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.
Australia
VGCCC Fines Werribee RSL for Self-exclusion Failures

The Victorian Gambling and Casino Control Commission (VGCCC) has fined the Werribee RSL $30,000 for failing to prevent 2 self-excluded customers from gambling.
VGCCC CEO Suzy Neilan said: “This is the first time the VGCCC has taken disciplinary action against a club or hotel for self-exclusion breaches.
“Self-exclusion programs empower people to manage their gambling by registering to be temporarily or permanently blocked from entering gambling areas of clubs, pubs and casinos.
“By failing to respect a person’s decision to self-exclude, a venue may put customers who have decided to take a break from gambling, or quit altogether, at risk of experiencing gambling harm.”
In January 2024, the VGCCC received an anonymous tip-off that a self-excluded person entered the Werribee RSL gaming room and used the poker machines. The venue self-reported a second breach in May 2024, after realising a different customer had gambled at the venue on at least 4 occasions between February and May 2024.
Ms Neilan said: “Taking disciplinary action is the last resort. We would prefer venues take their harm minimisation responsibilities seriously by complying with their legal obligations, including through the effective implementation of tools like self-exclusion.
“Venues and their staff are the last line of defence for self-excluded customers, who should be able to trust that their decision to self-exclude will be respected. They must have the appropriate controls in place to prevent self-excluded people from entering gaming rooms.”
The VGCCC acknowledged that Werribee RSL cooperated with the investigations and has since taken steps to strengthen its procedures. These include improved and regular staff training, daily audits of the self-exclusion register and greater use of technology to identify self-excluded customers who attempt to enter the gaming room.
This remedial action was taken into consideration in determining the amount of the fine.
The post VGCCC Fines Werribee RSL for Self-exclusion Failures appeared first on European Gaming Industry News.
Compliance Updates
Konami Gaming Awarded Gaming-related Vendor License in the UAE

Konami Gaming Inc. announced successful completion of Gaming-related Vendor Licensing in the United Arab Emirates (UAE), a key emerging market for commercial gaming. Konami Gaming is among the first in the industry to be awarded a Gaming-Related Vendor License by the General Commercial Gaming Regulatory Authority (GCGRA), an independent entity of the UAE Federal Government with exclusive jurisdiction to regulate, license, and supervise all UAE commercial gaming activities. A leading global provider of casino games and casino management systems, Konami has been awarded official license to serve the UAE’s developing gaming market with its award-winning products and services.
“Since Konami Gaming’s inception, our global growth has been achieved with an unwavering commitment to compliance. As the United Arab Emirates expands its economy to the regulated commercial gaming space, Konami is dedicated to supporting this market with the same integrity, innovation, and excellence we bring to all 431 gaming jurisdictions we serve worldwide,” said Tom Jingoli, president & chief operating officer at Konami Gaming.
For a quarter century, casino players have enjoyed Konami Gaming’s slot machines for the Class III gaming space, in which game outcomes are determined by random number generators (RNG). The company has since expanded its world-famous casino entertainment to online gaming and a variety of central determination market sectors. Additionally, Konami Gaming has spent over 20 years delivering its industry-leading SYNKROS casino management system to some of the largest and most diverse gaming destinations on earth, with ultra-reliable 99.99% uptime.
The post Konami Gaming Awarded Gaming-related Vendor License in the UAE appeared first on European Gaming Industry News.
Australia
ACMA: ReadyBet Breaches Gambling Self-exclusion Rules

The Australian Communications and Media Authority (ACMA) has issued ReadyBet with a remedial direction after the company marketed to customers who had registered with BetStop – the National Self-Exclusion Register (NSER).
An ACMA investigation found ReadyBet sent 273 texts and push notifications from its mobile app to self-excluded individuals.
Separately, the company also failed to promote the NSER in 2342 push notifications despite it being mandatory to promote BetStop in any marketing electronic messages.
The ACMA issued the remedial direction so that ReadyBet takes action to prevent it breaching the rules in the future.
Under the remedial direction, ReadyBet must commission an independent review of its marketing systems, including its use of third-party suppliers.
ReadyBet must also engage a provider to deliver training to its staff to avoid messages being sent to self-excluded individuals.
The ACMA may seek civil penalties if ReadyBet does not comply with the remedial direction.
The post ACMA: ReadyBet Breaches Gambling Self-exclusion Rules appeared first on European Gaming Industry News.
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