With the recent tragic happenings in Europe and elsewhere, it is a good time to touch on the issue of terrorism financing, gaming and employee screening measures for people working in the gaming industry.
The Anti-Money Laundering and Counter Terrorism Financing Rules Instrument 2007, administered by AUSTRAC specifies that it is imperative for gaming manufacturers and service providers to implement rigorous employee background screening when hiring staff to work in and around gaming. Large fines can ensue if any employer is found to have failed in this regard.
But what does the term ‘rigorous’ mean when it comes to screening potential candidates? There is unfortunately no guidance within the AML-CTF Rules as to specifically what is required when it comes to probity checking.
With so many screening options available such as police checks, employment history and reference checking, what should gaming recruiters be doing to ensure their screening procedures are meeting AUSTRAC requirements?
A criminal check will uncover a range of convictions for drug usage or trafficking, theft, breaking and entering and fraud as well as any terrorism related convictions. It is commonly accepted as the most robust form of employee screening currently available. But as a point in time check, it isn’t entirely foolproof. Police checks, should be an intrinsic part of any screening regime, but they should be combined with other screening activities as well.
Employment History Checks
As illustrated by high profile cases over past years, falsification of employment history is a growing problem across a range of industries.
Embellishment of the facts is common among job seekers, as revealed by Veda’s research of more than 1,000 adverse findings of verification of employees moving to new jobs in the 12 months to 30 June 2014.
The data shows that 27 per cent of dishonest job seekers are providing potential employers with misleading information about their employment history.
A professionally undertaken employment history check will highlight any unexplained gaps in a person’s employment history. These gaps or discrepancies are often red flags, indicating a less than glowing employment record.
Visa/Work Entitlement Checks
The Veda research found that dishonesty in relation to Australian work entitlement came a close second to falsified employment histories with 26 per cent of falsifications coming from this due diligence category.
It is not longer a defence for employers to claim they were not aware of the employee’s work entitlement status. Employers face heavy fines for failing to properly ensure employees are Visa checked.
VEVO checks can be conducted quickly and easily and could save your organisation tens of thousands in fines.
While some employers refuse to give references for legal reasons, reference checks should not be discounted as an important intelligence gathering exercise. When conducted properly, reference checks can be an excellent predictor of future work performance.
A thorough reference checking program will involve measures to weed out false referees and will seek to obtain information from those best placed to give feedback on the candidate’s work performance.
The way forward
Employment risk mitigation is no longer recommended just when hiring. Periodic checks should become part of an organisation’s ongoing due diligence process to confirm employees’ criminal, work rights or financial status have not changed.
Just as businesses currently insure against property damage and other forms of risk, the area of risk mitigation in recruitment is often overlooked.
As a minimum, gaming employers should be conducting police checks and considering at least one of the above additional check types when recruiting new staff.
ESA can conduct a wide range of pre-employment checks. Contact us today to find out how we can help.