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Compliance Updates

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

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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

Finland consults on online gambling rules with slot stake caps and autoplay ban

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Finland’s Ministry of the Interior has published a draft regulation for public consultation that would set detailed product-level requirements for gambling offered by holders of Finnish gambling licences. The regulation is proposed to enter into force on 1 July 2027, as Finland prepares for its new licensing regime.

The draft introduces maximum stakes across electronic casino game categories. Electronic slot machine games and electronic bingo would be capped at EUR 20 per round, with higher limits proposed for certain electronic table games. Online poker would be subject to a maximum initial bet of EUR 1,000 per game. Where a combination game spans multiple categories, the explanatory memorandum says the applicable maximum stake would be determined by reference to the game types included in that combination.

A lower set of stake limits would apply to players under 25. For this group, the maximum stake for electronic slot machine games and electronic bingo would be EUR 10 per round, with reduced caps also proposed across several table game categories.

The draft also regulates tournament entry fees and jackpot mechanics. Table game tournaments (excluding player-versus-player poker) would be capped at EUR 1,000, player-versus-player poker tournaments at EUR 5,000, and electronic slot machine tournaments at EUR 500. It expressly permits surprise-type jackpots and winning-combination jackpots, including fixed, odds-based and progressive jackpots.

For electronic slot machine games, the proposal adds game design and player protection requirements that would effectively prohibit autoplay. Players must choose their own stake and start each round themselves, and operators may not offer or technically enable simultaneous play of two or more electronic slot machine games. Each round must last at least 2.5 seconds and players must not be allowed to shorten the draw time before the result is displayed. The draft also restricts presentation features that could imply a win is likely in future rounds or misrepresent losses, requires disclosure that in electronic games of chance player choices do not affect the draw outcome, and mandates on-screen playing-time reminders every 15 minutes with a continue-or-logout choice (with an exception for electronic casino games where players play against each other).

The consultation is open to anyone wishing to comment, with submissions due by 5 August. The regulation remains in draft form and may change before adoption.

The post Finland consults on online gambling rules with slot stake caps and autoplay ban appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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Betting and Gaming Council

Betting and Gaming Council Launches Five-point Action Plan to Combat Illegal Gambling Black Market

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The Betting and Gaming Council (BGC) has launched a major new five-point plan to crack down on the growing illegal gambling black market, warning that failure to act will expose consumers to fraud, criminality and gambling-related harm.

The standards body, which represents around 90% of the regulated UK betting and gaming industry, is calling on ministers, regulators, technology companies and financial institutions to work together to shut down illegal operators targeting British consumers.

The BGC’s intervention comes amid growing evidence that the illegal gambling market is expanding at an alarming rate. Independent forecasts by H2 Gambling Capital estimate that black market gambling stakes could rise from £17bn in 2025 to more than £33bn by 2028, with almost one in every five pounds staked online potentially being placed with illegal operators within three years.

These operators offer none of the protections required in the regulated sector, pay no UK tax, contribute nothing to British sport and expose consumers to significantly greater risks of fraud, financial crime and gambling-related harm.

Every customer lost to the black market is a customer gambling without safeguards, without oversight and without the protections that exist within Britain’s highly regulated gambling market.

The BGC warned that allowing the black market to continue to grow would undermine years of progress in raising standards and protecting vulnerable consumers.

The BGC’s Five-Point Plan

1. Shut down illegal gambling advertising

Make social media companies responsible for removing illegal gambling content and advertisements, preventing criminal operators from reaching British consumers and protecting children and vulnerable groups from exposure.

Illegal operators increasingly rely on social media, search engines and online advertising to attract customers. The scale of the problem is growing rapidly. Analysis by WARC found that illegal operators now account for almost half of all UK gambling advertising spend and are projected to overtake licensed operators by 2028. Stronger action is needed to ensure illegal gambling advertisements are removed quickly, preventing criminal operators from targeting British consumers and reducing exposure among children and vulnerable people.

2. Block illegal gambling websites

Give the Gambling Commission stronger powers to block illegal gambling websites, remove unlicensed gambling apps and disrupt criminal operators targeting British consumers.

Illegal operators can rapidly create new websites and applications designed to mimic legitimate gambling brands, making enforcement increasingly difficult. The growth of the black market underlines the need for stronger powers. Analysis by H2 Gambling Capital shows the amount staked with illegal operators has surged to £16.6bn, more than tripling since 2019 and doubling in the last two years alone. Regulators need the ability to remove illegal sites more quickly and make it harder for criminal operators to reach consumers.

3. Cut off the money

Prevent payment providers from facilitating transactions linked to illegal gambling operators and disrupt the financial networks that sustain the black market.

Illegal gambling businesses depend on the ability to move money into and out of customer accounts. H2 Gambling Capital analysis found black market operator profits and stakes have both doubled between 2023 and 2025, demonstrating the growing financial strength of illegal operators. Stopping payments reaching unlicensed operators would strike directly at the business model that allows the black market to flourish and make it significantly harder for criminal enterprises to operate.

4. Hold enablers accountable

Introduce meaningful penalties for companies that knowingly provide advertising, payment processing, hosting or other services to illegal gambling businesses.

Illegal operators do not act alone. A network of companies often facilitates advertising, payments and online services, helping criminal operators reach British consumers. At the same time, Alvarez & Marsal analysis shows advertising compliance among licensed operators is exceptionally high, with Advertising Standards Authority rulings relating to fewer than 0.02% of gambling adverts. While regulated businesses comply with strict rules, illegal operators increasingly use influencers, search engines and AI-generated content to target consumers outside the regulatory framework. Those who knowingly enable such activity should face meaningful consequences.

5. Get tougher on illegal operators

Create tougher criminal sanctions against those who operate, support or profit from illegal gambling operations targeting UK consumers.

The penalties for operating illegal gambling businesses should reflect the significant consumer harm they can cause. Tougher sanctions would act as a deterrent while providing law enforcement with stronger tools to disrupt organised criminal activity. The urgency is clear: H2 Gambling Capital forecasts that stakes with illegal operators will rise from £17bn in 2025 to more than £33bn by 2028, meaning almost one in five online betting and gaming stakes could be placed with the black market within three years if action is not taken.

Grainne Hurst, Chief Executive of the Betting and Gaming Council, said: “The black market is growing fast, becoming more visible and attracting billions of pounds in stakes from British consumers.

“These forecasts are a wake-up call for everyone involved in protecting consumers. If current trends continue, black market gambling stakes could exceed £33bn within three years, with almost one in every five pounds staked online potentially ending up with illegal operators.

“That should concern anyone who cares about consumer protection and reducing gambling-related harm.

“Illegal gambling operators offer none of the protections required in the regulated sector. They do not conduct safer gambling interventions, they do not carry out identity checks, they do not verify age properly and they provide no route to redress when things go wrong.

“Every customer who is driven into the black market loses those protections.

“The evidence is already clear. Illegal operators are targeting British consumers online, advertising through social media, processing payments through legitimate financial systems and exploiting gaps in enforcement.

“If policymakers fail to tackle this growing threat, more gambling will take place in environments with no safeguards, no oversight and no consumer protections.

“This is not simply an issue for the regulated industry. It is a consumer protection issue, a public health issue and a criminal justice issue.

“Government, regulators, technology companies and payment providers must work together to stop illegal operators reaching British consumers, cut off their funding and hold those who facilitate their activities accountable.

“Our five-point plan sets out practical, targeted measures that would strike at the heart of the black market and better protect consumers.

“The BGC said the issue has become increasingly urgent as illegal operators become more sophisticated, using social media platforms, affiliate networks, search engines and encrypted communications to attract customers away from the regulated market.

The growth forecast for the black market demonstrates that current efforts are failing to keep pace with increasingly aggressive illegal operators who are targeting British consumers online while operating entirely outside UK regulation.

The standards body warned that any policy which unintentionally pushes consumers towards unlicensed operators risks strengthening criminal businesses, increasing gambling-related harm and undermining the significant investment made in safer gambling protections by the regulated sector.

As more consumers are exposed to illegal gambling products, they lose access to the safer gambling tools, affordability protections, age-verification checks and dispute resolution mechanisms that exist in the regulated market. The BGC warned that continued growth in the black market will increase gambling-related harm and undermine efforts to raise standards across the sector.

While the creation of the Government’s Black Market Taskforce was a welcome first step, more action is needed. The BGC is calling for the work of the Taskforce to be strengthened and translated into concrete action, ensuring regulators, law enforcement agencies, payment providers and technology companies work together to disrupt illegal operators and protect consumers.

Protecting consumers means keeping them within the highly regulated market, where robust safeguards, safer gambling tools and effective oversight are already in place.

The post Betting and Gaming Council Launches Five-point Action Plan to Combat Illegal Gambling Black Market appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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Ciarán Carruthers

GCGRA Appoints Ciarán Carruthers as Chief Executive Officer

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The General Commercial Gaming Regulatory Authority (GCGRA) announced the appointment of Ciarán Carruthers as Chief Executive Officer.

Ciarán Carruthers brings extensive experience across global luxury resort and gaming sectors and joins from Crown Resorts in Australia, where he served as Chief Executive Officer. He joins GCGRA at a pivotal moment in the development of commercial gaming regulation in the UAE, bringing deep operational expertise and regulatory experience to advance the Authority’s mission to establish a world-class, transparent and responsible regulatory framework. He has led significant regulatory and operational transformations across the global gaming industry, including restoring Crown Resorts to full licensing suitability, overseeing large-scale operations at Wynn Macau and advancing responsible gaming frameworks that have helped shape industry standards.

Jim Murren, Chairman of GCGRA, said: “We are pleased to welcome Ciarán to the GCGRA leadership team. He brings the experience and vision to lead the Authority as we continue to build a world-class regulatory framework for commercial gaming in the UAE.”

Ciarán Carruthers said: “I am honoured to join GCGRA and contribute to the continued development of the UAE’s regulatory framework for commercial gaming. The UAE is establishing itself as a global benchmark for modern and responsible gaming regulation, and I look forward to working closely with the team, licensees, and government partners to deliver on that ambition.”

The post GCGRA Appoints Ciarán Carruthers as Chief Executive Officer appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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