Compliance Updates
DGA: Three Orders and One Reprimand Issued to Mr. Green Limited for Breach of the Anti-Money Laundering Act
On April 10th, 2024, the Danish Gambling Authority has issued three orders to Mr. Green Limited for breaching the Anti-Money Laundering Act, on risk assessment, on procedures for internal controls and for failing to ensure that controls are carried out.
On April 10th, 2024, the Danish Gambling Authority has also given Mr. Green Limited a reprimand for breaching the rules on notification in the Anti-Money Laundering Act.
The reactions have been given in connection with the Danish Gambling Authority’s inspection of Mr. Green Limited’s materials that Mr. Green Limited has provided for compliance with the Anti-Money Laundering Act.
Order for insufficient risk assessment
Order (a) is issued because Mr. Green’s risk assessment is insufficient, as no separate risk assessment has been made of the individual identified risks associated with Mr. Green’s business model, including payment solutions, and the risk factors associated with it. It follows from section 7(1) of the Anti-Money Laundering Act that undertakings subject to the Act must identify and assess the risk that the undertaking may be misused for money laundering or terrorist financing. The Danish Gambling Authority’s assesses that the risk assessment must include a separate assessment of the risk of the individual payment solutions and delivery channels, as well as a separate risk assessment of the risk factors associated with these. Thus, Mr. Green did not comply with the risk assessment obligation.
Order for insufficient and lack of business procedures
Order (b) is issued because Mr. Green Limited does not have adequate procedures for internal controls, as these do not describe the interval at which controls should be performed. The order has also been given because Mr. Green Limited does not have written procedures on how to monitor that controls are carried out. It follows from section 8(1) of the Anti-Money Laundering Act that undertakings subject to the Act must have adequate written business procedures, which must include internal control. The business procedures should describe how the listed areas are handled in practice. The requirement for internal control also means that there must be controls of whether the controls are being carried out – in other words, that the controls are being checked. Mr. Green Limited has not sufficiently complied with the commitments on business procedures for controls.
Order for lack of documentation of controls
Order (c) is issued because Mr. Green Limited has not documented that controls have been carried out to verify that the internal controls have been performed. It follows from section 8(1) of the Anti-Money Laundering Act that undertakings subject to the Act must document the controls that have been carried out. Thus, Mr. Green Limited has not complied with the obligations to perform controls to ensure that the internal controls are performed.
Reprimand for not making an immediate notification
Reprimand (a) is given because Mr. Green Limited has in two cases not complied with the requirement for immediate notification to the Money Laundering Secretariat. According to section 26(1) of the Anti-Money Laundering Act, an undertaking must immediately notify the Money Laundering Secretariat if the undertaking knows, suspects or has reasonable grounds to suspect that a transaction, funds or activity is or has been related to money laundering or terrorist financing. Mr. Green has not complied with the notification obligations, as there has been no immediate notification.
Duty to act
The orders entail an obligation to act on the part of Mr. Green Limited. Mr. Green Limited must submit a revised risk assessment within June 10th, 2024.
Mr. Green must also within June 10th, 2024, submit a revised business procedure for internal controls and submit prepared business procedures for how the implementation of controls is monitored.
Mr. Green Limited must also submit documentation within October 10th, 2024, that it has been controlled that the controls have been carried out.
The reprimand does not entail any obligation to act on the part of Mr. Green Limited as the breach no longer exists.
The post DGA: Three Orders and One Reprimand Issued to Mr. Green Limited for Breach of the Anti-Money Laundering Act appeared first on European Gaming Industry News.
Betting and Gaming Council
BGC Responds to Gambling Commission’s Announcement on FRAs
The Betting and Gaming Council (BGC) has responded to the UK Gambling Commission’s decision to introduce Financial Risk Assessments (FRAs) in stages.
Grainne Hurst, Chief Executive of the Betting and Gaming Council, said:
“We are deeply disappointed and frustrated that the Gambling Commission has decided to press ahead with Financial Risk Assessments despite the significant concerns raised over the last 18 months by the BGC, operators, racing, parliamentarians and customers.
“The fact that the Gambling Commission has delayed implementation, raised thresholds and abandoned its original timetable is a clear recognition that the concerns raised by the BGC and others were well founded. Unfortunately, the central issues around reliability, consumer impact and the practical operation of these checks remain unresolved.
“The Commission has failed to address the fundamental issues identified during its own pilot. It has not demonstrated that the data underpinning these checks is accurate, reliable or consistent enough to support regulatory decisions affecting customers.
“The pilot exposed inconsistencies in the information returned by credit reference agencies, with the same customer potentially receiving different outcomes depending on the provider. Customers risk being wrongly identified as financially vulnerable based on a system that remains unproven. That is not a sound basis for regulatory intervention.
“The Commission has yet to publish a full evaluation of the pilot, so neither the industry nor the public has seen the evidence needed to justify introducing these checks.
“These checks cannot be described as genuinely frictionless if they produce unreliable outcomes, lead to unnecessary account restrictions or ultimately result in customers being asked to provide documents or open banking information.
“While the Commission has announced implementation groups, it has given no indication that they will resolve the outstanding questions around reliability, consumer impact and how the system will operate in practice.
“We support evidence-led, proportionate regulation that protects vulnerable people while allowing the 22.5 million adults in Britain who bet each month to do so safely. But until the Commission can demonstrate these checks are accurate, consistent and genuinely frictionless, our fundamental concerns remain, including the risk of driving customers towards the growing illegal gambling market.”
The post BGC Responds to Gambling Commission’s Announcement on FRAs appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
Compliance Updates
GRAI Signs Memorandum of Understanding with Danish Gambling Authority
The Gambling Regulatory Authority of Ireland has announced the signing of a Memorandum of Understanding with the Danish Gambling Authority, further strengthening collaboration between European gambling regulators.
The MOU reflects a continued commitment to closer cooperation on compliance, monitoring, and enforcement. It is designed to support more effective information sharing and coordination between jurisdictions that oversee many of the same operators and market practices.
A recent meeting between CEO of the Gambling Regulatory Authority of Ireland, Anne Marie Caulfield, and Director General of the Danish Gambling Authority, Anders Dorph, provided an opportunity to exchange perspectives on key regulatory challenges and to align approaches where possible, especially in a digital-first age where gambling regulation increasingly requires coordinated European responses to address cross-border risks.
Welcoming the agreement, CEO of the GRAI, Anne Marie Caulfield, said: “This Memorandum of Understanding with the Danish Gambling Authority is another vital milestone in strengthening cooperation between regulators operating in closely connected markets.
“Continued dialogue and collaboration between Ireland and Denmark will support more effective oversight and regulation, and we see this agreement as part of our continued efforts to deepen cooperation with regulatory partners across Europe.”
The post GRAI Signs Memorandum of Understanding with Danish Gambling Authority appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
Compliance Updates
ECA: EU Member States Miss Out on €22.9 Billion in Tax Revenue Due to Illegal Online Gambling
The European Casino Association (ECA) hosted a high-level roundtable in the European Parliament on tackling illegal online gambling. The event title still referred to the 2024 figure of €80 billion, the figure available when the roundtable was organised, but that number was overtaken at the event itself: the 2025 figures, released for the first time during the roundtable, showed that the illegal online gambling market aimed at EU consumers had reached €91.6 billion, an increase of around 14%. The title was therefore already outdated the moment the new numbers were presented. Drawn from the study commissioned by the ECA to Gambling Compliance International (GCI) and set out by ECA Chair Erwin van Lambaart, this rise deprived EU Member States of an estimated €22.9 billion in tax revenue.
A high-level roundtable in the European Parliament
The European Casino Association (ECA) organised a high-level roundtable discussion on illegal gambling in the European Parliament. Hosted by MEP Lukas Mandl, the gathering brought together EU lawmakers, the European Commission, the Anti-Money Laundering Authority (AMLA), Eurojust, the Joint Parliamentary Scrutiny Group (JPSG) on Europol, national gambling regulators and industry experts.
During the discussion, ECA Chair Erwin van Lambaart presented the 2025 figures from the impact study on illegal online gambling that the ECA commissions annually from Gambling Compliance International (GCI). Participants exchanged views under the Chatham House Rule on the growing scale of illegal online gambling, how it is currently tackled, and what more can be done at European level. They acknowledged the growing scale of the problem and called for stronger enforcement and closer cooperation to support a safe, well-regulated gambling environment.
The discussion is timely, coming shortly after the European Commission’s proposal to reform the mandate of Europol, a key institution in the fight against cross-border crime, including illegal gambling.
What the 2025 GCI figures show
The latest impact study, commissioned by the ECA to Gambling Compliance International (GCI), shows that the illegal online gambling market aimed at EU consumers reached €91.6 billion in 2025, an increase of around 14% on the previous year. This clear upward trend deprived EU Member States of an estimated €22.9 billion in tax revenue in 2025.
The figures also show that illegal operators now account for the majority of online gambling revenue in the EU-27, that more than 6200 illegal operators are actively targeting European consumers, and that the overwhelming majority of online gambling content Europeans are exposed to promotes illegal, unlicensed operators.
What is meant by “illegal gambling”
In the 27 Member States of the European Union, there is no grey market and no third category. A gambling operator is either legal, meaning it is licensed in the country where it serves its customers, or it is unlicensed and therefore illegal. When the ECA speaks of illegal gambling, it means operators serving European consumers without the licence that national law requires.
What sets legal and illegal operators apart
Legal, licensed operators abide by national and EU law, apply anti-money-laundering measures and cooperate closely with national and EU authorities. They protect vulnerable consumers, with particular care for young adults, through strict responsible-gambling programmes; they make significant tax contributions; and they support local development, tourism and jobs.
Illegal, unlicensed operators, by contrast, operate outside any licence and any regulatory or ethical standard. They fail to apply anti-money-laundering measures and can facilitate money laundering and the financing of crime. They ignore age and identity checks and actively target young and vulnerable players, using aggressive marketing, personalised bonuses and free plays to drive compulsive play. They pay no tax in the countries they target, and they mislead consumers, for example by using the logos of legitimate operators in advertising to commit fraud.
ECA Chair Erwin van Lambaart said: “The 2025 data from the GCI report leaves no room for doubt: illegal online gambling is a fast-growing, cross-border problem that puts players, especially young adults, at high risk, deprives societies of much-needed tax revenues, and undermines trust in the regulated market. Licensed casinos and their online businesses operate under strict rules and invest heavily in responsible gambling and anti-money-laundering measures. Yet illegal operators, often based outside the EU, can reach European consumers at the click of a button, without safeguards, without oversight and without contributing to our communities.”
“This is why we need strong political will and strengthened public-private cooperation that is aligned with this reality. By connecting national enforcement efforts, financial intelligence units and sector expertise, European institutions and agencies such as the European Commission, Europol and AMLA can help us turn data into action. If we fail to act now, the illegal online market will continue to grow at the expense of players, public finances and legitimate businesses.”
MEP Lukas Mandl said: “Illegal online gambling is not a niche issue, it is a serious cross-border threat that touches on consumer protection, organised crime and the integrity of our internal market. Europol is a crucial partner for Member States, but we must ensure that its mandate and resources allow it to fully support the fight against these illegitimate activities.”
“The evidence presented by the European Casino Association today show where cooperation is needed to do more. I will bring these insights into our parliamentary work and encourage colleagues cross-party to jointly go against the negative effects of illegal gambling from mental health issues to existential disasters of individuals and entire families, so that we can better protect citizens and make a clear difference between criminal activities and those operators who play by the rules.”
The post ECA: EU Member States Miss Out on €22.9 Billion in Tax Revenue Due to Illegal Online Gambling appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
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