Two reprimands and a police report against Insipia Limited (Betano) for violation of the Anti-Money Laundering Act 

Reprimand (a) is given because Insipia Limited should have carried out enhanced customer due diligence procedures on a newly established customer at an earlier stage. After 16 days, the customer had deposited a total of DKK 199,500 into his gambling account without Insipia Limited having tried to obtain documentation of the customer's income and assets. It was not until six months after the customer's deposits that Insipia Limited had attempted to obtain information from the customer about income and assets under the auspices of enhanced customer due diligence procedures. At the time when the customer had deposited DKK 199,500 into his gambling account, Insipia Limited should have tried to obtain the information from the customer, as the customer at that time already posed an increased risk pursuant to section 17(1) of the Anti-Money Laundering Act.

The customer's deposits to his gambling account totalling DKK 199,500 over 16 days deviate significantly from what an average customer is able to deposit into their gambling account with their private finances, and this increases the risk that the customer finances his or her spending with criminal proceeds. Despite the fact that the customer in the specific case had had a normal gambling activity and at the same time had suffered a significant financial loss by gambling, the customer still posed an increased risk based on the high deposit amount.

Reprimand (b) is given because Insipia Limited should have investigated the back-ground and purpose of the customer's unusually large deposits to his gambling account totalling DKK 199,500 over 16 days. It was not until six months after the customer's deposits that Insipia Limited carried out an investigation in order to confirm or disprove a suspicion that the customer's deposits were linked to money laundering. At the time when the customer had deposited DKK 199,500 into his gaming account, Insipia Limited should have investigated whether the customer's unusually large deposits could be explained on the basis of information about the customer's income and assets, e.g. by asking the customer for documentation of his source of income and assets in general.  

No obligation to act  

The reprimands do not entail any obligation to act for Insipia Limited, as the violation no longer exists.

Learning points  

Gambling operators should ask themselves the following questions based on the viola-tions in the specific case in order to mitigate the risk of being misused for money laundering or terrorist financing:

• Do we base our risk assessment of specific customers on factors that, among other things, increase the risk that customers finance their spending with criminal proceeds? 
• Have we designed our anti-money laundering system in such a way that we also mitiage the risk that customers' gambling spend may be financed by criminal proceeds? 
• In our ongoing monitoring of customers, have we taken a position on when, based on the overall knowledge of each individual customer, there are unusually large transactions?

Police report of Insipia Limited for violation of the Anti-Money Laundering Act 

On April 27, 2026, the Danish Gambling Authority has reported Insipia Limited to the police for having grossly negligently violated the requirements for enhanced customer due diligence procedures pursuant to section 17(1) of the Anti-Money Laundering Act and the requirements regarding the duty to investigate unusually large amounts pursuant to section 25(1)(1)(b) of the Anti-Money Laundering Act in the period from May 2025 to January 13, 2026.