Compliance Updates
DGA: Three orders and two reprimands to Skill on Net Ltd for breach of the Anti-Money Laundering Act
![Spillemyndigheden: Consultation on Updated Certification Programme for Betting and Online Casino](https://europeangaming.eu/portal/wp-content/uploads/2019/06/Spillemyndigheden-eg.jpg)
On April 3rd, 2024, the Danish Gambling Authority has issued three orders to Skill on Net Ltd (Skill on Net) for breaching the rules of the Anti-Money Laundering Act on risk assessment, procedures for internal control and documentation of implemented controls.
On April 3rd, 2024, the Danish Gambling Authority has also given Skill on Net two reprimands for breaching the rules on business procedures and the rules on whistleblower scheme in the Anti-Money Laundering Act.
The orders and reprimands are issued in connection with the Danish Gambling Authority’s inspection of Skill on Net’s material, which Skill on Net has prepared in order to comply with the Anti-Money Laundering Act.
Order for inadequate risk assessment
Order (a) has been issued because Skill on Net’s risk assessment is insufficient, as no separate risk assessment has been made of the individual identified risks associated with Skill on Net’s business model, including products and payment solutions, as well as the risk factors associated with these. Section 7(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must identify and assess the risk that the undertaking may be misused for money laundering or terrorist financing. It is the Danish Gambling Authority’s assessment that the risk assessment must include a separate assessment of the risk of the individual products and payment solutions, as well as a separate risk assessment of the risk factors associated with these. Thus, Skill on Net has not complied with the risk assessment obligation in section 7(1) of the Anti-Money Laundering Act.
Order for inadequate business processes
Order (b) has been issued because Skill on Nets’ written procedures do not describe how, when and by whom the internal controls are monitored to ensure that the internal controls are implemented. Section 8(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must have adequate written procedures, which must include internal controls. The requirement for internal control also means that checks must be carried out to ensure that the controls are implemented. Thus, Skill on Net has not sufficiently complied with the obligation to have procedures for internal control.
Order for lack of documentation for controls
Order (c) has been issued because Skill on Net has not documented that internal controls have been implemented. Section 8(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must document the checks carried out. Thereby, Skill on Net has not complied with the obligation under section 8(1) of the AML Act.
Reprimand for inadequate business processes
Reprimand (a) is given because Skill on Net’s business procedure for establishing customer relationships until October 16, 2023 was deficient, as there was a discrepancy between the business procedure and practice. Section 8(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must have adequate written procedures and that the procedures must describe how the areas are handled in practice. Thus, Skill on Net has not complied with the obligation to have sufficient written procedures for establishing customer relationships.
Reprimand (a) has been issued because Skill on Net’s business procedures up to 16 October 2023 did not take into account that customer due diligence procedures must be carried out at appropriate times, as required by section 10(1)(1)(1) of the Anti-Money Laundering Act. Thus, Skill on Net has not complied with the obligation to have sufficient written procedures for the implementation of customer due diligence procedures at appropriate times.
Reprimand (a) is also given because Skill on Net’s business procedure for politically exposed persons until 16 October 2023 was deficient, as PEP screening of customers who had not paid over a fixed defined amount was not performed on an ongoing basis. Section 18(1) of the Anti-Money Laundering Act states that undertakings subject to the Act must have procedures in place to determine whether the customer is a politically exposed person, close associate or close business partner of a politically exposed person. Reviewing whether an established customer has changed status to politically exposed person must include all customers. Thus, Skill on Net has not complied with the obligation to have sufficient written procedures for PEP screening.
Reprimand for inadequate whistleblower scheme
Reprimand (b) is given because Skill on Net’s whistleblower scheme until June 2023 did not sufficiently meet the requirement for anonymity, as reporting could only be done by e-mail. Section 35(1) of the Anti-Money Laundering Act states that undertakings subject to the Anti-Money Laundering Act must have a system where their employees can report violations or potential violations of anti-money laundering legislation via a special, independent and autonomous channel. It also states that reports must be able to be made anonymously. Thus, Skill on Net has not complied with the requirement of anonymity for whistleblowers.
The Danish Gambling Authority assesses that an inadequate risk assessment as well as inadequate business procedures and whistleblower scheme may have increased Skill on Net’s risk of being misused for money laundering. The purpose of the risk assessment is for the gambling operator to have a useful tool that provides an overview and understanding of where and to what extent the gambling operator is exposed to being misused for money laundering or terrorist financing and what measures are necessary to mitigate the risks. Business procedures must be a description of the activities that the gambling operator must perform to ensure compliance with legislation and other regulations and that the gambling operator’s policies and guidelines are followed. Adequate risk assessment, business procedures and a whistleblower scheme are fundamental to the Anti-Money Laundering Act, and the seriousness of the violation has therefore led to three orders and two reprimands.
Duty to act
The orders entail an obligation for Skill on Net to act. This means that Skill on Net must, within two months, submit a revised risk assessment, business procedures for the control of internal controls, and within six months submit documentation that internal controls have been implemented.
The reprimands do not entail any obligation for Skill on Net to act, as the violations no longer exist, as Skill on Net has subsequently revised its business procedures and whistleblower scheme.
Compliance Updates
Acquiring a Curacao Online Gaming License in 2024: Comprehensive Analysis of Financial & Procedural Aspects with Costs & Timelines Detailed
![](https://europeangaming.eu/portal/wp-content/uploads/2024/07/curacaduioapdj.jpg)
The “Acquiring a Curacao Online Gaming License, 2024: Comprehensive Analysis of Financial & Procedural Aspects with Costs & Timelines Detailed” report has been added to ResearchAndMarkets.com’s offering.
This report includes valuable insights into the financial and procedural aspects, including detailed information on costs and timelines associated with acquiring a Curacao license.
In 2023, Curacao introduced the “Landsverordening op de kansspelen” (Ordinance on Games of Chance) to modernize and regulate gambling legislation. Since March 2020, the Gambling Control Board (GCB) has been authorized to regulate offshore gambling games and oversee the issuance of Curacao licenses. As of 2023, there are 16 companies providing legal services for registration and licensing in the territory of Curacao. The license fee, as per GCB regulations, is 36,000 ANG or 19,800 USD, payable upon license issuance.
Research Timeline and Data Relevance
The research was conducted in two stages. The first stage, studying the regulator and Open Data Search, took place in December 2023. The second stage, writing the report and partially updating the data from the first stage, took place from the end of April to the end of May 2024.
Goals and Objectives
- Describe the information about the Curacao license and the issuing regulator.
- Describe the requirements and conditions for obtaining a Curacao license.
- Describe the costs and timelines for obtaining a Curacao license.
- Briefly study the market, find and suggest the following lists:
- Legal companies offering services for company registration and obtaining a Curacao license;
- Communication agents and integrators working with the Curacao license;
- Suppliers and vendors working with the Curacao license;
- Payment systems working with the Curacao license.
Key Topics Covered:
1. Goals and Objectives
2. Research Timeline and Data Relevance
- Document Markup
- Raw and Combined Data
- Terms & Glossary
3. General Information
- The Regulator
- Registration of Operators With Sublicense
- Application for an Online Gaming License
4. Requirements and Conditions for Obtaining a License
License Conditions
- General Prohibitions
- Safe and Secure Environment
- Equipment and Application Software
- Player Registration
- Payment Transactions
- Games
- Terms of Use
- Resolution of Complaints
- Administrative Responsibilities
- Publicly Available Information
- Reports
- Policies and Procedures
- Suspension and Revocation of License
- Additional Conditions
- Supervision
Recommendations or Minimum Requirements for the Business Plan
5. The Cost of the License
6. Decision Term and the Validity of the License
7. Application Method and Forms
8. Contact Information
9. Companies for Registration and Licensing
10. Integration Companies
11. Suppliers and Vendors
12. Payment Systems
13. META
14. Appendix: Terms & Glossary
For more information about this report visit researchandmarkets.com/r/izeo6g
Compliance Updates
Digitain Obtained Greek License
![Digitain Obtained Greek License](https://europeangaming.eu/portal/wp-content/uploads/2024/07/Digitain-Greek-License.png)
Digitain obtained the A1 Manufacturerâs License from the Hellenic Gaming Commission.
Digitain, a global leader in Sportsbook and iGaming solutions, has expanded its presence in European regulated market by obtaining a B2B license from the Hellenic Gaming Commission.
Iain Hutchison, Chief Revenue Officer of Digitain, said: “We are delighted that we have attained our B2B license from the Hellenic Gaming Commission. Digitain continues to expand across multiple regulated jurisdictions, and the Greek license is a further example of our vision and that of our teams’ commitment to regulatory compliance and the exemplary standards of our platform technology and focus as a company. We look forward to having our award-winning sportsbook and Centrivo platform and much more available within the Greek market as one of continental Europe’s largest and growing regulated markets.”
Compliance Updates
Hard Rock Casino NL turns to BetComply for Netherlands launch
![Hard Rock Casino NL turns to BetComply for Netherlands launch](https://europeangaming.eu/portal/wp-content/uploads/2024/07/11-3-e1721908582174.jpg)
BetComply, iGamingâs most trusted technical and regulatory compliance firm, has partnered with iCasino, securing a Dutch licence for their recently-launched Hard Rock Casino brand.
HardRockCasino.nl operated by iCasino b.v. under a brand licence agreement announced its Netherlands launch at the start of July, having worked closely with BetComply to secure a licence from the Dutch regulator de Kansspelautoriteit (KSA) in May.
The brand will continue to work with BetComply to ensure on-going compliance within the Netherlands framework.
iCasino CEO Paul Strikers said: âItâs hugely exciting to bring such a globally renowned brand to the Dutch market for the first time. We understood early on in the process that operator compliance needed to be one of our highest priorities, and thatâs why we enlisted the help of BetComply and its unparalleled expertise in the Netherlands. We thank Mike and the team for their tireless and rigorous support on our successful licence application, and look forward to building upon this partnership in the future; the first step being the application for a sports betting licence.â
BetComply Chief Compliance Officer Mike de Graaff added: âThe Netherlands market has attracted some huge international brands over recent months, underlining the opportunities on offer for those who build a deep understanding of their regulatory obligations. Weâve already helped more than a third of all licence holders in the country, and with the KSA taking a proactive approach across all elements of regulation, weâll continue to support our partners, including iCasino, as market conditions evolve.â
With recent high-profile reports of serious misconduct within the iGaming compliance space, it has never been more important to pick a trusted and reliable partner, both in the Netherlands and elsewhere.
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