DGA: Order and action brought against Unibet (Denmark) Limited for breach of the Anti-Money Laundering Act

On 10 December 2021, the Danish Gambling Authority has brought action against Unibet (Denmark) Limited for breaching the rules on customer due diligence of section 10(1), 11(1)(4) and 17(1), and the rules on the obligation to investigate of section 25(1) of the Anti-Money Laundering Act.

Concurrently, the Danish Gambling Authority has ordered Unibet to notify the Money Laundering Secretariat of a previous player with Unibet to correct an existing breach of the obligation to notify of section 26(1) of the Anti-Money Laundering Act. Unibet has been given a deadline of two weeks to make the report.

The action for failure to comply with the rules on customer due diligence and failure to comply with the obligation to investigate is brought against Unibet because Unibet has let a player deposit DKK 1.4 million to his account in the period from December 2016 to 2018 without having sufficient knowledge about whether or not the players funds originated from crime. This toke place despite the fact that Unibet had noted in March 2015 that the player, who at the time was inactive – must be monitored if he became active again.

In December 2018, Unibet requested that the player submit documentation for the origin of the funds. The documentation provided by the player confirmed the suspicion that the player gambled much more than he could finance via his income and assets. Despite this, Unibet let the player continue to deposit about DKK 1.8 million to his account during 2019 and up until April 2020, when his account was closed.

The order on notification is given because Unibet in the same case has omitted to notify the Money Laundering Secretariat, although they already in 2015 had a suspicion which was never dismissed. Since Unibet has not yet notified the Money Laundering Secretariat, the breach still exists and consequently, Unibet has received an order to correct the situation by making a report.