Inspections and responses under the Anti‑Money Laundering Act
Supervision
The Authority supervises all gambling operators offering games in Denmark with a licence, as well as operators established in Denmark offering games in other countries.
Based on a risk assessment, the Authority selects specific operators for inspection to assess compliance with anti‑money laundering obligations.
Types of inspections
The Authority conducts three types of inspections: full scope, ad hoc and thematic.
- In a full scope inspection, the Authority checks whether the operator complies with all obligations in the Anti‑Money Laundering Act.
- In an ad hoc inspection, the Authority checks compliance with specific obligations.
- In a thematic inspection, the Authority selects a theme and reviews material from several operators. Operators must provide all information necessary for the inspection.
Inspection process
The Authority informs the operator that it has been selected for inspection and requests relevant written material that the operator is required to prepare under the Act.
The Authority reviews the material and assesses whether an interview is needed to clarify matters.
If the Authority finds grounds for a reaction, a written consultation letter is sent, giving the operator an opportunity to comment.
The inspection concludes with a decision: an injunction and/or reprimand, a police report, or a closing letter without a reaction.
If an injunction is issued, the operator will be offered a guidance meeting.
Reactions
Under the Anti‑Money Laundering Act, the Authority may issue an immediate improvement, a reprimand, an injunction, or report the operator to the police.
Immediate improvement
For uncomplicated and minor breaches of formal requirements, and where the operator acknowledges the error, the Authority may agree orally on an immediate improvement instead of issuing an injunction. The operator agrees to correct the matter immediately according to the Authority’s instructions.
Injunctions
The Authority may issue injunctions for breaches of the Act. The injunction will include a deadline by which the operator must comply.
An injunction cannot be used for breaches that no longer exist.
Reprimands
If a breach has been remedied by the operator, an injunction cannot be used. Instead, a reprimand may be issued. For serious or repeated breaches, the matter must be reported to the police.
Police reports
Intentional or grossly negligent breaches of several provisions may lead to a police report and ultimately a fine, unless a higher penalty applies under the Criminal Code. The limitation period is five years.
Publication
The Authority must publish all reactions under the Anti‑Money Laundering Act on its website. This includes all injunctions, reprimands and decisions to report an operator to the police. Publications must remain online for five years.