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.
The post DGA: Three Orders and One Reprimand Issued to Mr. Green Limited 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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