The Danish Gambling regulator Spillemyndigheden issued three injunctions to Mr Green, after determining that the operator had violated the Money Laundering Act of the country.
Spillemyndigheden has identified three concerns regarding Mr Green’s activities in Denmark. This includes insufficient risk assessments, flawed and missing business process, and a lack of documentation.
M. Green is also facing prosecution in another case relating to the anti-money laundering process.
Injunctions are broken down
Spillemyndigheden referred to the “flawed risk assessment” as being the first cause for concern. This was specifically in relation to Section 7 (Money Laundering Act).
The regulator stated that a risk analysis should also include an assessment of the risks associated with individual payment options and delivery channels. The Act is violated by Mr Green because it does not have a separate risk assessment.
Spillemyndigheden stated that “companies covered by law must assess and identify the risks of the company being used for money laundering, or financing terrorism.”
Second, the injunction is for a failure to have adequate business procedures and internal controls.
Spillemyndigheden stated that the systems currently in place at Mr Green did not refer to the intervals at which checks must be performed. The regulator notes that Mr Green has no written procedures about how to conduct checks.
In Section 8, the Act requires that companies have written procedures and internal controls.
The requirement of internal control implies that it is necessary to check whether controls have been carried out. The regulator stated that the control was being monitored. Mr Green did not comply with the business process requirements for controls.
In the final injunction, there is a focus on a failure to document checks. The regulator claims that Mr Green failed to document any information regarding internal or external controls.
This is also in line with Section 8 (of the Act). The law states that companies are required to document the checks they have conducted.
Mr Green is facing prosecution
Spillemyndigheden also chose to prosecute Mr Green for a violation of Section 26.
It is a legal requirement that companies notify the Money Laundering Secretariat if they have any suspicions of money laundering, or financing terrorism. The prosecution of Mr Green will be brought about because it failed to meet these obligations.
“Mr. Spillemyndigheden stated that Green had not met his obligations in terms of notifications as there was no notification immediately.
What’s next for Mr Green
Spillemyndigheden has provided details on its “duty to behave” in the future. The three injunctions that were filed against the operator are referred to.
Green must first submit an updated risk assessment as well as a business process to implement internal controls, by the 10th of June. The company must submit a business process for the way controls are carried out.
M. Green is also required to submit proof of checks by the 10th October.
Spillemyndigheden said that there was no legal obligation for them to take action on behalf of Mr Green as the alleged infraction did not exist.
