Recommendations on anti-money laundering and responsible gambling

30, Jan 2015

The Danish Gambling Authority has reported an online casino licence holder to the police for violation of the anti-money laundering regulation. We have chosen to publish a summary of the case, so other casino licence holders can learn from this case. Additionally the Danish Gambling Authority wants to use the current case to give guidance to the gambling industry on their obligations in relation to responsible gambling.

The case relates to a player who has spent several millions at a gambling provider in the period from March 2012 to September 2013. At the bottom of this information you can find a link to the summary of the case.

Recommendation for all casino licence holders concerning their anti-money laundering obligations

The recommendation is for all license holders who provide casino. That is both online and land-based casino.
Players who spend large amounts (big spenders) are a money laundering risk factor. In the case the licence holder does not examine the player's origin of funds. In addition, the licence holder is not aware of the player's deposits which if not per transaction then cumulatively amount to large transactions. Therefore, the licence holder was reported to the police for failing to meet several obligations under the anti-money laundering regulation.
As a consequence of the case we recommend all licence holders to review their procedures, especially in relation to big spenders and the obligation to have knowledge about the players’ origin of funds. If you identify players where you do not have sufficient knowledge, you must examine the customer relations closer.

Please note, that it is not only players who are part of a customer loyalty programme who are covered by the term big spender in relation to the anti-money laundering regulation. A licence holder defines what a big spender is. The definition can be based on for instance what the average player in Denmark is estimated to spend on gambling, but the information should always relate to the licence holder’s own risk assessment. For the same reason a common industry definition of a big spender cannot be set as the definition should be based on the individual company’s risk assessment on anti-money laundering.
We also recommend license holders to remember to have focus on the players’ deposits on their player accounts in relation to online casino and in relation to land-based casino the funds that players spend on gambling.

Recommendation for all license holders concerning responsible gambling

In the same case the Danish Gambling Authority have expressed their grave misgivings concerning the provider's handling of the player and the provider's procedures with respect to responsible gambling.

The provider in the case does not use the information they have available about the player to start a dialogue with the player on responsible gambling measures.
Furthermore, the licence holder does not restrict their marketing initiatives towards the player despite the fact that there are several signs of danger for problematic gambling behaviour.

It is an obligation for every licence holder to have guidelines that ensure that proper steps are made to take due care of vulnerable players. As an end result If a company does not have sufficient internal rules and procedures in place it can cause the company to lose its licence to provide gambling. We therefore recommend licence holders to ensure that they have adequate guidelines within this area.

More information

Below is a link to the summary of the case. We have simultaneously published Newsletter no. 22 on general issues on money laundering.
You can also find more information about anti-money laundering obligations here:

We would also like to refer to the guidance that other gaming authorities issue within the area. For example the UK Gambling Commission has published an announcement which among other things concerns the failure to consider a player's origin of funds.

Case summary

Newsletter no. 22 on general issues on money laundering.

The Danish Gambling Authority's guidance on preventive measures against money laundering of criminal proceeds and financing of terrorism