Spillemyndigheden, the Danish gambling authority, has issued six orders to Royal Scandinavian Casino Århus for violations of the country’s Anti-Money Laundering Act.
The six orders vary from risk assessment, business procedures, supervision, training material and customer due diligence procedures and measures.
Spillemyndigheden said in a statement: “On June 14th 2023, the Danish Gambling Authority has given Royal Scandinavian Casino Århus I/S six orders for breaching the rules on risk assessment of section 7(1) of the AML Act (order a), business procedures of section 8(1) of the AML Act (order b), supervision of section 8(1) of the AML Act (order c), training material of section 8(6) of the AML Act (order d), performance of customer due diligence procedures of section 11 of the AML Act (order e) and performance of enhanced customer due diligence measures for guests from high risk third countries (order f).”
The authority added that risk assessment, business procedures, training material and customer due diligence measures are “fundamental parts” of the AML Act and rule breaches will result in an order or a reprimand, while serious or repeated cases are reported to the police.
Order A was issued to Royal Casino Århus due to insufficient customer identification types “including foreign PEPs and PEPs in international organisations and their family members and close associates”.
Spillemyndigheden noted that identification and risk assessments of individuals weren’t made subject to financial sanctions, adding that “when the risk assessment does not sufficiently describe the factors connected to their guests, the risk assessment does thereby not cover all areas of their business model”.
Order A was also given due to “insufficient identification and risk assessment of the use of cash as a means of payment”.
The authority stated that “given that an inclusion of mitigating initiatives has been done too early, a correct assessment of this factor has not been made, which is why the inherent risks are not stated correctly. Thus, the risk assessment does not cover all areas of their business model”.
Order B was issued as the casino didn’t have sufficient written business procedures “for the performance of customer due diligence measures for high-risk customers, enhanced customer due diligence measures for PEPs and their family members and close associates and for the obligations to report”.
Royal Casino Århus was issued Order C for not complying with their own business procedures “for the performance of internal controls of procedures for customer due diligence measures, procedures for investigation and registering, procedures for reporting and procedures for record-keeping”.
Order D highlighted the casino’s lack of sufficient training material on “enhanced customer due diligence measures for PEPs, prevention of financing of terrorism, and individuals subject to financial sanctions”, which meant employees didn’t have “adequate knowledge of the obligations of the AML Act”.
For Order E, the authority noted that sufficient customer due diligence measures were not performed by the casino “as a customer had not been verified correctly in accordance with the requirements of section 11(2) of the AML Act”.
The casino was also issued order F as sufficient customer due diligence measures for guests from high-risk third countries were not performed “given that information about the origin of the funds and the source of the customer’s assets have not been procured in relation to the requirements of section 17(1)(3) of the AML Act”.
Following the issuing of the orders, Spillemyndigheden stated that Royal Casino Århus has an obligation to act and a deadline of three months has been set for the operator to correct the order’s matters.
As part of the obligation to act, the casino must submit “an updated risk assessment, updated business procedures, updated controls, updated training material and updated procedures for customer due diligence measures addressing the insufficiencies identified”.
