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

GLI Becomes First International Gaming Lab to be Accredited in Ukraine

Published

2 days ago

March 27, 2026

Wladimir P.

gli-becomes-first-international-gaming-lab-to-be-accredited-in-ukraine

Gaming Laboratories International (GLI) has become the first international gaming lab to be accredited in Ukraine.

GLI Europe B.V. was appointed by Ukrainian regulatory authority, PlayCity, as both a testing/certification and inspection body for gambling equipment in the country and is currently the only foreign entity to be accredited.

GLI Europe B.V. will perform testing and certification of all gaming related hardware and software in accordance with the requirements of PlayCity and the Ukrainian gaming regulatory framework. GLI will deliver all Ukrainian certification services through its European operational hub, GLI Europe B.V., ensuring certification is conducted under GLI’s ISO/IEC 17025, 17020, and 17065 accreditations.

The company will work with both foreign and Ukrainian suppliers, whereas Ukraine is considered a regulated market, and suppliers will need to hold a certificate of approval from PlayCity in order to request certification for the market.

“We are grateful for the trust PlayCity has placed in GLI. At GLI, we work with regulators in more than 710 jurisdictions, and we will bring our global expertise to PlayCity and to suppliers who wish to enter the Ukrainian market, guaranteeing the highest levels of testing quality and compliance,” said James Boje, Managing Director, EMEIA.

The post GLI Becomes First International Gaming Lab to be Accredited in Ukraine appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.

Australia

NSW: More Than 650 Gaming Machine Exemptions Revoked to Address Gambling Harm

Published

3 days ago

March 26, 2026

Wladimir P.

nsw:-more-than-650-gaming-machine-exemptions-revoked-to-address-gambling-harm

The Minns Labor Government continues to reduce gambling harm by delivering on its commitment to remove outdated exemptions that enabled more than 650 pubs and clubs to operate gaming machines during standard shutdown hours.

Following an announcement in December by the Minister for Gaming and Racing David Harris that exemptions would cease from 31 March 2026, more than 650 venues will be required from 1 April to shut down all gaming machines between 4am to 10am each day, in line with NSW standard shutdown hours.

The six-hour shutdown is a harm minimisation measure intended to provide players with an important break in play.

Of the 672 venues with a varied shutdown period, usually for three hours instead of six, many have been in place for more than 20 years. These were given for reasons including being in high traffic ‘tourist’ locations, a history of earlier opening hours or financial hardship.

Venues that believed they had a strong case to keep their exemptions under the legislation and the revised Ministerial Guidelines, had the opportunity to put their case to Liquor & Gaming NSW.

As of 24 March 2026, 649 have been revoked by Liquor & Gaming NSW under delegation from the Independent Liquor & Gaming Authority and 10 by the Authority itself. Thirteen venues remain under assessment. All venues will be considered and an outcome communicated by 31 March 2026.

Sixty-two venues applied to keep their exemptions. Of the 49 applications assessed so far, all have been revoked.

Liquor & Gaming NSW will undertake a compliance campaign after 1 April when the new requirements come into effect, to ensure all venues are abiding by the changes.

A Review of Gaming Machine Shutdown Hours Framework conducted by Liquor & Gaming NSW in 2024 found that a minimum six-hour shutdown period, commencing no later than 4am, is effective at minimising gambling harm.

The move continues a suite of gaming reforms which the Minns Government has implemented since coming into office, including:

• Reducing the cash input limit from $5000 to $500 for all new gaming machines

• Reducing the state-wide cap on gaming machine entitlements, so that every year the number of gaming machines reduces based on forfeiture rates

• Banning political donations from clubs with electronic gaming machines

• Banning external gaming-related signage and internal gaming-related signage that can be seen from outside the venue

• Introducing Responsible Gambling Officers in venues with more than 20 gaming machine entitlements and mandating that extra Responsible Gambling Officers be on duty in venues after midnight

• Mandating that all venues with gaming machines must keep a Gaming Plan of Management and a Gambling Incident Register

• Banning gambling advertising on public transport and the ferries and terminals people catch it from

• Consulting with the community on a third-party exclusion scheme and use of mandatory facial recognition technology to support a statewide exclusion register for NSW hotels and clubs with gaming machines

Launching a NSW-first code of practice for the use of facial recognition in pubs and clubs that use the technology, following full consultation with a wide range of stakeholders including harm minimisation advocates, the NSW Privacy Commissioner and industry.

Minister for Gaming and Racing David Harris said: “The Minns Labor Government takes gambling harm minimisation seriously and that’s why I called for a review of the gaming machine variations back in December that has removed outdated exemptions that enabled more than 650 pubs and clubs to operate gaming machines during standard shutdown hours.

“Following months of review, it was clear these variations enabling about 20 per cent of clubs and pubs with gaming machines to operate outside of the mandated hours, some of which were more than 20 years old, were no longer fit for purpose.

“To enable variations to be revoked, I updated the Ministerial Guidelines and set up a streamlined process for venues to make their case if they wished to keep their variation, and to allow for a transition period.

“These changes are expected to prevent and reduce gambling harm.

“The NSW Government will continue to deliver evidence-based reforms to ensure we are striking the balance of addressing gambling harm while supporting sustainable development of an industry that employs more than 150,000 people in NSW and injects billions into the economy.”

The post NSW: More Than 650 Gaming Machine Exemptions Revoked to Address Gambling Harm appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.

Compliance Updates

UK Government proposals to undermine the ‘aim to permit’ of the Gambling Act 2005?

Published

3 days ago

March 26, 2026

Wladimir P.

uk-government-proposals-to-undermine-the-‘aim-to-permit’-of-the-gambling-act-2005?

Richard Bradley, partner at gambling licensing law firm Poppleston Allen, shares how new proposals in Parliament may affect licensed premises

The ‘aim to permit’ principle may be under threat
Switching the burden of proof from “if nothing wrong with the application, it should in theory be approved” to “the application can be rejected if on the licensing authority’s opinion the grant may not uphold the licensing objectives”

Members of the House of Lords have begun their further examination of the English Devolution and Community Empowerment Bill, (EDCE) which is in report stage and will be discussed again today, with report stage concluding 13 April 2026.

Baroness Taylor of Stevenage, a Labour Life Peer in the House of Lords, has tabled an amendment to the English Devolution and Community Empowerment Bill which proposes to introduce Gambling Impact Assessments by inserting two new sections to the Gambling Act 2005 (‘the Act’).

If the amendment is passed and these sections are inserted into the Act, this will allow a licensing authority to publish a Gambling Impact Assessment (GIA) where the authority considers the granting of any relevant licence to premises in their area is not likely to be reasonably consistent with one or more of the licensing objectives because:

The cumulative impact of relevant licences in respect of premises in the affected part(s) or
Other reasons which relate to that licensing objective, or those licensing objectives, and to the affected part(s).

A relevant licence has been defined as being:

a bingo premises licence
adult gaming centre premises licence
family entertainment centre premises licence or
a betting premises licence.

An authority would also be able to limit the numbers of licences in an area.

As part of any published assessment, the authority must set out evidence for how they have come to the opinion that the grant of any relevant licence would not be reasonably consistent with the objectives set out above.

Authorities will also be required to review any published GIA from time to time, and should the authority take the view that the assessment should be revised or withdrawn, they must publish any revision.

Where an application is submitted for a relevant licence and a GIA has been published and the authority has included in its Statement of Gambling Principles that there will be a presumption to refuse applications for relevant licences, then it will be deemed lawful for the authority to refuse such application solely on the ground that it falls within the scope of the GIA.

That being said, the amendment does confirm that refusing an application will be unlawful where the applicant asserts in the application that the grant would be reasonably consistent with the licensing objectives or objectives set out in the GIA and provides evidence that the grant would be reasonably consistent with the objectives.

Full details of the tabled amendment can be found here.

The post UK Government proposals to undermine the ‘aim to permit’ of the Gambling Act 2005? appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.