Police report and order for Tipwin Limited
On 21 June 2022, the Danish Gambling Authority has reported Tipwin Limited (hereafter referred to as Tipwin) to the police for breaching the rules on risk assessment, policies, business procedures, and supervision of sections 7(1) and 8(1) of the Anti-Money Laundering Act regarding their provision of land-based gambling products.
At the same time, the Danish Gambling Authority has given Tipwin an order for breaching the rules on risk assessment, business procedures and the obligation to train staff of sections 7(1), 8(1) and 8(6) of the Anti-Money Laundering Act regarding their provision of land-based gambling products. The order is also given for breaching the rules on business procedures of section 8(1) cf. 26(1) regarding their provision of online gambling products. It should be noted that the Danish Gambling Authority on 9 September 2022 has annulled the order related to breach of the obligation to train staff of section 8(6) of the Anti-Money Laundering Act.
Police report
The Danish Gambling Authority has reported Tipwin to the police, because Tipwin up until 16 May 2022 had not prepared a risk assessment of their sale of land-based betting products and did not have written procedures on their provision of their land-based gambling products. Moreover, Tipwin did not have sufficient business procedures for and supervision of their provision of land-based gambling products in relation to Anti-Money Laundering up until 25 May 2022.
The Danish Gambling Authority notes that the rules on risk assessment, policies and business procedures are fundamental parts of the Anti-Money Laundering Act. By neglecting to prepare a risk assessment, Tipwin has not had a useful tool to provide an overview and understanding of where and to which extent Tipwin is in risk of being abused for purposes of money laundering or financing of terrorism and which measures ae necessary to mitigate the risks hereof. Preparation of a risk assessment of the business’ business model is a fundamental means to mitigate the risk of money laundering of criminal proceeds. Thereby, Tipwin has not had policies and operational business procedures in place based on the risk assessment. By neglecting to prepare a risk assessment, policies and sufficient business procedures for their provision of land-based gambling products, Tipwin has exposed itself to a significant risk of being abused for purposes of money laundering.
Therefore, the Danish Gambling Authority has turned the case over to the police for investigation.
On 3 July 2023, Tipwin Limited accepted a fixed penalty notice of DKK 100,000 for a breach of sections 7(1) and 8(1) of the Anti-Money Laundering Act. Read more in the article "Tipwin Limited accepts fine of DKK 100,000 for breach of the Anti-Money Laundering Act" of 1 September 2023.
Order concerning provision of land-based gambling
The order for breaching the rules on risk assessment is given because Tipwin has not sufficiently identified the risk represented by using their self-service terminals.
The order for breaching the rules on business procedures is given because the Danish Gambling Authority has found that Tipwin does not have sufficient business procedures to mitigate the risk in relation to money laundering by use of self-service terminals, prize receipts and credit vouchers. In addition, the Danish Gambling Authority has found that Tipwin does not have sufficient business procedures describing how Tipwin must assess whether customers have made linked transactions of more than 2,000 euros within 24 hours.
The order for breaching the rules on training of staff is given because Tipwin has not sufficiently ensured that all employees have received training in the rules of the Anti-Money Laundering Act. Tipwin has not sufficiently documented that their retailers’ employees have received the compulsory training. It should be noted that the Danish Gambling Authority on 9 September 2022 has annulled the order related to the obligation to train staff.
Order concerning provision of online casino and online betting
In addition, an order is given for breaching the rules on business procedures because the Danish Gambling Authority has found that Tipwin has not prepared sufficient business procedures for their provision of online gambling products, regarding notifications to the Money Laundering Secretariat.
Deadline
The Danish Gambling Authority has given Tipwin a deadline of three months to correct the matters concerning risk assessment, business procedures and the obligation to train staff. It should be noted that Tipwin is no longer obligated to correct the matter as a consequence of the Danish Gambling Authority’s annulment of the order related to the obligation to train staff on 9 September 2022.