Denmark’s iGaming sector is experiencing a shakeup with one of its popular brands. On April 20 2024, the Danish Gambling Authority served Mr Green Limited with three orders and one reprimand.

The three orders for deeming risk assessment insufficient, are a lack of procedures and a lack of documentation of controls.

This article explains the three orders and reprimanding further.

The Three Orders

Insufficient risk assessment

The point of reference for the order for insufficient risk assessment is based on section 7(1) of the Anti-Money Laundering Act. The Act prescribes that undertakings subject to it must identify and assess the risk that the undertaking may be misused for money laundering or terrorist financing.

According to the Danish Gambling Authority, the business must conduct a separate risk assessment for the risk posed by individual payment solutions and delivery channels. More so, it should include a separate risk assessment of the risk factors associated with them.

The Danish Gambling Authority said.

“The Danish Gambling Authority 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,” it added.

The order was issued to Mr Green because their risk assessment was insufficient since no separate assessment was performed for the individual-identified risks associated with Mr Green's business model, including payment solutions, and the associated risk factors.

Insufficient and lack of business procedures

The breach by Mr Green was based on section 8(1) of the Anti-Money Laundering Act. The law states that businesses must have adequate written business procedures, which must include internal control. The procedures should describe how the listed areas are handled in practice.

Internal control also means that there must be controls of whether the controls are being put into action i.e. that the controls are being checked.

Mr Green was served an order based on this due to insufficient and lack of business procedures specifically regarding controls.

Lack of documentation of controls

The final order is based on section 8(1) of the Anti-Money Laundering Act. It states that businesses subject to the Act must document the controls that they have implemented

Mr Green was in breach because he did not document that controls have been carried out to verify that the internal controls have been performed.

Reprimand

The reprimand was based on section 26(1) which requires businesses subject to it to issue a notification if it 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 did not issue a notification of this and therefore, was in breach.

Way Forward

Mr Green must act. That means they have to:

• Submit a revised risk assessment by June 10 2024

• Submit revised business procedure for internal controls and monitoring procedures as well

• Finally, they must submit documentation showing proof of carrying out internal control procedures by October 20 2024.

An 888 spokesperson said: “Following a routine audit of Mr Green by the Danish regulatory, Spillemyndigheden, we have three audit findings to address. We are working closely with the regulator and plan to make some minor amendments to our AML processes and accompanying documentation."

The reprimand would be fulfilled once the above three have been addressed.