Compliance Updates
DGA: Three orders and two reprimands to Skill on Net Ltd for breach of the Anti-Money Laundering Act
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.
Compliance Updates
ECA: EU Member States Miss Out on €22.9 Billion in Tax Revenue Due to Illegal Online Gambling
The European Casino Association (ECA) hosted a high-level roundtable in the European Parliament on tackling illegal online gambling. The event title still referred to the 2024 figure of €80 billion, the figure available when the roundtable was organised, but that number was overtaken at the event itself: the 2025 figures, released for the first time during the roundtable, showed that the illegal online gambling market aimed at EU consumers had reached €91.6 billion, an increase of around 14%. The title was therefore already outdated the moment the new numbers were presented. Drawn from the study commissioned by the ECA to Gambling Compliance International (GCI) and set out by ECA Chair Erwin van Lambaart, this rise deprived EU Member States of an estimated €22.9 billion in tax revenue.
A high-level roundtable in the European Parliament
The European Casino Association (ECA) organised a high-level roundtable discussion on illegal gambling in the European Parliament. Hosted by MEP Lukas Mandl, the gathering brought together EU lawmakers, the European Commission, the Anti-Money Laundering Authority (AMLA), Eurojust, the Joint Parliamentary Scrutiny Group (JPSG) on Europol, national gambling regulators and industry experts.
During the discussion, ECA Chair Erwin van Lambaart presented the 2025 figures from the impact study on illegal online gambling that the ECA commissions annually from Gambling Compliance International (GCI). Participants exchanged views under the Chatham House Rule on the growing scale of illegal online gambling, how it is currently tackled, and what more can be done at European level. They acknowledged the growing scale of the problem and called for stronger enforcement and closer cooperation to support a safe, well-regulated gambling environment.
The discussion is timely, coming shortly after the European Commission’s proposal to reform the mandate of Europol, a key institution in the fight against cross-border crime, including illegal gambling.
What the 2025 GCI figures show
The latest impact study, commissioned by the ECA to Gambling Compliance International (GCI), shows that the illegal online gambling market aimed at EU consumers reached €91.6 billion in 2025, an increase of around 14% on the previous year. This clear upward trend deprived EU Member States of an estimated €22.9 billion in tax revenue in 2025.
The figures also show that illegal operators now account for the majority of online gambling revenue in the EU-27, that more than 6200 illegal operators are actively targeting European consumers, and that the overwhelming majority of online gambling content Europeans are exposed to promotes illegal, unlicensed operators.
What is meant by “illegal gambling”
In the 27 Member States of the European Union, there is no grey market and no third category. A gambling operator is either legal, meaning it is licensed in the country where it serves its customers, or it is unlicensed and therefore illegal. When the ECA speaks of illegal gambling, it means operators serving European consumers without the licence that national law requires.
What sets legal and illegal operators apart
Legal, licensed operators abide by national and EU law, apply anti-money-laundering measures and cooperate closely with national and EU authorities. They protect vulnerable consumers, with particular care for young adults, through strict responsible-gambling programmes; they make significant tax contributions; and they support local development, tourism and jobs.
Illegal, unlicensed operators, by contrast, operate outside any licence and any regulatory or ethical standard. They fail to apply anti-money-laundering measures and can facilitate money laundering and the financing of crime. They ignore age and identity checks and actively target young and vulnerable players, using aggressive marketing, personalised bonuses and free plays to drive compulsive play. They pay no tax in the countries they target, and they mislead consumers, for example by using the logos of legitimate operators in advertising to commit fraud.
ECA Chair Erwin van Lambaart said: “The 2025 data from the GCI report leaves no room for doubt: illegal online gambling is a fast-growing, cross-border problem that puts players, especially young adults, at high risk, deprives societies of much-needed tax revenues, and undermines trust in the regulated market. Licensed casinos and their online businesses operate under strict rules and invest heavily in responsible gambling and anti-money-laundering measures. Yet illegal operators, often based outside the EU, can reach European consumers at the click of a button, without safeguards, without oversight and without contributing to our communities.”
“This is why we need strong political will and strengthened public-private cooperation that is aligned with this reality. By connecting national enforcement efforts, financial intelligence units and sector expertise, European institutions and agencies such as the European Commission, Europol and AMLA can help us turn data into action. If we fail to act now, the illegal online market will continue to grow at the expense of players, public finances and legitimate businesses.”
MEP Lukas Mandl said: “Illegal online gambling is not a niche issue, it is a serious cross-border threat that touches on consumer protection, organised crime and the integrity of our internal market. Europol is a crucial partner for Member States, but we must ensure that its mandate and resources allow it to fully support the fight against these illegitimate activities.”
“The evidence presented by the European Casino Association today show where cooperation is needed to do more. I will bring these insights into our parliamentary work and encourage colleagues cross-party to jointly go against the negative effects of illegal gambling from mental health issues to existential disasters of individuals and entire families, so that we can better protect citizens and make a clear difference between criminal activities and those operators who play by the rules.”
The post ECA: EU Member States Miss Out on €22.9 Billion in Tax Revenue Due to Illegal Online Gambling appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
Yaspa CTO Toby Sucharov comments in relation to yesterday’s UKGC announcement on Financial Risk Assessments. “The Commission’s decision to introduce Financial Risk Assessments in stages is a significant moment for the UK gambling sector. The original ambition was always to protect vulnerable consumers without disrupting the majority of players, and today’s announcement shows that the industry is now moving from debate into implementation.
“The crucial question is whether the data being used is good enough to support that ambition. Credit reference agency data has clear advantages because it can be frictionless, but it is also limited. It can show missed payments, defaults or debt management plans, but those are often signs that financial harm has already happened. It is more of a rear-view mirror than a windscreen.
“To protect consumers sustainably, operators could benefit from more direct insights into a customer’s real financial position. That is where open banking has an important role to play, particularly for the small proportion of customers who cannot be assessed cleanly through credit reference data alone. Real-time bank transaction data can provide a clearer view of income, disposable income and gambling activity.
“The key challenge that led to using credit reference agencies was the friction around gaining customer consent. Traditional affordability checks have struggled because they ask customers to complete a separate task, often through an email or on-site message that is disconnected from what the customer is trying to do. Consumers do not complete operator tasks – they complete their own tasks.
“Our view is that the check has to be tied to the customer journey, particularly the deposit journey. If a customer is already choosing to add funds, a clear and proportionate prompt can make the process feel intuitive rather than intrusive. We have seen real-time deposit-integrated checks converting at 70%, versus a typical rate of 12% for traditional affordability checks. That’s a material distinction, and enables the industry to deliver meaningful financial risk assessments while preserving the frictionless experience the Commission, operators and customers all want.”
The post Inside View: Yaspa CTO on the UKGC Financial Risk Assessment appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
The Australian Communications and Media Authority (ACMA) has issued a formal warning to mixed martial arts fighter Jamie Mullarkey for breaches of Australia’s online gambling laws.
An ACMA investigation found that in 2025 Mr Mullarkey promoted an illegal offshore gambling service in sponsored posts on his Instagram account. Mr Mullarkey’s Instagram profile also referred to his sponsorship arrangements with the service, including a link to the gambling site and posts with promotional hashtags referring to the service.
Australian online gambling rules prohibit the promotion of illegal gambling services. This includes posts or live streams featuring illegal services, sharing links to those services or running promotional giveaways connected to illegal gambling services.
ACMA member Carolyn Lidgerwood said the enforcement action puts social media influencers and their agents on notice.
“Athletes and social media personalities with large online followings can have significant influence over their audiences and can encourage the use of illegal gambling services,” Ms Lidgerwood said.
“This is the first enforcement action we have taken against an influencer for breaching online gambling rules, and it should serve as a warning to others.
“In this case the ACMA issued a formal warning considering the specific circumstances of the matter. This included that Mr Mullarkey ended the sponsorship arrangement promptly, cooperated with the investigation and quickly removed the material. Mr Mullarkey also accepted responsibility for his conduct and expressed genuine remorse.
“However, all influencers need to be aware that promoting illegal online gambling sites is against the law and can result in significant penalties.”
Individuals who promote or publicise illegal online gambling services can face civil penalties of up to $59,400. Those who facilitate access to illegal gambling services, including by providing hyperlinks or directing users to those services, may face penalties of up to $2,475,000.
“The ACMA will use its full suite of regulatory tools, including these substantial civil penalties, where influencers promote or facilitate access to illegal gambling services,” Ms Lidgerwood said.
The post ACMA Warns MMA Fighter Jamie Mullarkey for Breaches of Online Gambling Laws appeared first on Americas iGaming & Sports Betting News.
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