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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.

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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.

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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.

 

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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.

 

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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

Danish Gambling Authority Updates Requirements for Reporting Game Data

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The Danish Gambling Authority (DGA) has updated the requirements for reporting game data.

Interested parties can comment on the update before the final version is issued. Comments must be sent to the DGA no later than Monday the 10th of June 2024. Comments must be submitted by using the contact form.

The DGA expects the updated requirements for reporting game data to come into force in 2025. The final date has not been determined. A possible transition period will be described in connection with the issuing of the updated requirements for reporting game data.

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Changes

Several linguistic adjustments have been made and some guidance texts have been added/adjusted. In addition to this, the following significant changes and additions should be mentioned:

  • Addition of a requirement that bets on fixed odds must be reported as independent transactions
  • Addition of requirements for reporting on odds for betting
  • Added requirement for reporting event information incl. list with country codes and sports
  • Added requirements for reporting odds on bets as well as specific requirements for reporting partially closed bets and Spreadbetting
  • Clarifying the handling of reporting for the betting exchange/BetExchange
  • Exception where SpillerInformationIdentifikation does not have to be reported for land-based betting has been removed after the introduction of the requirement for Player ID
  • Adding requirements for reporting RNG used for Virtual Fixed Odds
  • Adding a requirement that a casino session cannot be interrupted in the middle of a move, as well as a description of how “a move” is defined
  • Clarification of different poker types and how they are reported
  • Adding requirements to win lists in poker tournaments and manager games
  • Clarification of downscaling of pool games
  • Adding new requirements for providing test data for Jackpots
  • Clarifying the handling of changes to reported data. Including specific clarification of the distinction between changes to the game result and correction of error reporting.

The post Danish Gambling Authority Updates Requirements for Reporting Game Data appeared first on European Gaming Industry News.

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Compliance Updates

CT Gaming Obtains New Certification for Diamond King 3 in Romania

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CT Gaming has announced that its exceptional multigame, Diamond King 3, has been certified under the new regulations in the Romanian market.

“With the introduction of new technical regulations in Romania, we had to adapt our practices and obtain new product certifications. This certification represents a significant milestone, further solidifying CT Gaming’s presence in the Romanian market. Thanks to the work of our outstanding team, we were able to secure the necessary measures to ensure our clients and distributors can operate without any issues,” said Robert Stancu, Sales Manager at CT Gaming, Romania.

Diamond King 3 is the company’s premier multigame, showcasing CT Gaming’s commitment to delivering an exceptional gaming experience by combining classic titles with new releases. The multigame features 50 captivating games, including the legendary Mega Jack trio—Aztec Gold, Slot-O-Pol Deluxe and Champagne 20— which is now better than ever. Additionally, 20 games are linked to the exciting 3-level Diamond Tree jackpot. This combination offers players a diverse and thrilling gaming experience, with the potential for both small and large winnings.

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Robert Stancu added: “The unique blend of iconic titles, innovative themes, and jackpot features are all designed to create memorable experiences for players and contribute to our customers’ success. The inclusion of ‘Give Me 5 Clovers’ adds a fresh and exciting dimension to the multigame, and we are confident that players will embrace the diverse gaming experience that Diamond King 3 offers.”

The post CT Gaming Obtains New Certification for Diamond King 3 in Romania appeared first on European Gaming Industry News.

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Compliance Updates

West Ham’s Lucas Paqueta Charged with Betting Breaches

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West Ham United’s Lucas Paqueta has been charged with misconduct in relation to alleged breaches of FA Rules E5 and F3.

The player has been charged with four breaches of FA Rule E5.1 in relation to his conduct in the club’s Premier League fixtures against Leicester City on 12 November 2022; Aston Villa on 12 March 2023; Leeds United on 21 May 2023; and AFC Bournemouth on 12 August 2023.

It is alleged that he directly sought to influence the progress, conduct, or any other aspect of, or occurrence in these matches by intentionally seeking to receive a card from the referee for the improper purpose of affecting the betting market in order for one or more persons to profit from betting.

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Lucas Paqueta has also been charged with two breaches of FA Rule F3 in respect of alleged failures to comply pursuant to FA Rule F2. The player has until 03 June 2024 to provide a response to these charges subject to any request for an extension to this deadline.

The post West Ham’s Lucas Paqueta Charged with Betting Breaches appeared first on European Gaming Industry News.

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