According to Spillemyndigheden, the land-based casino breached several sections of the country’s Money Laundering Act.
The regulator said that the casino made insufficient identification and risk assessment of customer types, including foreign politically exposed persons (PEPs). Spillemyndigheden also noted a lack of identification and risk assessment of people subject to financial sanctions.
Danish law states that when risk assessments do not sufficiently describe factors associated with their guests, the assessment does not cover all areas of a business model. As such, this is deemed to be in breach of regulations.
Specific breaches of the Money Laundering Act included Section 7 (1) on risk assessment; Section 8 (1b) for business processes; and Section 8 (1c) on controls.
Spillemyndigheden also flagged Section 8 (6d) in relation to education; Section 11 (e) for implementing customer due diligence procedures; and Section 11 (f) on enhanced procedures for guests from high-risk third countries.
Breaches of regulation
Breaking down the six orders, the regulator said the first related to insufficient identification and risk assessment of the use of cash as a means of payment. It said as mitigating measures were considered too early this factor was not properly assessed and the assessment thus did not cover all areas of the business model.
The second order said the casino did not have sufficient written business procedures. The regulator said the venue lacks sufficient procedures for customer due diligence on high-risk customers, PEPs and their close business partners.
An order was also issued over the casino not complying with its own business procedures. These relate to internal controls of procedures for customer familiarisation, investigation and listing, as well as procedures for notification and storage.
The fourth order accused the casino of not having sufficient educational material regarding enhanced customer awareness procedures. Spillemyndigheden said the material currently available to staff would not cover all relevant areas of the Money Laundering Act.
The regulator also issued an order over a failure to carry out sufficient player familiarisation procedures. The casino was accused of not properly carrying out customer verification in line with the Act.
The final order referenced a failure to conduct sufficient customer due diligence procedures for guests from high-risk third. The regulator said the casino did not obtain knowledge as to source of funds or the player’s wealth.
“Spillemyndigheden notes that the rules on risk assessment, business procedures, training material and customer awareness procedures are absolutely fundamental in the Money Laundering Act,” the regulator said. “Violation of the rules leads as a clear starting point to injunctions or prosecution or, in gross or repeated cases, to a police report.”
Royal Scandinavian Casino Århus must now submit an updated risk assessment, business procedures, controls, training material and customer due diligence procedures.
The casino will have three months from the date of the orders (14 June) to comply. If it does not provide this information, the casino could be subject to further sanctions.
The ruling also comes after Spillemyndigheden this week issued two charges against Danske Licens Spil. The regulator ruled that the operator did not provide adequate anti-money laundering checks on a player.