Compliance Updates
Danish Gambling Authority Issues Six Orders to Royal Casino Århus for AML Failures
On 14 June 2023, the Danish Gambling Authority Spillemyndigheden has given Royal Scandinavian Casino Århus I/S six orders for breaching the rules on risk assessment of section 7(1) of the AML Act (order a), business procedures of section 8(1) of the AML Act (order b), supervision of section 8(1) of the AML Act (order c), training material of section 8(6) of the AML Act (order d), performance of customer due diligence procedures of section 11 of the AML Act (order e) and performance of enhanced customer due diligence measures for guests from high risk third countries (order f).
Order a is given because Royal Scandinavian Casino Århus I/S has made an insufficient identification of customer types, including foreign PEPs and PEPs in international organisations and their family members and close associates. Moreover, identification and risk assessments have not been made of individuals subject to financial sanctions. When the risk assessment does not sufficiently describe the factors connected to their guests, the risk assessment does thereby not cover all areas of their business model.
Order a is also given because Royal Scandinavian Casino Århus I/S has made an insufficient identification and risk assessment of the use of cash as a means of payment. Given that an inclusion of mitigating initiatives has been done too early, a correct assessment of this factor has not been made, which is why the inherent risks are not stated correctly. Thus, the risk assessment does not cover all areas of their business model.
Order b is given because Royal Scandinavian Casino Århus I/S does not have sufficient written business procedures. The business procedures lack sufficient procedures for the performance of customer due diligence measures for high-risk customers, enhanced customer due diligence measures for PEPs and their family members and close associates and for the obligations to report.
Order c is given because Royal Scandinavian Casino Århus I/S has not complied with their own business procedures for the performance of internal controls of procedures for customer due diligence measures, procedures for investigation and registering, procedures for reporting and procedures for record-keeping.
Order d is given because Royal Scandinavian Casino Århus I/S does not have sufficient training material about enhanced customer due diligence measures for PEPs, prevention of financing of terrorism, and individuals subject to financial sanctions. The training material is, therefore, not sufficient to ensure that the employees have an adequate knowledge of the obligations of the AML Act in relation to Royal Scandinavian Casino Århus I/S as a business.
Order e is given because Royal Scandinavian Casino Århus I/S has not performed sufficient customer due diligence measures, as a customer had not been verified correctly in accordance with the requirements of section 11(2) of the AML Act.
Order f is given because Royal Scandinavian Casino Århus I/S has not performed sufficient customer due diligence measures for guests from high-risk third countries given that information about the origin of the funds and the source of the customer’s assets have not been procured in relation to the requirements of section 17(1)(3) of the AML Act.
The Danish Gambling Authority notes that the rules on risk assessment, business procedures, training material and customer due diligence measures are fundamental parts of the Anti-Money Laundering Act. As a rule, breaches of the rules lead to an order or a reprimand or in serious or repeated cases, they are reported to the police.
The orders cause an obligation to act for Royal Scandinavian Casino Århus I/S, since they must submit an updated risk assessment, updated business procedures, updated controls, updated training material and updated procedures for customer due diligence measures addressing the insufficiencies identified in the orders.
The Danish Gambling Authority has given Royal Scandinavian Casino Århus a deadline of three months to correct the matters concerning the orders a-f.
Compliance Updates
Finland’s Gambling Reform Is Official – What Happens Next?
The wait is over: The Finnish Parliament has officially approved the new gambling legislation. In a decisive plenary session, MPs voted 158 in favor to 9 opposed, with 32 abstaining. The text remained unchanged from the version presented in previous weeks, solidifying the framework for Finland’s transition from a monopoly to a licensed market.
With the political uncertainty resolved, the focus now shifts to implementation. For operators, this means the race to compliance—and market entry—has effectively begun.
The Confirmed Timeline

With the legislation passed, the roadmap to the market opening is now set. Operators must use the coming months to prepare for a rigorous licensing process.
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Early 2026: The application window is expected to open. The regulator will begin accepting and reviewing license applications.
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2026 (Throughout): The “preparatory year.” This period is dedicated to vetting applicants, ensuring technical compliance, and establishing the new supervisory authority.
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January 1, 2027: The regulated Finnish market officially opens. Licensed operators can go live with betting and online casino services.
Entering the Finnish Market with Nordic Legal
Navigating a new jurisdiction is complex, but it doesn’t have to be inefficient. With extensive experience advising on gaming licences across the Nordic markets, Nordic Legal brings a proven, practical approach to the Finnish process.
Efficiency Through Synergy If you already work with us in Denmark or Sweden, we ensure your Finnish licence application isn’t a “start from scratch” project. We build directly on our existing knowledge of your organisation and systems.
Your usual Nordic Legal contact will coordinate directly with our Helsinki team at no extra cost. This integrated approach saves you time and avoids the frustration of duplicating work you’ve already done for other Nordic licenses.
Our Approach We focus on smart compliance:
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Reusing documentation where regulations overlap.
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Anticipating regulatory questions before they are asked.
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Aligning requirements for technical standards and responsible gambling.
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Engaging constructively with the Finnish authority to ensure a smooth process.
The Finnish Licence Application Package
To support your entry, we offer a comprehensive package designed to handle the heavy lifting:
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Translation of all required documents.
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Guidance and completion of complex application forms.
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Full project management from start to submission.
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Direct communication with the Finnish regulator on your behalf.
Next Steps
The window for preparation is narrowing. Contact your usual Nordic Legal advisor today to discuss the new legislation or our Licence Application Package. Alternatively, reach out to us directly to secure your place in Finland’s upcoming regulated market.
The post Finland’s Gambling Reform Is Official – What Happens Next? appeared first on Gaming and Gambling Industry Newsroom.
Compliance Updates
Updated FATF Lists of High-risk Jurisdictions
Reading Time: < 1 minute
The Danish Gambling Authority has called attention to FATF’s (Financial Action Task Force) updated lists of high-risk jurisdictions: the Grey List (jurisdictions under increased monitoring) and Black List (call for actions). Among other things, gambling operators must include FATF’s lists of high-risk jurisdictions when risk assessing players.
Jurisdictions listed on the Grey List:
Algeria, Angola, Bolivia, Bulgaria, Cameroon, the Ivory Coast, DR Congo, Haiti, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands and Yemen.
Jurisdictions listed on the Black List:
Democratic People’s Republic of Korea, Iran and Myanmar
Gambling operators are required to conduct enhanced customer due diligence (EDD) pursuant to section 17(1) of the Danish AML Act, if a player is assessed to impose a higher risk of the gambling operator being misused for money laundering or terrorist financing.
Gambling operators shall conduct this risk assessment based on Annex 3 to the AML Act (high-risk factors) which includes the FATF high-risk country lists (the so called black list and grey list)
It is not required that gambling operators perform EDD if a country is listed on the FATF’s list. EDD are only a requirement for players from jurisdictions listed in the EU Regulation of High Risk Third Country list pursuant to. 17(2) of the AML Act.
The post Updated FATF Lists of High-risk Jurisdictions appeared first on European Gaming Industry News.
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Spillemyndigheden: New licence type coming soon: Bingo via walkie-talkie and local radio
Reading Time: 2 minutes
Soon it may be possible to play bingo via walkie-talkie and on local radios. A bill is currently being considered by the Danish Parliament to introduce a new type of licence for bingo via walkie-talkie and local radio. The Danish Gambling Authority expects the rules to come into force as early as 1 January 2026.
If the bill is passed, providers of walkie-talkie bingo and local radio will be able to apply for a licence from 1 January 2026. The Danish Gambling Authority will update this news article when the rules are finally adopted.
How to apply for a licence
If you want to offer bingo via walkie-talkie or radio, you need a licence from the Danish Gambling Authority. You can expect to apply as early as 1 January 2026.
When applying for a licence, you must use the form “Apply for a walkie-talkie or radio bingo licence” (no. 1-02). The form will be available on the page “revenue-restricted licenses”.
The application form will also be published in a digital version, but it will not be available on virk.dk until January.
The Danish Gambling Authority strives to process all applications as quickly as possible.
As an applicant, you will be assigned a contact person who can guide you through the legislation during the application process. The contact person will generally remain the same throughout the period of validity of your licence.
Report on the first year of offering games
Licences for radio and walkie-talkie bingo are regulated by the Gambling Act and the Executive Order on Online Casino. The legislation sets out a number of requirements for licensed gambling operators. Among other things, the licence holder must complete a report on the first year of offering gambling.
The report is prepared one year after the licence has been put into use and must be sent to the Danish Gambling Authority no later than 14 months after the date when the licence has been put into use.
The licence holder can fill out the report themselves.
The report must account for how the licence holder has provided gambling in accordance with the conditions of the licence and legislation during the past year.
The report template will be available on the Danish Gambling Authority’s website as form no. 1-04.
The post Spillemyndigheden: New licence type coming soon: Bingo via walkie-talkie and local radio appeared first on European Gaming Industry News.
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