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On 14 June 2023, the Danish Gambling Authority Spillemyndigheden has given Royal Scandinavian Casino Arhus I/S six orders for breaching the rules on risk assessment of section 7(1) of the AML Act (order a), business procedures of section 8(1) of the AML Act (order b), supervision of section 8(1) of the AML Act (order c), training material of section 8(6) of the AML Act (order d), performance of customer due diligence procedures of section 11 of the AML Act (order e) and performance of enhanced customer due diligence measures for guests from high risk third countries (order f).
Order a is given because Royal Scandinavian Casino Arhus I/S has made an insufficient identification of customer types, including foreign PEPs and PEPs in international organisations and their family members and close associates. Moreover, identification and risk assessments have not been made of individuals subject to financial sanctions. When the risk assessment does not sufficiently describe the factors connected to their guests, the risk assessment does thereby not cover all areas of their business model.
Order a is also given because Royal Scandinavian Casino Arhus I/S has made an insufficient identification and risk assessment of the use of cash as a means of payment. Given that an inclusion of mitigating initiatives has been done too early, a correct assessment of this factor has not been made, which is why the inherent risks are not stated correctly. Thus, the risk assessment does not cover all areas of their business model.
Order b is given because Royal Scandinavian Casino Arhus I/S does not have sufficient written business procedures. The business procedures lack sufficient procedures for the performance of customer due diligence measures for high-risk customers, enhanced customer due diligence measures for PEPs and their family members and close associates and for the obligations to report.
Order c is given because Royal Scandinavian Casino Arhus I/S has not complied with their own business procedures for the performance of internal controls of procedures for customer due diligence measures, procedures for investigation and registering, procedures for reporting and procedures for record-keeping.
Order d is given because Royal Scandinavian Casino Arhus I/S does not have sufficient training material about enhanced customer due diligence measures for PEPs, prevention of financing of terrorism, and individuals subject to financial sanctions. The training material is, therefore, not sufficient to ensure that the employees have an adequate knowledge of the obligations of the AML Act in relation to Royal Scandinavian Casino Arhus I/S as a business.
Order e is given because Royal Scandinavian Casino Arhus I/S has not performed sufficient customer due diligence measures, as a customer had not been verified correctly in accordance with the requirements of section 11(2) of the AML Act.
Order f is given because Royal Scandinavian Casino Arhus I/S has not performed sufficient customer due diligence measures for guests from high-risk third countries given that information about the origin of the funds and the source of the customer’s assets have not been procured in relation to the requirements of section 17(1)(3) of the AML Act.
The Danish Gambling Authority notes that the rules on risk assessment, business procedures, training material and customer due diligence measures are fundamental parts of the Anti-Money Laundering Act. As a rule, breaches of the rules lead to an order or a reprimand or in serious or repeated cases, they are reported to the police.
The orders cause an obligation to act for Royal Scandinavian Casino Arhus I/S, since they must submit an updated risk assessment, updated business procedures, updated controls, updated training material and updated procedures for customer due diligence measures addressing the insufficiencies identified in the orders.
The Danish Gambling Authority has given Royal Scandinavian Casino Arhus a deadline of three months to correct the matters concerning the orders a-f.
