Orders and reprimands issued to 25syv A/S for violations of the Anti Money Laundering Act

The Danish Gambling Authority has also issued 25syv four reprimands for, in the period prior to 11 January 2026, having violated the Anti Money Laundering Act’s rules on business procedures under Section 8(1), ongoing monitoring of business relationships under Section 11(1)(5), the record keeping obligation under Section 25(3), and the reporting obligation under Section 26(1).

Orders

Order regarding violations of the rules on risk assessment has been issued because 25syv did not sufficiently assess the risks associated with their online offering and their land based offering.

Order regarding violations of the rules on internal controls has been issued because 25syv did not document that checks had been carried out to ensure that internal controls were carried out.

Order regarding violations of the rules on screening for politically exposed persons has been issued because 25syv did not conduct such screening.

Reprimands

Reprimand regarding violations of the rules on business procedures has been issued because 25syv’s business procedures up until 12 January 2026 were inadequate.

Reprimand regarding violations of the rules on ongoing monitoring of an established business relationship has been issued because 25syv, in the period from 1 October 2023 to 14 December 2025, did not conduct sufficient ongoing monitoring of their customers in the land based offering.

Reprimand regarding violations of the rules on the record keeping obligation has been issued because 25syv did not make adequate records in connection with investigations carried out under Section 25(1) of the Anti Money Laundering Act.

Reprimand regarding violations of the rules on the reporting obligation has been issued because 25syv, in one instance, did not report immediately after a suspicion of money laundering could not be dismissed.

Obligations to act

The orders entail an obligation for 25syv to take action, meaning that 25syv must submit an updated risk assessment.

25syv must also submit documentation showing that checks have been carried out to ensure that internal controls have been performed, as well as documentation showing that screening for politically exposed persons has been conducted.
The Danish Gambling Authority has given 25syv deadlines of one month, three months, and six months to remedy the issues covered by the orders.

The reprimands do not entail any obligation for 25syv to take action, as they concern violations that no longer exist.

Learning points

Providers of gambling services should consider the following questions to ensure that they cannot be misused for money laundering or terrorist financing:

• Have we assessed the risks associated with all our products and payment solutions, based on the way we offer them? Does the assessment reflect the differences between, for example, a land based offering and an online offering?
• Are our business procedures adequate, practical, and compliant with the requirements of the Anti Money Laundering Act?
• Have we carried out internal controls, as well as checks to ensure that these controls are performed, and can we document this?
• Do we screen whether a customer is a politically exposed person, and can we document this?
• Do we conduct ongoing monitoring of our customers, including their transactions, so that we are able to assess whether the transactions are consistent with our knowledge of the customer and the customer’s business and risk profile?
• Do we regularly check that our systems for monitoring customers are functioning properly?
• Do we make complete records of the elements included in an investigation, including the basis for the investigation, the information considered, and the conclusion of the investigation?
• Do we report immediately if a suspicion or indication of money laundering cannot be dismissed?