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.
Australia
Roadmap for Gaming Reform report published
The Independent Panel brought together, for the first time, a mix of industry representatives, harm minimisation experts, police, experts in cybersecurity and privacy, academics, community organisations and a person with lived experience of gambling harm.
Specifically, the Independent Panel examined the feasibility and acceptance of implementing cashless gaming technologies in clubs and hotels in NSW to gain insights from the technology to inform the Roadmap report.
Independent Panel for Gaming Reform Chairperson Michael Foggo said the panel’s Executive Committee has put forward an ambitious roadmap for gaming reform for the government to consider.
“This has been challenging and complex work, and I thank each of the panel’s 16 members for their time, expertise and enthusiasm over the 16 months of the panel’s work, and for contributing their views to developing the recommendations,” Mr Foggo said.
“The trial of this new technology was an important step to better understand the benefits and challenges for its implementation, giving technology providers, venues, patrons and government insights on operational issues tested in the real world.
“The trial learnings, advice from experts, research and evidence have informed the recommendations and safeguards to manage gambling harm and money-laundering risks and inform reasonable implementation timeframes to minimise impacts on industry.
“The roadmap also includes recommendations to progress the government’s commitment to reduce the overall number of gaming machine entitlements in NSW, as well as removing unnecessary complexity and further streamlining existing gaming regulatory regimes.”
The Independent Panel provided the government with separate advice on issues including mandating facial recognition technology to identify self-excluded patrons, and the establishment of a statewide exclusion register with third party exclusions.
The Executive Committee noted that further work needs to be undertaken by the government in developing its preferred approach to gaming reform.
Compliance Updates
EGT obtained World Lottery Association Security Control Standard: 2020 Level 2 Certification
EGT is proud to announce that it is already a member of the World Lottery Association (WLA), having successfully attained certification under its security standard WLA Security Control Standard: 2020 (WLA-SCS:2020) Level 2. This standard defines the requirements for information and operational security, as well as ensuring the integrity of the activities in the lottery and sports betting industries.
The main subject of the certification is EGT’s VLT solutions. To receive this designation, the company completed a two-stage process. First, it covered the requirements of the international standard for information security management systems ISO/IEC 27001 at the end of 2023. After that, it met additional lottery-focused security requirements set by WLA.
Mr. Vladimir Dokov, CEO of EGT, commented: “This achievement recognizes EGT’s commitment to sustainable development. It reaffirms our position as a leader in information security and underscores our ongoing dedication to creating products that meet the criteria of international accrediting institutions.”
Compliance Updates
Thunderkick secures new Danish supplier licence
The licence extends Thunderkick’s Danish content provision to 2029
Independent slots studio Thunderkick has obtained a B2B licence from the Danish Gambling Authority (Spillemyndigheden).
The new licence is valid from 1st January and will enable Thunderkick to continue distributing its games to Danish operators through to 2029.
Thunderkick is among the first game suppliers to be granted the newly introduced licence, allowing the studio to maintain and grow its market presence in the coming year.
The Stockholm-based company currently offers its games across several major regulated European markets, and the extension of its commercial operations in Denmark highlights Thunderkick’s dedication to becoming a prominent provider of distinctive content on its home continent.
Wan Kim, Chief Compliance Officer at Thunderkick, said: “Thunderkick continually strives to amplify its position in Europe, partnering with leading operators across target markets to enhance brand visibility and increase our player base.
“Obtaining a B2B licence has been a focus since the Danish Gambling Authority announced the new regulations earlier this year, and our application’s success emphasises the quality of Thunderkick products and our unwavering commitment to adhering to consistently updating regulations.
“The licence will facilitate our continued growth in Denmark, where some of the country’s biggest operators offer our unique content to local players.”
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