Newsletter 16

30 Aug 2013

The report about the first year's provision of gambling

30 August 2013

From February 2013 and on the Danish Gambling Authority has received reports from the holders of a licence to betting and online casino about their first year on the Danish gambling market. Reports are being received continuously as the gambling operators have been on the Danish market for a year.

It is a requirement in the Act on Gambling that a licence holder must complete and submit the report at the latest 2 months after the first year of gambling.

The Danish Gambling Authority appreciates the effort that  licence holders have put into completing the report. The reports give us useful insights in and a greater understanding of the activities of the licence holders which we are able to use in the future cooperation.

As part of the process we have asked additional questions to the content of some of the reports. Subsequently the licence holders have submitted revised reports.

Violations and points of criticism

From the content of the reports we have concluded that violations of the legislation have been committed. Minor violations will not be sanctioned if the licence holder rectifies the errors promptly.
In some cases we have decided on expressing criticism of the procedures etc. Below we have listed some of the areas where several licence holders have procedures which may possibly be violations of the legislation.

Shortly after the publication of this newsletter we will send a letter to all licence holders who have provided gambling from 1 January 2012 concerning our evaluation of their reports. Licence holders who have started the provision of gambling later will receive our evaluation of their report continually.

1. The geographical scope of the licence

A licence to betting or online casino may only be used to provide gambling in Denmark.

This means that provision of gambling in other countries cannot take place with a Danish licence regardless that the players open an account on the Danish version of the web page. In the same way it is only possible to provide gambling in Denmark with the Danish licence. This applies regardless of which licence the player has opened an account as a customer on.

This question is relevant in several of the situations which have been listed below. 

  • Players with an address in Denmark but who live in another country

Even if a player normally lives in another country, the player must gamble on the Danish licence when he stays in Denmark.

Section 2, 4, of the executive order states how players must be registered etc. Please notice that if the player has been verified in accordance with the Danish rules - regardless of whether the player has opened an account on another licence - it is not necessary to open an account again. All gambling must take place on the Danish licence when the player stays in Denmark. If this is not technically possible, the player should be denied access to play while he stays in Denmark.


  • Players with an address and residence in Denmark who claim to live in another country

A licence holder must have procedures which secure that all players with an address and residence in Denmark cannot open an account on another licence by stating another country of residence intentionally. The responsibility cannot be placed on the player and his potentially incorrect information. The most efficient way is to check the player's IP address.

All players who gamble on a gambling web page with a Danish IP address:
The player should not be able to place a stake in a game before the stated identity information is in accordance with the stated IP address.

Hidden IP address:
If the player has hidden his IP address when opening his account, this should alert the licence holder that further examinations should be carried out as quickly as possible.

  • Players who open an account on another web page than the Danish web page

All players who stay in Denmark and state their country of residence as Denmark when registering should automatically be redirected to the Danish licence before a stake in a game can take place.

  • Players whose residence is in Denmark but who travel abroad

When a player leaves the Danish territory, he is no longer subject to the Danish legislation, and the provision of gambling to this player should take place according to the rules in the country where he is staying.

Provision of gambling outside the Danish territory cannot take place with a Danish licence.

  • Especially about Greenland 

Several licence holders also have a licence to provide gambling in Greenland. The above rules also apply to the provision of gambling in Greenland.

2. Set-off free account

In connection with the processing of the applications for a licence to betting and online casino the Danish Gambling Authority approved the licence holder's procedures for the update of the set-off free account.

It has been an essential condition of issuing a licence that the players' funds are sufficiently secured. Modifications to procedures etc. cannot be accepted without the approval of the Danish Gambling Authority.

It is a condition in the licences that:

The licence holder must inform the Danish Gambling Authority at once if there are significant changes of the conditions in which the licence has been obtained. Of significance is among other things information which the licence holder has stated in the application and background material, including circumstances concerning the ownership of the licence holder, information about the criminal record and the financial terms of the gambling enterprise. 

3. Preventive measures against money laundering of profit and financing of terrorism

Online casinos must inform about suspicious transaction to The State Prosecutor for Serious Economic and International Crime (SEIC). It is our opinion that there have been too few notifications of suspicious transactions in the area of online casino compared to other areas. In 2012 there were made 3 notifications. At present in 2013 there have been only a few notifications.

All licence holders are recommended to go through their internal rules, procedures, guidelines etc. again. In that connection it is important to emphasize that a notification of a suspicious transaction is not a report to the police.

We will use the content of the reports in this area to intensify the supervision of selected licence holders' procedures in the area.