Two reprimands to Casino Copenhagen K/S for breach of the Anti-Money Laundering Act

The reprimands are issued in connection with the Danish Gambling Authority's inspection of Casino Copenhagen's material that Casino Copenhagen has prepared in order to comply with the Anti-Money Laundering Act. 
 
Reprimand a) is given because Casino Copenhagen in several cases has not investigated the background and purpose of transactions that are complex, unusually large or made in an unusual pattern, or do not have an apparent economic or legal purpose. Thus, Casino Copenhagen has not complied with the obligation to investigate under section 25(1) of the Anti-Money Laundering Act.   
 
Reprimand b) is given because Casino Copenhagen, upon suspicion or reasonable grounds to suspect that a transaction is or has been related to money laundering or terrorist financing, has not informed the Financial Intelligence Unit immediately. Thus, Casino Copenhagen has not complied with the notification obligation under section 26(1) of the Anti-Money Laundering Act.
   
The Danish Gambling Authority assesses that a violation of the investigation and notification obligations may have increased Casino Copenhagen's risk of being misused for money laundering. Sections 25 and 26 of the Anti-Money Laundering Act on investigations and notifications are fundamental to the Anti-Money Laundering Act, and the seriousness of the violations has therefore led to two reprimands. 

No obligation to act 

The reprimands do not entail any obligation to act for Casino Copenhagen, as the breaches no longer exists.

Learning points 

Gambling operators should ask themselves the following questions based on the breaches identified above to ensure that they cannot be misused for money laundering or terrorist financing: 

• Have you made sure that your notes regarding the investigation of suspicious transactions are described in a way that can refresh your memory and give others an understanding of the case?
• Have you made sure to include factual information and a description of what the survey resulted in when taking notes?
• Have you structured your business procedures in such a way that you immediately notify the Financial Intelligence Unit?