The Danish Gambling Authority Warns of Money Laundering Risks When Using Affiliates

The Danish Gambling Authority has become aware that money laundering can occur through affiliates who market for gambling operators. Gambling operators that use affiliates should therefore consider whether this gives rise to updating their risk assessment.

An affiliate is a marketing channel where a person or company makes money by marketing for, for example, a gambling operator. The general consumer protection and marketing rules and the Gambling Act’s rules on marketing and communication also apply to affiliates. An affiliate earns money from the agreement by, for example, attracting new customers via their own website or through their own social network to the gambling operator’s website with a link. The link is generated specifically for the affiliate. The affiliate receives payment for the referral (pay per click), or a certain percentage of the amount the new customer deposits into their account.

How criminals can exploit affiliate agreements with gambling operators

In affiliate agreements with an individual or a company, there is an inherent risk that a gambling operator will be misused for money laundering. Particularly organized criminal networks can exploit an affiliate agreement. Networks of organized criminals can refer a large number of people within their criminal network as customers using the link to a gambling operator. A larger amount of illegal funds can be deposited into customers’ gambling accounts, which will not initially look suspicious, as the amount is distributed among several people in the criminal’s network. The deposited funds can subsequently be paid out to customers, possibly after play-through from their gambling accounts. This approach will make it look like legitimate winnings from gambling, and at the same time the affiliate increases its profit by having brought more new customers to the gambling operator, who according to the affiliate agreement is usually paid per additional new customer.

Signs of money laundering through affiliates

The Danish Gambling Authority points out that gambling operators may risk being misused for money laundering through these affiliate agreements. It may indicate that a gambling operator is being misused for money laundering by its affiliate if a majority of the customers referred by the affiliate only use the gambling operator’s website once and then no longer use the gambling operator’s services. It may therefore be relevant to assess whether entering into an affiliate agreement gives rise to updating one’s risk assessment.