Compliance Updates
Two reprimands for Danske Licens Spil A/S for breach of the Anti-Money Laundering Act
On June 13th, 2023, the Danish Gambling Authority has reprimanded Danske Licens Spil A/S for lack of compliance with the requirement for enhanced customer due diligences measures of section 17(1) of the Anti-Money Laundering Act.
The reprimand is given because Danske Licens Spil A/S did not perform enhanced customer due diligence measures concerning a specific player at an earlier stage in the customer relationship, as it should have been assessed that the player constituted an increased risk of money laundering based on the transaction volume and the number of reports to the Financial Intelligence Unit. Thereby, Danske Licens Spil A/S has not complied with the requirement for performing enhanced customer due diligence measures. At a later stage in the customer relationship, Danske Licens Spil A/S performed enhanced customer due diligence measures and subsequently ended the customer relationship.
Moreover, the Danish Gambling Authority has reprimanded Danske Licens Spil A/S for breaching the rules on reporting of section 26(1) of the Anti-Money Laundering Act.
The reprimand is given in the same customer relationship because Danske Licens Spil A/S in two instances failed to report to the Financial Intelligence Unit despite not being able to dismiss a suspicion of money laundering after the conclusion of an investigation. Thereby Danske Licens Spil A/S has not complied with the obligations on reporting. Previously, Danske Licens Spil A/S had made several reports concerning the customer. The fact that a gambling operator has made reports to the Financial Intelligence Unit concerning a customer relationship does thereby not exempt the gambling operator from its obligation to report subsequent new suspicious transactions.
No obligation to act
The reprimands cause no obligation to act for Danske Licens Spil A/S, because the breaches no longer exist.
The Danish Gambling Authority notes that the rules on enhanced customer due diligence measures and the obligation to report are fundamental parts of the Anti-Money Laundering Act. As a rule, breaches of the rules lead to an order or a reprimand or in serious or repeated cases, they are reported to the police.