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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

PlayCity Partners with Streaming Platform Kick to Block Illegal Gambling Ads

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PlayCity, the state agency overseeing the gambling and lottery sector in Ukraine, has partnered with streaming platform Kick to further accelerate the blocking of illegal gambling ads on the platform.

“We are directly providing Kick’s headquarters with a list of channels that violate legislation and illegally advertise gambling,” PlayCity said.

The agency said that the first two channels on the platform were blocked during the past week.

In addition, at the agency’s request, access was restricted last week to 37 accounts across TikTok, Instagram, Twitch and Kick, with the blocked accounts having a combined audience of more than 895,000 users.

Specifically, access was restricted to 20 TikTok accounts with 473,000 followers, 11 Instagram accounts with 314,000 followers, four Twitch channels with 107,000 followers, and two Kick channels with 1200 followers.

“Blocking such content helps quickly stop the recruitment of users into gambling through illegal advertising campaigns,” PlayCity said.

The post PlayCity Partners with Streaming Platform Kick to Block Illegal Gambling Ads appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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Compliance Updates

KSA – Target for Gambling Tax Increase Not Achieved: Expected Tax Revenues Turn Out Lower

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The recent increase in the Dutch gambling tax has failed to achieve its primary financial objectives. This is evident from the “monitor of the effects of the increase in gambling tax,” conducted by the Ministry of Finance and the Dutch Gaming Authority. As of January 1, 2025, the gambling tax was increased from 30.5% to 34.2%, and in 2026 the rate was further raised to 37.8%. The aim of this increase was to raise government revenue. The monitor shows that this goal is not being achieved as expected: the projected tax revenues turned out lower.

The tax increase was expected to yield an additional €108 million in 2025 compared to the previous year, and €216 million in 2026. However, the monitor shows that these amounts are turning out much lower: an additional €2 million was collected in 2025, and €57 million in 2026. Moreover, the tax increase is causing a decrease in revenue from state participations, resulting in even lower additional revenue for the State.

The fact that tax revenues are lower is due to several developments. In the years measured, various measures were taken to better protect players, causing the gross gaming result (GSR) of providers to decrease. This leads to a decrease in the tax base, the amount on which tax must be paid. The tariff increase itself may also have led to a decrease in the tax base, for example because physical establishments of gambling companies were closed in the interest of profitability.

The monitor also examined the effects on market size, channeling, and contributions to charities and sports. It is not possible to draw conclusions regarding this, as multiple changes occurred simultaneously. For instance, the aforementioned rules to better protect players and various advertising restrictions have also impacted the gambling market.

The post KSA – Target for Gambling Tax Increase Not Achieved: Expected Tax Revenues Turn Out Lower appeared first on Americas iGaming & Sports Betting News.

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LatAm: Beyond Brazil – Chile, Uruguay and Peru’s Regulatory Trajectories

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Looking beyond Brazil, which LatAm market stands out most right now, and what makes it attractive?

Liam Hoofe, Content Strategist at GameOn

Based on our research for GO Intel, I think Chile is the market to watch out for the most. The size of the opportunity is potentially massive, with the Chilean Senate’s own figures estimating that more than 5 million Chileans are already gambling online.

The demand is definitely there, and broader discussions about a regulatory framework are underway. Our estimates in GO Intel also put channelisation rates at 80% if enforcement and regulation ran smoothly.

The proposed ‘cooling-off’ period for operators already active there is also quite a unique approach, and it will benefit those who approach the market with the right foundations in place.

Of course, as we’ve seen with Brazil, there will no doubt be a lot of public debate around the market, and the tax structure could be complex, but of the three we researched, this one still stands out the most.

Paulina Hovar, Lead Sales Manager LATAM at BGaming

Right now, Mexico and Argentina stand out the most to me.

Mexico has been showing steady growth for a while now. It’s already a fairly mature market with strong operator presence, but there’s still plenty of room to scale. At the same time, one of the main things to watch is the tax situation and how regulation may develop in the future, since that could impact profitability and market dynamics.

Argentina is interesting for a different reason. The market is regulated at the provincial level, so it’s much more decentralized. That creates opportunities because entry can be more flexible, but it also means you need to understand the local landscape and choose partners and regions carefully.

Ramiro Atucha, Board Advisor to Kiron Interactive

Mexico stands out. The size of the market alone makes it attractive, and the current regulation is already acceptable enough for public companies to feel comfortable operating there. It’s also moving toward a more formal framework, so there’s still margin to grow. Beyond Mexico, I’d point to Chile, certain provinces in Argentina, and Colombia. All three have their own dynamics, but they’re markets you can’t ignore right now.

 

When entering markets that are still evolving from a regulatory perspective, what’s the right balance between moving early and waiting for clarity?

Liam Hoofe, Content Strategist at GameOn

That’s the million-dollar question, and it’s one I’m not sure there is a 100% correct answer to. For me, it’s about building relationships, ensuring you have the right infrastructure in place, and understanding a market before you invest.

Operators and studios that just enter with no understanding of the culture and of the way the regulatory landscape could adapt are putting themselves at risk of failing.

Trying to remain one step ahead of regulation and working alongside the regulators to help the market mature is always going to be a much better approach than just waiting for regulation to come into place and being reactive.

Paulina Hovar, Lead Sales Manager LATAM at BGaming

It depends on how mature the market is.

If the regulatory framework is already clear and established, then the best approach is to operate fully within the licensed model from day one.

But in markets that are still in a gray or transitional stage, where operators are already active, it can make sense to take a more gradual approach. That could mean building partnerships, adapting the product to local needs, and preparing for future regulation before fully committing.

You also have to be very careful about legal and reputational risks. Every market is different, so timing and level of involvement should be assessed on a case-by-case basis.

Ramiro Atucha, Board Advisor to Kiron Interactive

As early as possible, as long as it isn’t illegal or forbidden. That’s the right moment to enter and transition through the regulatory process. Brazil is the clearest example. Sports betting was legalized in 2018, but the full regulatory framework only came in late 2023, with licensed operations starting in 2025. The operators that used those years to attract players, test the market and build name recognition without breaking the law made a real difference. By the time regulation arrived, they were already established.

As markets like Chile, Peru, and Uruguay develop, what will separate the brands that succeed from those that struggle?

Liam Hoofe, Content Strategist at GameOn

The biggest differentiator for me is localisation, and by that, I mean real localisation, not just translating a game into Spanish and calling it a day. This means actually creating products and promotions that speak to local audiences. LatAm is not just some big monolithic market with a one-size-fits-all solution – brands that succeed there are the ones that understand this. The ones who know that a player in Chile is not the same as one in Uruguay or Brazil are going to be the big winners.

On top of that, working closely with regulators and showing genuine concern for players’ well-being in these markets will make a huge difference. It’s not enough anymore to just display simple responsible gambling tools; players want to see it in your actions, and it’s obvious to them which brands really care and which are just ticking boxes.

And finally, local partnerships. Some of the most successful companies we work with are those that really integrate themselves and find local partners that offer genuine insight into communities, and can be leveraged to build trust. This can be achieved in a number of different ways, whether it’s through working with local content creators and influencers or getting involved with local charities and events.

Paulina Hovar, Lead Sales Manager LATAM at BGaming

As markets like Chile, Peru, and Uruguay continue to develop, the following three factors will set successful brands apart from the rest.

First, strong local partnerships. Without people on the ground and a real understanding of how each market works, it’s very difficult to build a sustainable position.

Second, product adaptation. Translation alone is never enough. Companies need proper localization that reflects user behavior, cultural differences, and local audience preferences.

And third, regulatory readiness. The companies that invest early in certification, compliance, and building the right processes will have a major advantage later on. It’s expensive and takes time, but in regulated markets, long-term preparation usually makes the difference between short-term growth and lasting success.

Ramiro Atucha, Board Advisor to Kiron Interactive

Brands that bring international experience and proven competitiveness from other markets, combined with genuine local understanding, will get the best of both worlds. The international background gives you credibility and product depth. The local presence gives you a product that’s actually adapted to how players in that country behave. Neither side works on its own. In Chile, Peru, and Uruguay, the operators who get this combination right are the ones who’ll separate from the pack.

The post LatAm: Beyond Brazil – Chile, Uruguay and Peru’s Regulatory Trajectories appeared first on Americas iGaming & Sports Betting News.

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