Compliance Updates
Spillemyndigheden Calls Attention to FATF’s Updated Lists of High-risk Jurisdictions
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 are Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, the Ivory Coast, Croatia, DR Congo, Haiti, Kenya, Lebanon, Mali, Monaco, Mozambique, Namibia, Nigeria, the Philippines, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam and Yemen.
Jurisdictions listed on the Black List are 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.
Africa
South Africa: Tribunal Grants Lottoland Interim Relief – Orders Google to Grant Lottoland Access to its Advertising Platform
The Competition Tribunal (“Tribunal”) has issued an interim order directing Google Ireland Ltd and Google South Africa (Pty) Ltd (collectively, “Google”) to permit Lottoland South Africa (Pty) Ltd (“Lottoland”) to access its advertising services known as “Google Ads”, for so long as Google permits any firm in South Africa to utilise Google’s Ads Services to advertise fixed-odds betting on the outcome of lotteries. The Tribunal’s order applies for a period of six months from its date, or the conclusion of a hearing into the prohibited practices alleged by Lottoland, whichever is the earlier.
This platform enables advertisers to display ads to users who utilise Google search, with Google Ireland acting as the service provider for Google Ads in South Africa.
The Tribunal’s order follows an interim relief application by Lottoland, a licensed bookmaker, which, inter alia, offers fixed-odds bets on the outcome of various lotteries around the world, including the South African national lottery, sporting events and other betting contingencies. Lottoland competes with other licensed bookmakers in South Africa such as Hollywood Bets, World Sports Betting, Betway, Betfred (which owns Lottostar) and Netbet (which trades as Sportingbet).
In summary, Lottoland alleged that Google terminated its access to Google Ads without justification while allowing access to its competitors, causing it financial harm and distorting competition in the market that Lottoland operates in, to the detriment of consumers.
Google contended that Lottoland’s offering of fixed-odds bets on the outcome of the national lottery in South Africa contravenes sections 57(1) and 57(2)(g) of the Lotteries Act. It submitted that in terms of its online advertising policies, which are designed to protect users, restrictions are placed on the promotion of certain gambling activities. Of particular relevance, the promotion of lotteries is limited to state-licensed entities and that this restriction is in place to ensure compliance with the provisions of the Lotteries Act.
Reasons for Decision
A non-confidential version of the Tribunal’s reasons will be published in due course once any confidentiality claims in relation to the reasons have been finalised with the parties involved. In deciding the matter, the Tribunal considered the following three factors holistically, balancing each factor against the other to determine what is reasonable and just:
• Evidence relating to the alleged prohibited practice;
• The need to prevent serious or irreparable damage to the applicant (Lottoland); and
• The balance of convenience.
Compliance Updates
IAGR confirms new Board members
The International Association of Gaming Regulators (IAGR) has announced the appointment of four new trustees to its Board, each bringing unique expertise and leadership to strengthen IAGR’s global regulatory efforts:
- Anders Dorph, Danish Gambling Authority (Europe)
- Peter Kesitilwe Emolemo, Gambling Authority of Botswana (Africa)
- Kevin Mullally, General Commercial Gaming Regulatory Authority (Asia/Oceania)
- Louis Rogacki, New Jersey Division of Gaming Enforcement (North America)
IAGR President Ben Haden said, ‘I’m delighted to welcome our four new trustees to the IAGR Board. Their diverse expertise and leadership across different jurisdictions will bring fresh perspectives to our work, further strengthening our global approach to gaming regulation.
‘I look forward to collaborating with Peter, Louis, Kevin and Anders as we continue to foster innovation and drive forward effective, responsible regulation for the benefit of the global gaming community.
‘We also extend a big thank you to Trude Høgseth Felde and Mabutho Zwane for their dedicated service as they complete their terms on the Board, and I’m pleased to announce that Jason Lane will continue for another term as a Trustee.’
As a leading forum for gaming regulators worldwide, IAGR enables members to meet, share information, discuss legislative developments, exchange views and learn best practices in gaming regulation.
In recent news, IAGR has also confirmed that its 2025 annual conference will be held in Toronto, Canada, from 20 to 23 October 2025, with registrations opening in early 2025.
Compliance Updates
MGA Issues First ESG Code Approval Seals to Licensees
The Malta Gaming Authority (MGA) has awarded its first-ever ESG (Environmental, Social and Governance) Code Approval Seals to licensees in the online gaming sector, marking a milestone in the Authority’s commitment to promoting responsible and sustainable industry practices.
This initiative follows the launch of the voluntary ESG Code of Good Practice last year, which invited licensees to submit their ESG disclosure returns. The Code, which covers 19 topics categorised under Environmental, Social and Governance pillars, offers a strategic roadmap for online gaming companies to streamline their reporting efforts.
Following the first annual reporting cycle, 14 gaming operators have been awarded the ESG Code Approval Seal. The Code supports two levels of reporting: Tier 1, which establishes foundational ESG standards, and Tier 2, which represents a more aspirational approach.
Seals are valid for one year, with flexibility for renewal in the subsequent reporting period, allowing operators to advance or adapt their reporting tier year by year.
“We believe this initiative will significantly enhance the industry’s reputation and sustainability credentials,” MGA CEO Charles Mizzi said.
“By integrating ESG considerations into their operations, gaming companies not only contribute to the wellbeing of society and the environment but also strengthen the trust and confidence that consumers, investors, and regulators have in the industry. This initiative sends a clear message: sustainability, in the broadest sense of the word, is integral to the future of the gaming sector.”
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