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.
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.
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.
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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