Casino Copenhagen reprimanded for AML policy failings

The regulator specified a number of failings – including a lack of risk assessments and defects in company policy.

The first reprimand dealt with violations of section 7, subsection 1 of the Act. The regulator found that Casino Copenhagen had made an “incomplete” assessment of their potential risks as a business, meaning that certain elements – including payment methods and customer types – were not adequately risk assessed.

Failings B and C dealt with a lack of written business procedures. Casino Copenhagen did not have full descriptions of how business-related tasks should be carried out. Procedures were incomplete in relation to politically exposed persons, customer due diligence and duty of investigation. Similarly reprimand C was issued because the casino’s lack of “sufficient” material meant that it was not possible to check whether the operator had the appropriate policies in place.

Reprimand D states that the material Casino Copenhagen used to educate its employees was “of a general nature”, and did not have sufficient anti-money laundering information for its employees.

The final failing dealt with section 35 of the Act. It addressed a lack of anonymity in Casino Copenhagen’s whistleblower scheme, which could have discouraged employees from speaking out.

Spillemyndigheden also issued an order for Casino Copenhagen to update its risk assessment policies to include assessing the confirmation of winnings.

The regulator stressed that Casino Copenhagen did not have an obligation to act on the prosecutions, as the casino has already submitted an updated risk assessment, business procedures, policies, teaching material and an updated whistleblower scheme.

However, Casino Copenhagen must submit an updated risk assessment that considers assessing the confirmation of winnings.

“The Gambling Authority notes that the rules on risk assessment, business procedures, policies, teaching materials and the whistleblower scheme are very basic in the Money Laundering Act, and violation of the rules leads as the clear starting point to injunction or reprimand or, in serious or repeated cases, to police reporting,” the regulator said in a statement.

Last week Spillemyndigheden reported German operator Tipwin to police for violations of Denmark’s Money Laundering Act.