Reel Denmark Limited reprimanded for breach of Anti-Money Laundering Act

The reprimand was given because Reel have let a player deposit about DKK 2,4 million to his account in 2019 and 2020 without having sufficient knowledge of whether the player’s funds originated from criminal proceeds. It was only in the summer 2021 – after the Danish Gambling Authority had chosen the player for a spot check in relation to responsible gambling and money laundering – that Reel requested data on the player’s income and employment. Reel reached the conclusion that the player’s salary could finance the gambling activities – even though the player had deposited far more to his account than the amount, which the player would receive after taxes had been deducted from the salary. The Danish Gambling Authority assesses that Reel have breached the rules on KYC measures by not collecting the player’s data sooner. The Danish Gambling Authority also assesses that Reel should have further investigated the player’s circumstances, since the data on income and employment was not sufficient to disprove a suspicion of money laundering. Consequently, Reel have breached the rules on the obligation to investigate. 

The reprimand is also given because the Danish Gambling Authority finds that Reel should have suspected or had reason to assume that the player’s transactions might be related to money laundering. Based on this, Reel should have reported the matter to the Money Laundering Secretariat immediately. Reel only reported the matter to the Money Laundering Secretariat on 18 January 2022 – after the Danish Gambling Authority had consulted Reel on the case, and about two years after a suspicion arose, which could not be disproved. 

The reprimand does not subject Reel to an obligation to act since Reel subsequently has introduced new business procedures for KYC measures and the obligation to investigate to ensure that similar cases cannot take place in the future.