Compliance Updates
DGA: Three orders and two reprimands to Skill on Net Ltd for breach of the Anti-Money Laundering Act
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.
The post DGA: Three orders and two reprimands to Skill on Net Ltd for breach of the Anti-Money Laundering Act appeared first on European Gaming Industry News.
Asia
WorldMatch Certifies Games for the Philippines
WorldMatch has announced the release of the first batch of its certified games for the Philippines market. This significant milestone marks a crucial step in the company’s global expansion strategy and commitment to providing high-quality gaming experiences to Filipino players.
The initial batch, comprising carefully selected games certified to meet the regulatory standards of the Philippines, promises to offer a wide variety of entertainment options for players in the country. From classics to modern titles, each game has been designed to deliver an engaging and enjoyable experience for users.
“This is an exciting moment for us. We are thrilled to bring our expertise and innovation to the Philippines market and collaborate with brand new partners to deliver extraordinary gaming experiences to local players,” said Xhuljana Demerxhiu, Head of Sales at WorldMatch.
The post WorldMatch Certifies Games for the Philippines appeared first on European Gaming Industry News.
Compliance Updates
NIGC Announces Acting Chair
The National Indian Gaming Commission announced the President’s appointment of Associate Commissioner Sharon M. Avery as Acting Chair of the Agency, effective May 15, 2024. Secretary of the Interior Deb Haaland recently appointed Avery to a three-year term as Associate Commissioner, effective May 6, 2024. Avery will serve both as Associate Commissioner and Acting Chair until a presidentially appointed, Senate-confirmed Chair is in place.
As Acting Chair, Avery has the same statutory authority to lead the Agency and take official actions as a Senate-confirmed appointee.
“I am humbled the administration has entrusted me with the distinguished opportunity to serve as the NIGC Acting Chair. In this capacity, and to the best of my abilities, I will diligently execute my duties and responsibilities designated by the Indian Gaming Regulatory Act to continue the Agency’s regulatory oversight of tribal gaming facilities without disruption, until a permanent Chair has been confirmed,” said Avery.
Avery is an enrolled member of the Saginaw Chippewa Indian Tribe of Michigan. She has been with the NIGC for over four years where she has served as an Associate General Counsel in the NIGC Office of General Counsel. Before joining the NIGC, Avery served for more than 10 years in the legal department for the Saginaw Chippewa Indian Tribe of Michigan. Most recently, she served as the Tribe’s General Counsel for Tribal Operations.
Compliance Updates
Spillemyndigheden: Anti-Money Laundering- A report to the police must be followed up by a notification
Notifications to the Money Laundering Secretariat is one the most important sources of information on money laundering and financing of terrorism. A notification is information about a potentially criminal act, and it cannot be replaced by a report to the police.
Gambling operators are obligated to notify in accordance with section 26 of the AML Act. The obligation to notify means that gambling operators must immediately notify the Money Laundering Secretariat if they know of, suspect, or have reason to believe that a transaction, funds or an activity is or has been linked to money laundering or financing of terrorism.
Notifications are essential for the role of the Money Laundering Secretariat, as notifications can in themselves constitute a case. In addition, a notification about a suspicion can be part of a larger case of other suspicious matters.
Police reports cannot replace notifications
There are no exceptions to the obligation to notify even if you have reported the matter to the police. In case a gambling operator has reported a customer to the police, the gambling operator must also notify the Money Laundering Secretariat which is an authority independent from the police.
The post Spillemyndigheden: Anti-Money Laundering- A report to the police must be followed up by a notification appeared first on European Gaming Industry News.
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