Setting the "231" Framework of an International Gaming Player

Caso Framework Player Internazionale Gaming

Leading gaming group in Europe

As part of a reorganization project, the Internal Control Functions requested the support of MACFIN to review the 231 framework in an overall approach (e.g. mapping processes, risks, controls, definition of roles and responsibilities, information flows, etc.). The project included the updating/implementation of the 231 Organizational Models of some Companies and a training course for over 2000 employees and collaborators.


Analyze the business model and organizational structure

assessing the impact of the 231 in Group and individual legal entities, as well as the main risk profiles and priorities for action

Identify possible areas for improvement

with reference to the "231" controls and define an Action Plan for their adjustment

Update / Implement the 231 Organizational Models

of the Group entities and contribute to their dissemination through staff training


Analysis of the potential risk profiles

resulting from organizational and regulatory changes through the mapping of company processes, sensitive activities, 231 risks and controls in place

Overall assessment of the 231 control framework

also with reference to the existing anti-money laundering (i.e. Legislative Decree 231/2007) and privacy (i.e. GDPR) controls, with the identification of the adjustment actions necessary to adequately monitor the detected risk profiles

Adaptation of the 231 Organizational Models

of the Group entities (i.e. General section, protocols, information flows to the OdV) and some organizational documents (e.g. organization and chart, procedures, etc.), taking into account the corresponding level of updating and the overall adequacy with the new organizational structure and standards in use

Design and lead a training course

through the combination of face-to-face lectures and "e-learning" modalities


Overall review and optimization of the framework

Group control, coordinating the needs of the corporate units and Control Functions (Compliance, Risk Management, Internal Auditing)

Definition of a complete and standardized mapping

of Group processes, 231 risk profiles and existing controls

Cross-dissemination between employees and collaborators

of the culture of the administrative responsibility and greater awareness of the controls implemented by the Group in this area


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