Compliance Updates
Our UKGC consultation response: Failing to protect the vulnerable should not be the White Paper’s legacy
The dust has settled and the process is complete. The consultation on the proposed changes outlined in the UK Gambling White Paper is closed so now we just have to wait and see. Whilst we do so, we thought that in the spirit of transparency, we would share our own thoughts, more or less as they were communicated in our consultation response to the UK Gambling Commision.
Offering a real-time customer risk profiling tool, ClearStake’s focus was obviously on affordability checks. But then, much of the industry’s attention has been on this topic over the last few months. This is, to our mind, the single most important challenge facing the sector. Addressing it in the right way, a way that protects both punters and operators, will be the key to a sustainable, profitable future.
And with that goal uppermost in our mind, here is what we said:
1. Affordability checks must use real financial data
Certainly at the levels of spend proposed as meriting more thorough checks (£1,000 in a day or £2,000 over the space of three months), we don’t believe there is any real substitute for real financial data, by which we mean bank data. There is simply no other way of establishing whether a player can afford to lose this amount of money or not. Everything else – including data from credit reference agencies – is guesswork. We believe that the single greatest mistake that could be made during this process is not solving the problem of financial harm caused by gambling. That won’t be an issue if the government requires decisions to be made by operators in possession of a proper financial picture of their customers.
2. We can solve two problems at once
The consultation focused on affordability checks, but it would be almost perverse to ignore the wider reality at play here. Operators also have to perform anti money-laundering and source-of-funds (SOF) checks on their customers, and they do so by looking at bank statements. Given this is the case, it makes a lot of sense to us to effectively combine both these requirements within a single check.
3. At higher spend levels, it makes sense to keep customers connected
There has been a lot of talk about how frequently checks should take place, or to put that another way, whether it should be necessary to go back to a customer within six months or a year if they have already passed a check. To us, this rather misses the opportunity presented by Open Banking in particular. After the first check, assuming the player allows it, any checks in future can be entirely frictionless. The connection can remain in place and used when necessary (and only when necessary!) in order to make the ongoing compliance relationship as smooth as possible. We don’t expect ongoing connection to be mandated, but it should certainly be held up as best practice for all concerned.
4. Some of the proposed data points make little sense
When a solution that takes guesswork out of the equation is available, does it really make sense to suggest that postcodes and job titles are meaningful ways to determine an individual’s financial situation? We don’t think so. We believe that continuing to ‘lean in’ to data like this gives a misleading impression that it is good enough. It isn’t. Even as part of a broader decision-making process, it is very difficult to see where some of these data points fit in. You could say the same, of course, about missed loan repayments from three years ago.
5. The solution exists – why cobble together a new one?
Hovering behind the entire consultation process appears to be a not-quite-defined ‘solution’ to the affordability challenge. This is apparent in the various hints towards the use of CATO data (let’s just say it, even if the Commission aren’t willing to) and a hodge-podge of random data points in order to make affordability decisions, as part of a system that would have to be piloted in order to ensure a) it works and b) it doesn’t create data security issues.
Leaving aside the absurdity of asking us to judge the merits of an approach that hasn’t actually been defined, we would simply point out that in Open Banking, a solution to this challenge already exists. One that is already used by over 7 million people in the UK, by most UK operators to handle payments, and already used to handle affordability and SOF checks by forward-thinking operators. Why on earth are we re-inventing the wheel?
So there you have it. That’s what we told the consultation, albeit in language a little less colourful. I hope they listen.
The wait is over: The Finnish Parliament has officially approved the new gambling legislation. In a decisive plenary session, MPs voted 158 in favor to 9 opposed, with 32 abstaining. The text remained unchanged from the version presented in previous weeks, solidifying the framework for Finland’s transition from a monopoly to a licensed market.
With the political uncertainty resolved, the focus now shifts to implementation. For operators, this means the race to compliance—and market entry—has effectively begun.
The Confirmed Timeline
With the legislation passed, the roadmap to the market opening is now set. Operators must use the coming months to prepare for a rigorous licensing process.
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Early 2026: The application window is expected to open. The regulator will begin accepting and reviewing license applications.
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2026 (Throughout): The “preparatory year.” This period is dedicated to vetting applicants, ensuring technical compliance, and establishing the new supervisory authority.
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January 1, 2027: The regulated Finnish market officially opens. Licensed operators can go live with betting and online casino services.
Entering the Finnish Market with Nordic Legal
Navigating a new jurisdiction is complex, but it doesn’t have to be inefficient. With extensive experience advising on gaming licences across the Nordic markets, Nordic Legal brings a proven, practical approach to the Finnish process.
Efficiency Through Synergy If you already work with us in Denmark or Sweden, we ensure your Finnish licence application isn’t a “start from scratch” project. We build directly on our existing knowledge of your organisation and systems.
Your usual Nordic Legal contact will coordinate directly with our Helsinki team at no extra cost. This integrated approach saves you time and avoids the frustration of duplicating work you’ve already done for other Nordic licenses.
Our Approach We focus on smart compliance:
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Reusing documentation where regulations overlap.
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Anticipating regulatory questions before they are asked.
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Aligning requirements for technical standards and responsible gambling.
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Engaging constructively with the Finnish authority to ensure a smooth process.
The Finnish Licence Application Package
To support your entry, we offer a comprehensive package designed to handle the heavy lifting:
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Translation of all required documents.
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Guidance and completion of complex application forms.
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Full project management from start to submission.
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Direct communication with the Finnish regulator on your behalf.
Next Steps
The window for preparation is narrowing. Contact your usual Nordic Legal advisor today to discuss the new legislation or our Licence Application Package. Alternatively, reach out to us directly to secure your place in Finland’s upcoming regulated market.
The post Finland’s Gambling Reform Is Official – What Happens Next? appeared first on Gaming and Gambling Industry Newsroom.
Reading Time: < 1 minute
The Danish Gambling Authority has called attention to FATF’s (Financial Action Task Force) updated lists of high-risk jurisdictions: the Grey List (jurisdictions under increased monitoring) and Black List (call for actions). Among other things, gambling operators must include FATF’s lists of high-risk jurisdictions when risk assessing players.
Jurisdictions listed on the Grey List:
Algeria, Angola, Bolivia, Bulgaria, Cameroon, the Ivory Coast, DR Congo, Haiti, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands and Yemen.
Jurisdictions listed on the Black List:
Democratic People’s Republic of Korea, Iran and Myanmar
Gambling operators are required to conduct enhanced customer due diligence (EDD) pursuant to section 17(1) of the Danish AML Act, if a player is assessed to impose a higher risk of the gambling operator being misused for money laundering or terrorist financing.
Gambling operators shall conduct this risk assessment based on Annex 3 to the AML Act (high-risk factors) which includes the FATF high-risk country lists (the so called black list and grey list)
It is not required that gambling operators perform EDD if a country is listed on the FATF’s list. EDD are only a requirement for players from jurisdictions listed in the EU Regulation of High Risk Third Country list pursuant to. 17(2) of the AML Act.
The post Updated FATF Lists of High-risk Jurisdictions appeared first on European Gaming Industry News.
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Soon it may be possible to play bingo via walkie-talkie and on local radios. A bill is currently being considered by the Danish Parliament to introduce a new type of licence for bingo via walkie-talkie and local radio. The Danish Gambling Authority expects the rules to come into force as early as 1 January 2026.
If the bill is passed, providers of walkie-talkie bingo and local radio will be able to apply for a licence from 1 January 2026. The Danish Gambling Authority will update this news article when the rules are finally adopted.
How to apply for a licence
If you want to offer bingo via walkie-talkie or radio, you need a licence from the Danish Gambling Authority. You can expect to apply as early as 1 January 2026.
When applying for a licence, you must use the form “Apply for a walkie-talkie or radio bingo licence” (no. 1-02). The form will be available on the page “revenue-restricted licenses”.
The application form will also be published in a digital version, but it will not be available on virk.dk until January.
The Danish Gambling Authority strives to process all applications as quickly as possible.
As an applicant, you will be assigned a contact person who can guide you through the legislation during the application process. The contact person will generally remain the same throughout the period of validity of your licence.
Report on the first year of offering games
Licences for radio and walkie-talkie bingo are regulated by the Gambling Act and the Executive Order on Online Casino. The legislation sets out a number of requirements for licensed gambling operators. Among other things, the licence holder must complete a report on the first year of offering gambling.
The report is prepared one year after the licence has been put into use and must be sent to the Danish Gambling Authority no later than 14 months after the date when the licence has been put into use.
The licence holder can fill out the report themselves.
The report must account for how the licence holder has provided gambling in accordance with the conditions of the licence and legislation during the past year.
The report template will be available on the Danish Gambling Authority’s website as form no. 1-04.
The post Spillemyndigheden: New licence type coming soon: Bingo via walkie-talkie and local radio appeared first on European Gaming Industry News.
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