Order issued to AG Communications Limited for breach of the Anti-Money Laundering Act

The reaction has been given in connection with the Danish Gambling Authori-ty's inspection of AG's written material, which AG has prepared with a view to complying with the Anti-Money Laundering Act's requirement that AG must identify and assess the risk that AG may be misused for money laundering and financing of terrorism.

The order has been issued because AG's risk assessment is inadequate, as it contains an inssuficient identification and assessment of risk factors associated with AG's payment solutions and products. 

The order has also been issued because AG's risk assessment is inadequate, as it does not contain a separate assessment of the risk associated with each of AG's payment solutions and products. 

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, AG has not complied with the obligation to carry out a risk assessment in section 7 of the Anti-Money Laundering Act.  

The Danish Gambling Authority assesses that an inadequate risk assessment may increase AG's risk of being misused for money laundering. The purpose of the risk assessment is for the gambling operator to have a useful tool that provides an overview and an understanding of where and to what extent the gambling operator is exposed to being misused for money laundering or financing of terrorism, and what measures are necessary to limit the risks thereof.

Duty to act

The order entails a duty to act for AG. AG must submit a revised risk assessment addressing the order no later than 2 September 2024.

Learning points

Gambling operators should ask themselves the following questions in light of the violations identified above in order to prevent them from being misused for money laundering or 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 payment solutions and products? 
• Have we separately assessed the risk factors identified as risk factors included in the risk assessment? 
• Have we separately risk-assessed each payment solution and each product?