1. Objective
NGA licensees should be able to explain, evidence, and reconcile how funds move through their platform — from deposit to settlement, payout, refunds, and chargebacks — with accurate records and clear responsibilities. The goal is to prevent opaque flows and ensure traceability.
2. Funds flow mapping (minimum expectation)
Maintain an end-to-end funds flow map covering the full lifecycle and all third parties involved. The map should be kept current and reflect the production setup.
| Stage | Minimum standard | Typical failure |
|---|---|---|
| Deposit | Capture method, PSP/processor, settlement account, reference linking, and deposit status states. | Unreconciled deposits; missing references; “manual spreadsheet tracking”. |
| Wallet / balance | Internal ledger logic, balance rules, adjustments, and reversal processes documented. | No ledger rules; balances changed without audit trail. |
| Payout / withdrawal | Payout rails, approvals, limits, and evidence of completion (bank/processor confirmations). | Payouts initiated without approvals; missing confirmations. |
| Refunds / chargebacks | Policy + workflow; timelines; supporting evidence; impact recorded in ledger and reports. | Chargebacks handled off-system; balances not corrected properly. |
Funds flow map: what to include
Parties involved (licensee, PSPs, banks, processors), account names (not necessarily account numbers on public pages), settlement timing, reconciliation frequency, dispute handling responsibilities, and logging points (IDs, references, status transitions).
3. Segregation & safeguarding practices
- Separation where applicable: ensure operational funds and customer-related flows are distinguishable in records and accounts.
- Clear labels: account naming conventions and ledger tagging that make intent and ownership clear.
- Access control: restrict who can initiate payouts, adjustments, and refunds; require approvals for material actions.
- Documentation: written policies for balance adjustments, promotions, bonuses, and reversals.
4. Reconciliation & reporting
- Reconcile platform ledger to processor/bank statements at a frequency proportionate to volume and risk.
- Exception handling: define how breaks are investigated, resolved, and recorded.
- Records continuity: maintain immutable logs of key events (deposit creation, settlement, payout initiation, completion).
- Management reporting: summaries of deposits, payouts, refunds, chargebacks, and reconciliations.
Suggested reconciliation fields
Transaction ID, external reference, amount, currency, timestamp, status, settlement date, account/rail used, variance/break reason, investigation notes, resolution action, and closure date.
5. Transparency to users
Where users interact with balances, deposits, or withdrawals, NGA licensees should present clear and accurate information on timing, fees (if any), limits, and processing status. Ambiguity creates disputes and operational risk.
- Status visibility for deposits and withdrawals (pending/processing/completed/failed/reversed).
- Clear payout timelines and conditions.
- Plain-language handling of reversals, bonuses, and constraints.
6. Third-party processing & platform dependencies
- Maintain contracts and SLAs for processors, PSPs, and payout partners.
- Ensure logs and reports remain accessible to the licensee (not only the vendor).
- Maintain a contingency plan for processor outages or termination.
7. Oversight-ready evidence pack
- Funds flow map (current and signed-off internally).
- Ledger schema / event definitions (what each status means and who can trigger it).
- Reconciliation logs and exception register.
- Sample transaction trails (deposit → settlement → ledger → payout).
- Chargeback/refund policy and sample case records.