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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.

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PAGCOR Enforces Accreditation for All iGaming Service Providers by 2026

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The Philippine Amusement and Gaming Corporation (PAGCOR) has given gaming affiliates, developers and support service providers until early 2026 to comply with its newly implemented B2B Accreditation Framework, a regulatory system that formalises participation in the iGaming supply chain.

Companies that submit applications by December 31, 2025, will qualify for a three-year initial accreditation, while unaccredited foreign content providers face removal from licensed platforms after March 31, 2026.

The framework, which took effect on October 2, sets mandatory accreditation requirements for all third-party entities providing gaming content, systems or technical support to PAGCOR-licensed operators.

Accreditation covers several categories, including gaming affiliates, game content providers (GCPs) and support service providers (SSPs). Gaming affiliates may act as aggregators that distribute multiple game titles to operators, while GCPs are developers or studios supplying electronic game software or live-streamed content.

Accreditation is valid for two years from the date of PAGCOR Board approval, an increase from the previous one-year term.

Foreign data or content streaming providers that fail to secure accreditation by the March 2026 deadline will have their content deemed “non-compliant and unauthorized.” They may appoint a Philippine-registered company or a PAGCOR-accredited Gaming System Administrator as their exclusive distributor instead of setting up a local office.

PAGCOR has warned that licensed operators using unaccredited service providers may face sanctions.

The post PAGCOR Enforces Accreditation for All iGaming Service Providers by 2026 appeared first on European Gaming Industry News.

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Curacao Gaming Authority statement

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The Gaming Control Board (GCB) is a foundation established on 19 April 1999 with the specific purpose of becoming the supervisor of the entire gaming industry operating in and from Curaçao. With the entry into force of the National Ordinance on Games of Chance (LOK) on 24 December 2024, the GCB has been designated as the Curaçao Gaming Authority (CGA) and will continue operations under this name.

The CGA is led by a Board of Directors under the supervision of a Supervisory Board. Until recently, the CGA fell under the political-administrative responsibility of the Minister of Finance; since 19 august 2025 this responsibility has been transferred by the government to the Minister of Justice, as announced by the government on 13 october 2025.

In the context of its activities and its commitment to transparency, the CGA confirms that the Supervisory Board resigned in mid-September. The process to appoint new members by the government has already begun. This development has no impact on the performance of the CGA’s supervisory duties, including the continued implementation of the National Ordinance on Games of Chance (LOK). All licensing and supervisory activities continue uninterrupted.

The Curaçao Gaming Authority remains committed to ensuring the integrity and reliability of the gaming sector in Curaçao.

The post Curacao Gaming Authority statement appeared first on European Gaming Industry News.

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Compliance Updates

KSA: Monitoring report autumn 2025: turnaround in market development, concerns about illegal share

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The growth of the legal online gambling market appears to be stagnating, but the illegal market continues to grow. This turnaround in the legal market is partly due to the positive effects of measures introduced a year ago to protect players. This is according to the Dutch Gaming Authority (Ksa) in its autumn 2025 monitoring report. Although the number of players is still increasing, the gross gaming result (GSR) of the legal market is lagging behind.

The gross gaming result (GSR, stakes minus prizes paid out) for the first half of 2025 is €600 million. Six months earlier, it was 16% higher, at €697 million. This is partly due to the introduction of new rules to better protect players, which also include a deposit limit.

Number of players and accounts

The number of accounts played on a monthly basis has increased: in the second half of 2024, this averaged 1.18 million accounts. In the first half of 2025, this number rose to 1.29 million. On average, 7.1% of the accounts are new. More new accounts are likely being created because, with the implementation of the new rules at the end of 2024, players will be able to deposit less per account monthly without sharing their income data with the provider.

A player can have multiple accounts, so the number of accounts doesn’t equal the number of people gambling. It’s estimated that in the first six months of 2025, there were 839,000 active players with legal providers. This means that 5.7% of the adult population gambled legally online during those months. That’s slightly more than the previous six months, when that percentage was 5.4%.

Loss

The average player’s monthly losses have decreased substantially since the implementation of the protective measures. While the average loss per player was €146 per month at the end of 2024, it has dropped to €119 per month by the beginning of 2025. This takes into account the fact that players play with multiple providers and may not be active every month.

Young adults (ages 18 to 24) played with 23 percent of the accounts used in the first half of 2025. This is relatively high, as they represent only 9.3% of the adult population. They do lose less money per account on average than adult players, namely €37 per month compared to €78 for adults. Compared to the total player population, young adults also engage in relatively more sports betting.

Illegal market

The channeling in terms of players (the percentage of people gambling with legal providers) is stable: approximately 94% gamble exclusively legally. The channeling in terms of BSR (the amount of total gambled money going to illegal providers) has shown a slight downward trend that continued in the first half of 2025: from 51% at the end of 2024 to 49% at the beginning of 2025. This downward trend may be explained by players shifting to illegal offerings due to the new player protection regulations, where these perceived restrictive rules do not apply. The Ksa considers this a worrying development, as players in the illegal market are much less well protected.

 

Source: kansspelautoriteit.nl

The post KSA: Monitoring report autumn 2025: turnaround in market development, concerns about illegal share appeared first on European Gaming Industry News.

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