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The Danish Gambling Authority Spillemyndigheden issued six orders to Royal Scandinavian Casino Arhus I/S on 14 June 2023 for violating the rules regarding risk assessment under section 7(1) AML Act, business procedures under section 8(1) AML Act, supervision under section 8(1) AML Act, training materials of section 8.6(6) AML Act and enhanced due diligence for guests from high-risk third countries.
Royal Scandinavian Casino Arhus I/S is required to issue an order a because it has not adequately identified customer types. This includes foreign PEPs, PEPs working in international organisations, and their families and close associates. The identification of those who are subject to financial sanctions and the risk assessment have also not been done. The risk assessment is incomplete if it does not adequately describe factors related to the guests.
Royal Scandinavian Casino Arhus I/S also gives order a because it has not adequately identified and assessed the risks associated with using cash as a payment method. The inclusion of mitigating measures was done too soon, and a proper assessment of this factor could not be made. This is why the inherent risk has not been stated correctly. The risk assessment doesn’t cover the entire business model.
Royal Scandinavian Casino Arhus I/S has not provided sufficient written procedures. There are not enough procedures in the business procedures to perform customer due diligence for high-risk clients, enhanced customer due due diligence for PEPs, their families and close associates as well as reporting obligations.
Order C is issued because Royal Scandinavian Casino Arhus I/S did not comply with its own internal control procedures of procedures for due diligence of customers, procedures of investigation and registration, procedures of reporting, and procedures of record-keeping.
Royal Scandinavian Casino Arhus I/S is issued with order d because it does not have enough training material on enhanced customer due diligence for PEPs and the prevention of funding of terrorism. It also lacks information about individuals who are subject to financial sanctions. The training material does not provide enough information to ensure that employees are aware of their obligations under the AML Act, in relation to Royal Scandinavian Casino Arhus I/S.
Royal Scandinavian Casino Arhus I/S is ordered to issue order e because it has not taken sufficient measures for customer due diligence, and a customer’s identity was not verified in accordance with section 11(2) AML Act.
The order f was issued because Royal Scandinavian Casino Arhus I/S did not perform sufficient due diligence on customers from high-risk countries, given that the information regarding the origin of funds and source of assets of guests had not been obtained in accordance with the requirements of Section 17(1)(3) AML Act.
Danish Gambling Authority states that the Anti-Money Laundering Act is fundamentally based on the rules relating to risk assessment, business processes, training materials and customer due diligence. In general, violations of the rules are punished with an order, a reprimand, or, in cases where they occur repeatedly or are serious, reported to the police.
Royal Scandinavian Casino Arhus I/S is under an obligation to act as a result of the orders, and must provide an updated risk analysis, updated business procedures updated controls, updated material for training, and updated procedures regarding customer due diligence.
Royal Scandinavian Casino Arhus has been given a three-month deadline by the Danish Gambling Authority to rectify the issues relating to the orders A-F.
