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.
Amidst an evolving economic landscape, gaming executives report a positive outlook on future industry business conditions while remaining satisfied with the current business environment, according to the American Gaming Association’s (AGA) Gaming Industry Outlook.
Nearly all gaming executives surveyed characterized the current business environment as good (44%) or satisfactory (50%), mirroring similar sentiment from Q3 2023. Meanwhile, executives are more optimistic about future conditions, with 32 percent of CEOs expecting business conditions to improve over the next six months, up from 20 percent in Q3 2023.
“Gaming’s record-setting growth over the last three years has set a new standard for industry success,” said AGA President and CEO Bill Miller. “However, as we enter a period of market normalization, continued investment and innovation in offering world-class, responsible entertainment experiences will be required to maintain industry momentum.”
Gaming Executive Panel
Gaming executives have become more positive in their views that overall balance sheet health will improve over the next 6 months (42% net positive), but they expect the pace of revenue growth (13% net negative) and new hiring (22% net negative) to slow. These expectations for decelerating growth have influenced expectations for increases in capital investment and gaming units in operation, with smaller net positive sentiments than before.
- In contrast to past Outlooks, gaming equipment suppliers are slightly pessimistic about the sale of gaming units for replacement use and new or expansion use (both 13% net negative). However, they remain optimistic about the pace of capital investment (38% net positive).
- Half of operator CEOs expect capital investments in hotels over the next year to be higher than normal, and compared to last fall, more also expect higher than normal levels of capital investment in meetings and conventions and table games (28%). Meanwhile, 44 percent of CEOs expect increases in food and beverage investment, down from 67 percent in Q3 2023.
These expectations are also informed by evolving macroeconomic challenges. Executives report that inflationary or interest rate concerns continue to be a major factor limiting operations (28%), but these have been overtaken by geo-political risk (34%) and uncertainty of the economic environment (34%) as the biggest limiting factors in the most recent Gaming Executive Panel.
Current Conditions Index
The Current Conditions Index of 102.8 for Q1 indicates solid annualized real economic growth in the industry of 2.8%. This includes gaming revenue, employment and employee wages and salaries. Notably, the Current Conditions Index shows gaming expanding faster than the overall U.S. economy which last week reported 1.6 percent GDP growth in Q1 2024.
Future Conditions Index
The Future Conditions Index stands at 102.2, indicating annualized industry economic activity, after controlling for underlying inflation, is expected to moderately increase over the next six months. This outlook reflects Oxford Economics’ forecast that the U.S. economy will slow during 2024 but avoid recession. Despite a projected economic slowdown, consumer survey results continue to indicate that more than one-third of adults expect to visit a casino during the next 12 months, consistent with prior quarter results.
About the Outlook
The AGA Gaming Industry Outlook is prepared biannually by Oxford Economics. It provides a timely measure of recent industry growth and future expectations. The Q1 2024 survey was conducted between March 28 – April 10, 2024. A total of 32 executives responded, including executives at the major international and domestic gaming companies, tribal gaming operators, single-unit casino operators, major gaming equipment suppliers, and major iGaming and/or sports betting operators.
PHOENIX – Bettors in Arizona wagered approximately $637.5 million on sports in February of 2024, according to a new report by the Arizona Department of Gaming. This represents an approximate 4.6% increase when compared to February of 2023.
The state collected approximately $2.8 million in privilege fees in the month. You can view the full February report on the ADG website: LINK.
North Carolina legislator intends to introduce legislation to ban college player prop bets, according to a staff member.
North Carolina State Representative Marcia Morey, D-Durham, a former Olympic swimmer, will submit a bill by the bill filing deadline on Thursday to ban these bets, Hannah Smith, Administrative Assistant, told Gambling.com on Monday.
The North Carolina Legislature began meeting in Raleigh on April 24 with the session set to end on July 31.
Recently, NCAA President Charlie Baker, a former Massachusetts governor, called upon states to ban college player prop bets, which is short for proposition bets. Baker said these bets, based on an athlete’s individual performance such as the over/under on the number of rebounds the player might record, could undermine the integrity of games and lead to harassment of players.
Former North Carolina Tar Heel star Armando Bacot is among athletes who have expressed concern about harassment. Bacot said he heard from fans angry that he didn’t get enough rebounds in an NCAA tournament game against Michigan State – a game the Tar Heels won.
College Prop Bets Allowed in Some States
Some states already ban these bets, while others including Louisiana, intend to impose a ban this summer before the college and pro football seasons begin.
In other states, the proposed ban has met with resistance.
During a recent interview on The Edge, Arkansas casino executive Carlton Saffa told Gambling.com a ban would drive bettors to unregulated offshore sportsbooks or illegal bookies. He said a better solution is to keep those bets legal in regulated markets where irregularities can be spotted.
“Sunshine is the best disinfectant,” Saffa, the Chief Marketing Officer for the Saracen Casino Resort in Pine Bluff, Arkansas, said.
College player prop bets remain legal in Arkansas.
In North Carolina, where statewide mobile sports betting became legal in March, State Representative Jason Saine, R-Lincoln, said in a story on the WNCN-TV website that a college player prop ban is ‘a solution in search of a problem’. If athletes are being harassed, he said, campus police should crack down on those making the threats and make an example of them. A ban won’t stop the problem, Saine said.
“If we ended (player prop bets) tomorrow, this kind of behavior would still continue with fanatical people,” Saine said. “Follow rules of society, you don’t threaten anybody, or you shouldn’t be. And, that’s kind of my take on it. I don’t think we need a whole new set of rules to pursue something like that.”
Morey, the lawmaker proposing the ban, said people are ‘forgetting about the individuals who are actually playing the game and having the pressure on them’.
“Let’s give them a break,” she said.
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