Compliance Updates

DGA: Three orders and two reprimands to Skill on Net Ltd for breach of the Anti-Money Laundering Act

Published

2 years ago

April 10, 2024

dga:-three-orders-and-two-reprimands-to-skill-on-net-ltd-for-breach-of-the-anti-money-laundering-act

Reading Time: 4 minutes

On April 3rd, 2024, the Danish Gambling Authority has issued three orders to Skill on Net Ltd (Skill on Net) for breaching the rules of the Anti-Money Laundering Act on risk assessment, procedures for internal control and documentation of implemented controls.

On April 3rd, 2024, the Danish Gambling Authority has also given Skill on Net two reprimands for breaching the rules on business procedures and the rules on whistleblower scheme in the Anti-Money Laundering Act.

The orders and reprimands are issued in connection with the Danish Gambling Authority’s inspection of Skill on Net’s material, which Skill on Net has prepared in order to comply with the Anti-Money Laundering Act.

Order for inadequate risk assessment
Order (a) has been issued because Skill on Net’s risk assessment is insufficient, as no separate risk assessment has been made of the individual identified risks associated with Skill on Net’s business model, including products and payment solutions, as well as the risk factors associated with these. Section 7(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must identify and assess the risk that the undertaking may be misused for money laundering or terrorist financing. It is the Danish Gambling Authority’s assessment that the risk assessment must include a separate assessment of the risk of the individual products and payment solutions, as well as a separate risk assessment of the risk factors associated with these. Thus, Skill on Net has not complied with the risk assessment obligation in section 7(1) of the Anti-Money Laundering Act.

Order for inadequate business processes
Order (b) has been issued because Skill on Nets’ written procedures do not describe how, when and by whom the internal controls are monitored to ensure that the internal controls are implemented. Section 8(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must have adequate written procedures, which must include internal controls. The requirement for internal control also means that checks must be carried out to ensure that the controls are implemented. Thus, Skill on Net has not sufficiently complied with the obligation to have procedures for internal control.

Order for lack of documentation for controls
Order (c) has been issued because Skill on Net has not documented that internal controls have been implemented. Section 8(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must document the checks carried out. Thereby, Skill on Net has not complied with the obligation under section 8(1) of the AML Act.

Reprimand for inadequate business processes
Reprimand (a) is given because Skill on Net’s business procedure for establishing customer relationships until October 16, 2023 was deficient, as there was a discrepancy between the business procedure and practice. Section 8(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must have adequate written procedures and that the procedures must describe how the areas are handled in practice. Thus, Skill on Net has not complied with the obligation to have sufficient written procedures for establishing customer relationships.

Reprimand (a) has been issued because Skill on Net’s business procedures up to 16 October 2023 did not take into account that customer due diligence procedures must be carried out at appropriate times, as required by section 10(1)(1)(1) of the Anti-Money Laundering Act. Thus, Skill on Net has not complied with the obligation to have sufficient written procedures for the implementation of customer due diligence procedures at appropriate times.

Reprimand (a) is also given because Skill on Net’s business procedure for politically exposed persons until 16 October 2023 was deficient, as PEP screening of customers who had not paid over a fixed defined amount was not performed on an ongoing basis. Section 18(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must have procedures in place to determine whether the customer is a politically exposed person, close associate or close business partner of a politically exposed person. Reviewing whether an established customer has changed status to politically exposed person must include all customers. Thus, Skill on Net has not complied with the obligation to have sufficient written procedures for PEP screening.

Reprimand for inadequate whistleblower scheme
Reprimand (b) is given because Skill on Net’s whistleblower scheme until June 2023 did not sufficiently meet the requirement for anonymity, as reporting could only be done by e-mail. Section 35(1) of the Anti-Money Laundering Act states that undertakings subject to the Anti-Money Laundering Act must have a system where their employees can report violations or potential violations of anti-money laundering legislation via a special, independent and autonomous channel. It also states that reports must be able to be made anonymously. Thus, Skill on Net has not complied with the requirement of anonymity for whistleblowers.

The Danish Gambling Authority assesses that an inadequate risk assessment as well as inadequate business procedures and whistleblower scheme may have increased Skill on Net’s risk of being misused for money laundering. The purpose of the risk assessment is for the gambling operator to have a useful tool that provides an overview and understanding of where and to what extent the gambling operator is exposed to being misused for money laundering or terrorist financing and what measures are necessary to mitigate the risks. Business procedures must be a description of the activities that the gambling operator must perform to ensure compliance with legislation and other regulations and that the gambling operator’s policies and guidelines are followed. Adequate risk assessment, business procedures and a whistleblower scheme are fundamental to the Anti-Money Laundering Act, and the seriousness of the violation has therefore led to three orders and two reprimands.

Duty to act
The orders entail an obligation for Skill on Net to act. This means that Skill on Net must, within two months, submit a revised risk assessment, business procedures for the control of internal controls, and within six months submit documentation that internal controls have been implemented.

The reprimands do not entail any obligation for Skill on Net to act, as the violations no longer exist, as Skill on Net has subsequently revised its business procedures and whistleblower scheme.

The post DGA: Three orders and two reprimands to Skill on Net Ltd for breach of the Anti-Money Laundering Act appeared first on European Gaming Industry News.

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Compliance Updates

Spelinspektionen Continues its Work Against Illegal Gambling in the Second Quarter of 2026

Published

18 hours ago

July 23, 2026

Wladimir P.

spelinspektionen-continues-its-work-against-illegal-gambling-in-the-second-quarter-of-2026

During the second quarter of 2026, the Swedish Gambling Authority continued its work against operators suspected of offering games without a Swedish license.

New regulatory cases were initiated and several operators corrected themselves during the processing, which means that the regulatory cases were closed without further action. This shows how important it is for the Swedish Gambling Authority to identify operators suspected of offering games without a Swedish license at an early stage and initiate supervision against them.

During the quarter, the Authority also worked on an in-depth analysis of marketing for unlicensed gambling. The analysis shows that marketing continues to be a central part of how unlicensed operators reach Swedish players. Therefore, it is important that the Swedish Gambling Authority also takes action against those who promote participation in illegal gambling.

Marketing for unlicensed gambling

Marketing today takes place through several different channels, including social media, influencers, banners, SMS, sponsored search results and other ways to drive traffic to gaming sites. In certain environments, such as gaming and social media platforms, there are particular risks as young players may be exposed to games outside the Swedish licensing system.

However, the majority of marketing for games is still for companies with a Swedish license, especially in established, traditional marketing channels. The Swedish Consumer Agency has the main responsibility for supervising the marketing of licensees, while the Swedish Gambling Authority is responsible for supervising the marketing of unlicensed operators.

“Marketing is one of several ways for consumers to access unlicensed gaming. Therefore, the work against promotion is an important part of our supervision. We see that clear information and early contact can lead to actors correcting themselves,” said Ewa Gabrielsson, investigator at the Swedish Gambling Authority.

The post Spelinspektionen Continues its Work Against Illegal Gambling in the Second Quarter of 2026 appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

Anne Marie Caulfield

Irish Gambling Regulator Threatens Prediction Market with High Court Action

Published

2 days ago

July 22, 2026

Wladimir P.

irish-gambling-regulator-threatens-prediction-market-with-high-court-action

One of the largest prediction market websites has been threatened with court action if it does not geoblock Ireland, the head of the Irish gambling regulator has said.

Prediction markets are platforms where users can trade bets and gamble cryptocurrency on sports, the financial sector, politics and more, including events relating to the war in the Middle East, the existence of aliens, and tweets posted by Elon Musk.

Anne Marie Caulfield, who has been chief executive of the Gambling Regulatory Authority of Ireland (GRAI) since it began operations last year, said prediction markets amount to betting and therefore fall under her remit.

She said the GRAI enforcement team has already been active in the space, with one of the largest such markets already geoblocking on foot of “intervention” from the authority.

Speaking on RTÉ’s This Week radio programme, Ms Caulfield said a second “is in the process of doing so”.

She added: “And if they don’t, it’s open to us to go to the High Court.”

She said sites were withdrawn in Ireland in the “vast majority” of the almost 30 interventions the GRAI had made.

She added that this had happened as quickly as 35 minutes after the intervention.

Asked what the High Court action may look like, Ms Caulfield said: “In the instance where they don’t do so, we can go to the High Court and get a blocking order for access to the site, and also in relation to the funding involved.”

Pressed on whether that action had been threatened, she said: “We have issued warning letters, yes, to that effect.”

Ms Caulfield did not name the prediction markets involved.

However, users from Ireland are already prohibited from trading “event contracts” on the prediction market Kalshi, as per its membership agreement which also lists 55 other restricted countries.

One of the other main prediction markets, Polymarket, has seen restrictions in more than 30 countries including Belgium, Germany, Italy, France, the UK, and Poland – while it operates in the US with additional compliance measures.

In May, Tánaiste and Finance Minister Simon Harris said he would ask gardaí, regulators and government departments to examine “suspicious bets” made on Polymarket.

He raised “grave concerns” around a “Wild West” of unregulated betting on the platform, as he said it would be prudent to examine if there was money laundering occurring.

His comments came after reports highlighted a million dollars worth of betting on the outcome of the Dublin Central by-election, with hundreds of thousands of that volume placed on Gerry “The Monk” Hutch not to win a seat – which is what transpired.

There is no suggestion of wrongdoing on behalf of any candidate.

Mr Harris said: “What seems to be developing at a global scale and indeed a rapid pace now is a kind of Wild West where people are placing bets in the form of cryptocurrency in a secretive, murky and unregulated manner.”

The post Irish Gambling Regulator Threatens Prediction Market with High Court Action appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

Compliance Updates

The MGA Publishes Notice on Websites Impersonating Licensed Operators

Published

4 days ago

July 20, 2026

Wladimir P.

the-mga-publishes-notice-on-websites-impersonating-licensed-operators

The Malta Gaming Authority (MGA) has observed a pattern of websites impersonating MGA-licensed operators and misleading consumers into believing that they are licensed, regulated or otherwise authorised by the Authority in accordance with the Gaming Act (Chapter 583 of the Laws of Malta) and the regulatory instruments issued thereunder.

In light of this, the MGA published a list of three websites impersonating licensed operators. The websites are:

• www.manekicasino.bet

• www.dragonaracasino.uk.com

• www.slot-hunter.at

“The MGA is hereby declaring that it has no connection with the above listed URLs and any other website, platform and/or entity impersonating the Authority and/or MGA-licensed operators. Any reference to the MGA and/or gaming licence/s said to be issued by it, as stated on these domains, are false and misleading,” the MGA noted.

“The MGA would like to remind consumers not to utilise services provided by an entity unless they have ascertained that the entity in question is duly authorised to provide such services by the Authority. Whereas MGA-licensed operators comply with strict legal requirements in the interest of consumers, the activities of unlicensed entities are unregulated, and do not provide the necessary safeguards delineated by virtue of the gaming regulatory framework, making transactions with such entities risky for consumers.”

The post The MGA Publishes Notice on Websites Impersonating Licensed Operators appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.