Newsletter no. 41 annual account 2018

03, May 2019

Annual account 2018

All betting and online casino licensees that have held a licence throughout the entire period between 1 January 2018 and 31 December 2018 must submit an annual account.

 

This year, the annual account is a questionnaire survey. The survey must be completed in one session, which is why we recommend that you have all relevant information ready before you start completing the survey. You will find a link and the corresponding code to the questionnaire survey in an e-mail that you will receive from your legal contact person.

Licensees for whom 2018 was their first year providing gambling are not required to submit an annual account. These licensees must instead produce a report on their provision of gambling, which must be delivered no more than 14 months after the licence was taken into use.

A renewal of a licence is considered as a new licence, and all terms need to be fulfilled again, including the term about the report of the provision of gambling as described in the Act on Gambling section 43, 1.

When must the annual account be submitted

The Danish Gambling Authority must receive the annual account no later than 30 June 2019.

What should the annual account include?

The annual account must include the following:  Key financial data and a management report including information on the company’s main activities and developments, as well as a description of significant factors that have or are expected to impact the company.
 
Unless otherwise stated below, the annual account shall only include the provision of gambling at the Danish market in 2018.

For licensees with licence to provide gambling in Greenland, the annual account must also include the provision of gambling in the Greenlandic market.

Questions in the annual account 2018

1. The number of registered players for online casino divided according to age and gender. Players shall be divided into the following age groups: 18-25 years, 26-35 years, 36-45 years, 46-55 years, 56-65 years, 66-75 years, 76+ years.

2. The number of registered players for betting divided according to age and gender. Players shall be divided into the following age groups: 18-25 years, 26-35 years, 36-45 years, 46-55 years, 56-65 years, 66-75 years, 76+ years.

3. The number of registered players in the Greenlandic market.

4. Online casino – key financial data – Income. All the numbers must be in Danish kroner (DKK).
 a. Deposit
 b. Winnings  
 c. Commission
 d. Gross Gaming Revenue (GGR)
 e. Financial income
f. Other income 

5. Betting - key financial data – Income. All the numbers must be in Danish kroner (DKK).
 a. Deposit
 b. Winnings 
 c. Commission
 d. Gross Gaming Revenue (GGR)
 e. Financial income
f. Other income

6. Online casino - key financial data – cost – marketing cost, in Danish kroner (DKK), for the Danish market on the following media.
 a. TV
 b. Cinema
 c. Printed media
 d. Radio
 e. Internet: AdWords
 f. Internet: Banner adverts on third party websites
 g. Internet: Social media
1 Youtube
2 Instagram
3 Facebook
4 Twitter
5 Influencers
 h. Own homepage
 i. Email
 j. SMS
k. Other

7. Betting - key financial data – cost – marketing cost, in Danish kroner (DKK), for the Danish market on the following media.
 a. TV
 b. Cinema
 c. Printed media
 d. Radio
 e. Internet: AdWords
 f. Internet: Banner adverts on third party websites
 g. Internet: Social media
1 Youtube
2 Instagram
3 Facebook
4 Twitter
5 Influencers
 h. Own homepage
 i. Email
 j. SMS
k. Other

8. Online casino - key financial data – Cost – the number of allocated welcome bonuses to new players in 2018, divided in each quarter. Additionally, their value in Danish kroner (DKK) must be registered. Allocated bonuses is defined as the time when a player has accepted a bonus but have not yet fulfilled the bonus terms.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

9. Online casino - key financial data – Cost – the number of welcome bonuses to new players realised in 2018, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered. Realised number is defined as the number of bonuses where the player has fulfilled all the terms for the bonus offer, and thus gained access to the derived gains. Realised amount is defined as the amount to which the player has gained access by meeting the terms of the bonuses.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

10. Online casino - key financial data – Cost – the number of allocated bonuses to existing players in 2018, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered. Allocated bonuses is defined as the time  when  a player has accepted the bonus, but have not yet fulfilled the terms of the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

11. Online casino - key financial data – Cost - the number of bonuses to existing players realised in 2018, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered. Realised number is defined by the number of bonuses where the player has fulfilled all the terms for the bonus offer, and thus gained access to the derived gains. Realised amount is defined as the amount to which the player has gained access by meeting the terms of the bonus.
a. Q 1
b. Q 2
c. Q 3
d. Q 4

12. Online casino - key financial data – Cost – The number of prize payments where “free spins” have been used by players in each quarter of 2018. Additionally, their value in kroner minus the value of placed stakes must be registered. Stakes is defined as the amount that must be placed in order to activate the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
d. Q 4

13. Betting - Online casino - key financial data – Cost – the number of welcome bonuses to new players in 2018, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered. Allocation of welcome bonuses is defined by the time where a player has accepted a bonus but have not yet fulfilled the terms of the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

14. Betting - key financial data – Cost – the number of welcome bonuses to new players realised in 2018, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered Realised number is defined as the number of bonuses where the player has fulfilled all terms for the bonus offer, and thus gained access to the derived gains.  Realised amount is defined by the amount to which the player has gained access by meeting the terms of the bonuses.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

15. Betting - key financial data – Cost – the number of bonuses to existing players in 2018, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered Allocation bonuses is defined as the time where a player has accepted a bonus but have not yet fulfilled it with the terms of the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

16. Betting - key financial data – Cost - the number of bonuses to existing players realised in 201, divided in each quarter. Additionally their value in Danish kroner (DKK) must be registered Realised numbers is defined as the number of bonuses where the player has fulfilled all the terms for the bonus offer, and thus gained access to the derived gains. Realised amount is defined by the amount to which the player has gained access by meeting the terms of the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

17. Betting - key financial data – Cost - The number of prize payments where “free bets” have been used by players in each quarter of 2018. Additionally, their value in kroner minus the value of wagered stakes must be registered. Stakes are defined as the amount that must be placed in order to activate the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

18. Betting - key financial data – Cost - The number of refunds issued in each quarter of 2018, where the licensees refund a players’ stake if the bet is unsuccessful (often called “risk-free bets”), and their value in kroner. Stakes are understood defined as the amount that must be placed in order to activate the bonus.
 a. Q 1
 b. Q 2
 c. Q 3
 d. Q 4

19. Online casino - key financial data – cost – All the numbers must be in Danish kroner (DKK).
 a. Gaming fee
 b. staff costs
 c. Financial income
 d. Write-offs and write-downs
e. Other external costs (excluding bonus)
 f. Taxes paid on profits
g. Net profit for the year

20. Betting - key financial data – Cost - All the numbers must be in Danish kroner (DKK).
 a. Gaming fee
 b. staff costs
 c. Financial income
 d. Write-offs and write-downs
 e. Other external costs (excluding bonus)
 f. Taxes paid on profits
 g. Net profit for the year

21. When land-based betting is provided, the following information must be submitted:
 21.1 Number of serviced terminals installed in stores and betting shops
 21.2 Number of self-service terminals installed in stores and betting shops
21.3 Number of terminals that provide betting on the result of an electronically simulated sporting event
 21.4 Number of terminals installed at land-based casinos
21.5 Total revenue BSI? on betting on results of electronically simulated sporting events
21.6 Fill in the five gambling premises with the largest revenue BSI? on betting on the result of electronically simulated sporting events as well as the revenue of the individual gambling presmises

22. Limitation – do your company apply limitation of players?
 a. Yes
 b. No

23. Complaints
a. The number of complaints received from players (the definition of a complaint is when a player disagrees with a licensee’s handling of a case or the result thereof.)
b. The average processing time for handling a complaint.
c. The number of complaints where the processing time has exceeded 14 days.

24. Deposit limit - The number of players who set a deposit limit for themselves in each quarter of 2018:
a. Daily – Q 1
b. Daily – Q 2
c. Daily – Q 3
d. Daily – Q 4
e. Weekly – Q 1
f. Weekly – Q 2
g. Weekly – Q 3
h. Weekly – Q 4
i. Monthly – Q 1
j. Monthly – Q 2
k. Monthly – Q 3
l. Monthly – Q 4

25. Self exclusion - The number of players who have temporarily excluded themselves:
a. 24 hours
b. 30 days
c. Over 30 days
d. Permanent self-exclusion
e. Other

26. A management report including information about the company’s main activities and developments, as well as a description of significant factors which have or are expected to impact upon the company.
If the company is part of a business group, any uncertainties relating to both the company and the group must be described. Furthermore, information on key events such as campaigns, changes in the gambling products offered or gambling platforms must be provided, as well as other significant activities. In addition, ex-pectations for the following year must be stated in the management report.

27. Have you taken any measures to ensure that you do not send marketing to self-excluded players?
a. Yes
b. No

28. By ticking off, please state whether your risk assessment, cf. section 7 (3) of the Danish Anti Money Laundering Act. 1, contains some of the specified items. Please note that the list cannot be considered as a positive list in relation to the requirement in the Anti Money Laundering Act section 7, as your risk assessment should reflect your specific business model. The list therefore constitutes examples of risk factors. The factors depend on your business model.
a. By "Game" is meant whether the risk assessment considers the individual or inherent risks of the game or the game category.
b. By “Players” is meant whether the risk assessment considering players as e.g. “high rollers”, and other categories by the players’ individual inherent risk.
c. A politically exposed person, closely related and close partners is defined in section 2 (2) of the Danish Anti Money Laundering Act. 1, No. 6-8, to which reference is made.
d. “Level of know your customer procedure” is to be understood, as if the risk assessment is defining the individual categories of players, for whom you must make an enhanced due diligence cf. the Danish Anti-Money Laundering Act section 17.
e. By “Gaming behavior” is meant the players’ behavior on your gaming platform in the games and the interaction with your customer support via chat, email and phone.
f. "Indication of strawman activity" means whether the conduct of the player in any event indicates that the player is acting on behalf of another person.
g. By “temporary account” means, whether the risk assessment addresses the inherent risks in such an account.
h. "Transaction sizes" means that you base your business model on your segment transactions such as deposits and payments, game transactions and unusual transactions for the player on a risk scale.
i. "Transaction behavior" means how the player makes transactions. This may be compared with the point below.
j. "Activity level" means, for example, whether the player inserts funds without or with very little game activity.
k. “Jurisdictions" means that if the risk assessment covers the providing of gambling in several jurisdictions, the assessment must reflect the risk that is involved in the individual jurisdiction. For example, the risks that may arise in the Danish market may differ from the risks in the Greenlandic market for gambling.
l. "Payment means / services" means an assessment of the inherent risks of the applied credit cards, e-wallets etc.
m. "Difference in payment and payment channel" means if the player deposits money into his gaming account with one payment/payment service and requests for the payment to another payment / payment service.
n. "Delivery channels" means if, for example, land-based (betting), web-based and tablet or phone-based platforms are assessed for the inherent risks.
o. "Cash (land-based betting)" means the inherent risks arising from the use of cash.
p. By "Loyalty card or pay-card with transfer function to bank account (land-based betting) " means the inherent risks of offering an introductory source of cash to the financial system.
The instructions for item 28 - The Danish Anti Money Laundry Act, section 11, paragraph 1. 1, 5 or 18 (1). 2 indicates that you must investigate the source of the player's funds if necessary. Disclose how this knowledge is achieved, including what external sources (if applicable) you used to gain this knowledge about the player.

29. Describe how you investigate the source of the funds, including which (if any) external sources you use.
a. Please list the external sources used
b. If you use external sources please state what the individual source validates?
The instructions for item 29 - The Danish Anti Money Laundry act § 7 (1) indicates that your risk assessment must be updated on a regular basis. If you have updated your risk assessment for the period covered by the statement, you must specify this by selecting the number of times that you have updated the risk assessment during the period.

30. How many times have the internal policies, procedures and controls been up-dated during the period covered by the statement?
a. 0
b. 1
c. 2
d. 3
e. 4
f. More

The instructions for item 31 - The Anti Money Laundering Act section 26 states that you should notify the State Attorney for Special Economic and International Crime about any transactions or inquiries which you suspect have or have been associated with money laundering or terrorist financing, to. State how the notifications have been divided into the following categories:
·         STR (Suspicious transaction report)
·         SAR (Suspicious activity report)
 
See regulation No. 1403 of 1/12 2017 on submission of notifications, etc. to the State Attorney for Special Economic and International Crime.

31. Please, enter the number of notifications that you have made during the period covered by the statement by the following categories:
a. STR
b. SAR

The instructions for item 32 – Match-fixing - Specify whether you are connected to an external alarm and monitoring system created to detect suspicious transactions or behaviour related to match-fixing. The system may be offered either by a private entity or a public authority or entity.
If the answer is yes, please state the name of the company/public authority providing the system.

32. Betting - Match Fixing, Item. 32. Betting – Match-Fixing - Are you connected to an external alarm and monitoring system.
 a. Yes
 b. No

33. If yes, which external system
a. 1
b. 2
c. 3

The instructions for item 33 - Item 32 is a supplement to Item. 33, where you must specify the measures, which you have implemented, cf. regulation on online betting and/or ordering of land based bets based on transactions related to bets.
If the answer is yes, you must indicate whether it is an external system and the name of the company or public authority providing the system.

34. Betting – match-fixing - Do you use a transaction-based alarm and monitoring system?
a. Yes
b. No

35. Is it an external system
a. Yes
b. No

36. If yes, which system are you using?
Instructions for item 36 – Match-fixing - You must indicate if an implemented alarm and monitoring system's results are reviewed internally by one or more persons before deciding to cancel bets cf. regulation on online betting and / or land-based betting notice.

37. Betting – match-fixing – Is a suspicious bet analysed by one or more persons?
a. Yes
b. No

38. Please, indicate which risk parameters are included in the risk assessment.
 
39. Responsible Gaming - Is it possible for people under 18 years to create and play from a temporary account.
a. Yes
b. No
 
40. If yes, how many times has it occurred that people under 18 have created and played from a temporary account in the period 01/01 2018 - 31/12 2018?
 
41. Responsible Gambling - Is it possible for a player to make a payment to a gambling account with different payment methods than credit cards?
a. Yes
b. No

42. If yes, please list which other payment methods, may be used.
 
43. Betting - Do you have any measures to ensure that betting is not provided for young people under the age of 18?
a. Yes
b. No
 
44. If yes, please list which measures.

45. Betting - Have you identified sale of betting for young people under the age of 18 years in the period between 01/01/2018 - 31/12 2018?
a. Yes
b. No

46. If yes. Please state how many times it has occurred in the period between 01/01 2018 - 31/12 2018?

47. Betting - Do you have a procedure in the event of sale of betting to young people under 18 years?
a. Yes
b. No
 
48. If yes, please account for your procedure.

49. Please, submit information on the contact person and contact information of the following
 49.1 The company’s contact person/email/tel. no.
 49.2 Legal contact person/email/tel. no.
 49.3 Technical contact person/email/tel. no.
49.4 The person responsible for gambling software and day-today running/email/tel. no.
 49.5 The person responsible for finance/email/tel. no.
49.6 The person responsible for anti-money laundering and combating financing of terrorism/email/tel. no.
 49.7 The person responsible for system changes/email/tel. no.
 49.8 The person responsible for IT security/email/tel. no.