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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.

BetterGambling

BetterGambling Exclusive Report: 800+ UK Casino Operators Face Closure as 2026 Regulations Trigger Industry Apocalypse

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BetterGambling, the UK’s independent gambling industry think tank, released its comprehensive Market Intelligence Report, indicating over 800 casino operators will be forced out of the UK market by 2027, the largest industry slump in British gambling history.

The study, authored by BetterGambling’s stable of former casino bosses and regulatory experts, projects a precipitous 30-40% drop in authorised operators as the 2026 regulatory landscape renders continued operation economically non-viable for the low-to-midsized players.

“We are witnessing the greatest scale of change since the Gambling Act 2005. Our analysis proves that this is not just market consolidation – it’s a structural realignment of an industry that today supports 2,262 licensed operators as of March 2024,” said Diana Tunsu, Reviewer at BetterGambling.

Key findings from the BetterGambling report include:

• 680-900 operators anticipated to exit the market by the end of 2027 (30-40% of the current market)

• New casino launches will drop by 60-70% relative to 2024 levels

• White-label operations will see a 45-55% closure rate as a result of shifts in platform economics

• Stand-alone casinos will see 40-50% market consolidation as a result of compliance barriers

• Total first-year compliance investment of £800,000-2.8 million per operator.

The Compliance Investment Reality

BetterGambling’s in-depth analysis of operators reveals the true cash investment required for 2026 compliance. The regulatory fee alone will remove £100 million from the industry annually, and technology infrastructure upgrades will cost individual operators between £500,000 and £2 million.

“The economics are straightforward. Operators with GGY below £3 million per year are faced with a stark choice: spend significantly on compliance or consider strategic options including withdrawing from the market,” explained Diana Tunsu.

For more detailed analysis of the impact on different forms of casinos, see our in-depth UK Casino Reviews section.

White-Label Market Transformation

White-label casino businesses are recognized as being severely tested in this report, with 45-55% predicted to merge or close down. Of the estimated 350-450 current white-label businesses, BetterGambling predicts 200-300 will survive past 2027.

“White-label operators have a complex equation,” said the BetterGambling research team.

“They must navigate through the same compliance for independent operators when handling revenue-sharing arrangements with platform providers.”

The post BetterGambling Exclusive Report: 800+ UK Casino Operators Face Closure as 2026 Regulations Trigger Industry Apocalypse appeared first on European Gaming Industry News.

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Compliance Updates

UKGC Introduces New Deposit Limit Rules

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The UK Gambling Commission (UKGC) is going to implement new deposit limit rules to help customers manage their spending.

Operators are currently required to offer tools so customers can easily set personal budgets for gambling at registration or when they first deposit money into their gambling account. To increase consumer empowerment the Commission is amending the rules to provide further consistency and clarity for customers when setting financial limits. These changes focus on how these limits are defined and communicated to customers.

From 30 June 2026 all online operators must provide customers with the opportunity to set a “deposit limit” which is based solely on the amount a customer pays into their account over a set duration. To avoid confusion, only this form of limit may be called a “deposit limit”.

In addition, gambling businesses will also be able to offer different limits, such as loss limits or limits where withdrawals are also taken into account.

The improvements to the rules are coming into effect in stages, and a key milestone is the set of previously announced changes which will come into effect on 31 October 2025 and require all gambling businesses to:

• prompt their customers to set a financial limit before they make their first deposit and make it easy for them to review and alter their limit

• remind consumers every six months to review their account and transaction information to help customers maintain control of their gambling spend

• offer financial limits using free text at an account level to help customers set meaningful limits

• provide financial limit setting facilities via a link on the homepage and deposit pages which are clearly visible and accessible, with the number of clicks to reach these facilities minimalised

• action all customer requests to decrease a financial limit immediately.

Helen Rhodes, Commission Director of Major Policy Projects, said: “Our work will help empower consumers to have greater awareness and control over their gambling. These further changes will also bring consistency and clarity for those consumers choosing to set deposit limits, while still supporting gambling businesses to offer customer choice for different forms of limits.”

The post UKGC Introduces New Deposit Limit Rules appeared first on European Gaming Industry News.

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Compliance Updates

MGA Introduces Self-Assessment Tool to Help Individuals Assess Gambling Habits

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As part of its ongoing commitment to player protection, the Malta Gaming Authority (MGA) has announced the launch of an online Self-Assessment Tool, available in both English and Maltese, designed to help individuals reflect on their gambling habits and behaviour.

Developed in close collaboration with several key local organisations – namely Sedqa, Caritas Malta, the OASI Foundation and the Responsible Gaming Foundation – the tool is completely anonymous, free to use and accessible to all.

Rooted in the Problem Gambling Severity Index – a widely recognised, evidence-based screening tool – the questionnaire comprises nine straightforward questions. These aim to assess the extent of an individual’s gambling behaviour while also considering broader social and environmental influences.

The tool encourages self-reflection in an accessible way, helping players consider whether they may benefit from reaching out for professional guidance. Should a user’s results indicate the need for further support, they will be directed to one of the participating organisations, each of which serves as a trusted point of contact for advice and care. Information is also available on safer gambling tools, such as setting limits or using global bet-blocking tools.

This initiative represents a collaborative, people-first approach to player protection, working alongside local entities in Malta and Gozo to ensure that anyone experiencing gambling-related harm is not only informed but also supported.

The MGA encourages players to use the tool regularly as a way to monitor changes in their gambling behaviour over time and stay mindful of any change that may occur.

The post MGA Introduces Self-Assessment Tool to Help Individuals Assess Gambling Habits appeared first on European Gaming Industry News.

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