
The risk practitioner has the ability to help decision makers assess the extent and likelihood of a range or potential outcomes, both potential losses and gains. The risk practitioner can improve the likelihood of quality decisions and therefore of success.
Is it gambling when you have what you believe to be reliable information and are making an intelligent decision?Online Gambling Risk Management Strategies
It’s certainly gambling when decisions are made in haste without reliable information on the extent and likelihood of what might happen.Online Gambling Risk Management Software
I welcome your thoughts.
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