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
Finland Govt Looks at Whether Scratchcards can be Gifted Again
Finland’s Interior Ministry is examining whether scratchcards might once again be allowed as gifts.
The investigation will consider whether winnings from a scratchcard could be claimed by someone other than the person who purchased the card.
At the start of 2024, scratchcards were brought under mandatory identification rules. Since then, recipients of gifted cards have been unable to redeem any prizes they potentially offer.
Parliament approved a new Lotteries Act in December. At the same time, legislators included a statement urging the government to explore ways to permit scratchcards to be given as gifts.
Christmastime is traditionally the biggest season for lottery scratch card sales in Finland.
The post Finland Govt Looks at Whether Scratchcards can be Gifted Again appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.
Compliance Updates
VNLOK Report: Over 95% of Gambling Ads on Meta Platforms are from Illegal Providers
Illegal gambling providers continue to reach Dutch consumers on a large scale via Meta platforms. An analysis by VNLOK’s Ads Library for October, November and December 2025 shows that in each month, more than 95% of the gambling promotions found—both Facebook pages and advertisements—come from illegal providers. At the same time, only a small portion is removed by Meta, which calls for faster and more robust measures.
Illegal gambling advertisements are widely visible
Recent analyses show that illegal gambling advertising via meta-platforms remains widely visible to Dutch consumers. Of the Facebook pages and gambling ads promoting gambling, over 95% originated from illegal gambling providers in all three months.
Fast rotation with a wide reach
It’s striking that ads from illegal providers are rolled out and replaced at breakneck speed: on average, they were visible for one and a half days in October (79% for less than a day), two days in November (69% for less than a day), and two days in December, with 87% of illegal ads being visible for less than a day. Illegal gambling ads also have a wide reach, peaking at 50 million impressions in November.
Enforcement is lagging behind
The regulated Dutch gambling market is designed to protect consumers through strict duty of care, affordability guarantees and advertising regulations. Illegal providers fall outside this system, yet still manage to reach Dutch target groups on a large scale through social advertising. The share of illegal ads removed by Meta remains limited: 3% in October, 5.2% in November and 4.7% in December.
“These figures are alarming. The enormous flood of illegal gambling advertisements on Meta platforms undermines player protection and also erodes trust in the legal market. This problem is unfortunately growing. The promotion of illegal gambling websites on social media is expanding from social advertising to social content. Meta and other platforms are being flooded with viral videos featuring the brands of illegal gambling websites. This content is attracting targeted minors and young adults to illegal gambling offerings, where the risk of gambling harm is very high,” Björn Fuchs, Chairman of VNLOK.
Call from VNLOK
The findings show that the current approach by platforms and regulators is insufficiently aligned with the scale and speed of illegal gambling advertising on social media. To better protect consumers and safeguard the regulated system, additional and targeted actions are necessary:
Meta must strengthen proactive detection, advertiser verification, and rapid takedown processes for illegal gambling promotions targeting the Netherlands.
The Netherlands Gambling Authority must take even more enforcement action, within existing legal frameworks, against marketing companies and platforms that facilitate advertisements and/or content that direct Dutch consumers to illegal gambling websites.
The visibility and attractiveness of legal online gambling are crucial to prevent even more Dutch players from turning to illegal providers. Policymakers and regulators must ensure that additional rules and restrictions for legal providers do not compromise the visibility and attractiveness of legal online gambling. This will lead to a decrease in the net protection of Dutch consumers. A sufficiently visible and attractive legal offering is crucial to prevent even more Dutch players from turning to illegal providers.
The post VNLOK Report: Over 95% of Gambling Ads on Meta Platforms are from Illegal Providers appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.
Compliance Updates
eGaming Integrity launches Voluntary Code Advisory Service for prize draw operators
eGaming Integrity – a leading compliance and internal audit advisory firm – has launched a Voluntary Code Advisory Service to support online prize draw and competition operators as regulatory scrutiny of the sector increases and a new compliance deadline approaches.
The service was launched following the introduction of the Department for Culture, Media and Sport’s Voluntary Code of Good Practice for online prize draws and competitions in November 2025. The Code sets a deadline of 20 May 2026. By that point, operators are expected to be more transparent, strengthen consumer protections and show active oversight of their operations. Failure to demonstrate effective voluntary compliance may increase the likelihood of statutory licensing and subsequent tighter regulation.
Prize draws are not regulated as gambling under the Gambling Act 2005. Despite this, the sector has grown rapidly and attracted attention in Westminster. The UK online prize draw market is now estimated to be worth around £1.3bn, with more than 7 million players. That scale has brought closer attention from policymakers.
The Voluntary Code shifts the focus from policy language to demonstrable practice. Operators now have to show what they actually do, and prove it.
eGaming Integrity’s new service is designed to help operators understand the requirements of the Code, assess current practices and prepare clear, practical evidence of compliance. Support covers areas including free entry routes, transparency of terms and odds, responsible marketing practices, internal monitoring processes and public disclosure of consumer protection measures.
Emma Shilling, Director at eGaming Integrity, said: “The Voluntary Code changes the conversation for prize draw operators. It is no longer enough to point to a policy and say the right words are there. Operators are being asked to show what happens in practice. Our job is to help businesses work that through properly, spot issues early and evidence what they are doing.”
eGaming Integrity’s audit and risk specialists lead the work. The focus is on practical rather than theoretical matters. Findings are clearly set out, with recommendations that operators can act on as regulatory expectations tighten.
Robert Penfold, Head of Internal Audit at eGaming Integrity, said:
“The writing is on the wall. This is voluntary for now, but that could change quickly. Operators who build real oversight systems today won’t be scrambling if this becomes statutory tomorrow.”
The Voluntary Code Advisory Service is available immediately to UK prize draw and competition operators.
The post eGaming Integrity launches Voluntary Code Advisory Service for prize draw operators appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.
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