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.
MGM Yonkers Inc., a subsidiary of MGM Resorts International, submitted its commercial casino license application to the New York Gaming Commission and the Gaming Facility Location Board, with a $2.3 billion proposal to transform its historic Empire City Casino site into a commercial casino and entertainment destination. The development plans have been thoughtfully curated to achieve the maximum benefits for the State of New York, City of Yonkers and surrounding counties, while also meeting the needs of the local community.
MGM Yonkers’ plans include the full renovation and expansion of Empire City Casino’s existing gaming areas, an expansive high-limit lounge and the addition of a state-of-the-art BetMGM Sportsbook offering retail sports betting. The plan also envisions the addition of a 5000 person maximum capacity entertainment venue and accompanying meeting space which will welcome a variety of A-list and local performances with the design flexibility to accommodate special events, local graduations, and other community needs.
Additionally, three new full-service restaurants and the renovation of existing food and beverage venues will provide high-concept dining options for guests. A parking garage with solar energy arrays and electric vehicle parking spaces are among features that demonstrate MGM Resorts’ strong commitment to sustainability. If MGM Yonkers is awarded a commercial casino license, it anticipates completing all project elements by mid-2029.
“Empire City Casino and Yonkers Raceway have anchored the entertainment and tourism culture in downstate New York for more than a century. Achieving a full casino license will ensure this site will continue to be a cultural and economic force for generations to come,” said Bill Hornbuckle, President and CEO of MGM Resorts International.
The post MGM Yonkers Submits Commercial Casino License Application in New York appeared first on Gaming and Gambling Industry in the Americas.
The Netherlands Gaming Authority (KSA) has issued two warnings to Optdeck for untargeted advertising and offering autoplay. Optdeck offers games of chance in the Netherlands under the brand name Unibet.
Unibet is a sponsor of the cycling team Unibet Tietema Rockets. Part of this sponsorship is a coach with the Unibet logo on it. This coach was not only used in the Netherlands to transport the sports team but also for other purposes. This violates the ban on non-targeted advertising.
The KSA also received a signal about a form of autoplay in a game offered by Unibet. The BonusBuy function, where players can automatically continue playing with purchased bonuses without having to start a new game, is prohibited because it encourages excessive gaming.
Optdeck said it was not aware that the bus was also used for other transport and that monitoring various sponsorship agreements can be complex. The cycling team has been asked to stop using the bus immediately, and the bus and team vehicles will be provided with modified stickers without the Unibet logo. The KSA has indicated that it is always the provider’s responsibility to guarantee that sponsorship agreements comply with the laws and regulations. In addition, the coach in this form will no longer be allowed on the road as of 1 July 2025, because that is also when the ban on sports sponsorship comes into effect.
The BonusBuy violation was also a third-party error. After the game went live, this function was incorrectly activated by the supplier. The function was only available for two hours, and players who suffered losses during those two hours were compensated. In addition, measures have been taken to prevent such errors from being made in the future.
The KSA emphasised that the provider itself is responsible for correctly following laws and regulations, even if there is a collaboration with third parties. Because both violations were stopped immediately as soon as they were noticed, the regulator has left its intervention at a warning for now. If Optdeck makes another mistake in the future, the KSA said it may impose stricter sanctions.
The post KSA Issues Warnings to Optdeck Over advertising and Autoplay Violations appeared first on European Gaming Industry News.
The GGL has published its 2024 Activity Report, which reviews key developments and achievements of the past year. The report explains the approach to combating illegal gambling as well as the activities related to the supervision of legal gambling providers. A key component of the report is also an analysis of market developments in the German gambling market.
Last year, the GGL processed 230 permit and amendment applications and supervised 141 providers. The authority faced a variety of regulatory, legal and supervisory challenges. Major events such as the UEFA European Football Championship and the Olympic Games, in particular, resulted in increased advertising and betting activities, necessitating increased monitoring.
A milestone in 2024 was the court approval of the “Markers of Harm” developed by the GGL. These indicators were developed for monitoring increased deposit limits and were first used in 2024. They serve as an early detection of problematic gambling behaviour. The Mainz Administrative Court confirmed their legal admissibility. The GGL sees this as an important step towards uniform player protection standards.
In 2024, the GGL successfully took action against illegal offerings and was able to make the offerings of numerous illegal providers inaccessible to players in Germany. A total of 231 prohibition proceedings were initiated and over 1700 websites were reviewed. Approximately 450 illegal gambling sites were no longer accessible from Germany due to prohibition orders, and another 657 were no longer accessible due to geo-blocking based on the Digital Services Act (DSA). Payment blocking made deposits and withdrawals for illegal offerings more difficult.
Another success was the adjustment of Google’s advertising guidelines at the initiative of the GGL. Since September 2024, only authorized providers in Germany have been allowed to advertise via Google Ads. This significantly reduced the visibility of illegal offers.
“Our measures are having an impact. Nevertheless, combating illegal offerings remains challenging and requires perseverance and close cooperation with national and international partners,” said Ronald Benter, CEO of GGL.
According to GGL estimates, illegal online gambling accounts for approximately 25% of the total online gambling market.
The legal German gambling market (online and land-based) generated gross gaming revenue (equivalent to players’ losses) of approximately €14.4 billion in 2024—an increase of approximately 5% over the previous year. Tax and levy revenues from gambling amounted to approximately €7 billion.
The providers regulated by the GGL generated approximately four billion euros, which corresponds to a 28% share of the total permitted market.
In the illegal market, the GGL registered 858 German-language gambling websites operated by 212 operators without a license. The GGL estimates that the illegal German-language websites it recorded represent a market volume of between €500 and €600 million. This corresponds to approximately 3% to 4% of the entire legal market (terrestrial and online) and approximately 25% of the legal market for dangerous online gambling, such as virtual slot machines or sports betting.
In 2025, the GGL expects further groundbreaking court rulings on its measures, thus providing even greater legal certainty in its approach. The authority will continue to support the evaluation of the 2021 State Treaty on Gambling and, among other things, further expand advertising monitoring. The further development of the use of safe servers is intended to further improve oversight of the legal gambling market and enable more precise monitoring. A particular focus is on intensive cooperation with national and international authorities to further effectively curb the illegal gambling market. This will target not only the providers themselves, but also technical service providers, advertising partners, and other supporting actors.
Ronald Benter said: “Our stated goal is to make the business model of illegal providers unattractive through a comprehensive package of measures. Combating illegal offerings remains a long-term process that requires strategic action, decisive action, and close interagency cooperation.”
The post GGL Publishes its 2024 Activity Report appeared first on European Gaming Industry News.
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