Reprimand issued to JackpotBet A/S for breach of the Anti-Money Laundering Act

The reprimand is issued in connection with an inspection of JackpotBet’s written material, which JackpotBet has prepared to comply with the requirement of the Anti-Money Laundering Act that JackpotBet must identify and assess the risk that JackpotBet may be misused for money laundering and financing of terror-ism.  

The reprimand was issued because, in the period up to 17 January 2024, Jack-potBet had an inadequate risk assessment, as JackpotBet had failed to identify and assess the risk factors associated with JackpotBet’s business model, includ-ing customers, products, transactions, delivery channels and countries and geo-graphical areas where the business activities are carried out.

The reprimand was also issued because, until 17 January 2024, JackpotBet had not carried out a separate risk assessment of each product and payment solution.

Section 7 of the Anti-Money Laundering Act states that companies subject to the Act must identify and assess the risk that the company may be misused for money laundering or financing of terrorism. 

Thus, JackpotBet has failed to comply with the risk assessment obligation in 
section 7 of the Anti-Money Laundering Act.

The Danish Gambling Authority assesses that an inadequate risk assessment may have increased the risk of JackpotBet being misused for money laundering. The purpose of the risk assessment is that the gambling operator must have a useful tool that provides an overview and understanding of where and to what extent the gambling operator is exposed to being misused for money laundering or financing of terrorism and what actions are needed to limit the risks thereof.

Duty to act

The reprimand does not result in a duty to act for JackpotBet A/S, as it is a no longer existing breach.

Learning points

Gambling operators should ask themselves the following questions in the light of the breaches identified above to prevent being misused for money laundering and financing of terrorism:

• Have we identified and assessed the risk of money laundering and financing of terrorism in all parts of our business model, including all customer types, products, transactions and payment solutions, delivery channels, geographical risks and organisational matters?
• Have we separately assessed the individual identified risk factors involved in the risk assessment? 
• Have we assessed each payment solution and each product separately?